SL: RE: RIN 1018-AU53 and RIN 1018-AV39
Dear Western Gray Wolf Recovery Coordinator,
As a supporter of Defenders of Wildlife, I strongly oppose the U.S. Fish and Wildlife Service's recent proposals regarding the management of gray wolves in the Northern Rockies (RIN 1018-AV39 and RIN 1018-AU53).
Specifically, I object to the Service's plan to redefine what are seen as "unacceptable impacts" on elk and other species (RIN 1018-AV39). The new, vaguer definition would cause wolves to be killed not just for causing game populations to fall below state targets, but also if wolves affect deer or elk movements or behavior in almost any way.
Such an approach is not based on sound science. According to the state wildlife agency estimates, game populations are thriving in Idaho, Montana and Wyoming.
I believe the revised definition would pose an unacceptable threat to the long term survival of gray wolves in the Northern Rockies. Under the proposed definition, endangered wolves could be killed just for fulfilling their natural role in the Northern Rockies' interconnected ecosystem -- down to only 200 wolves per state.
I also strongly oppose the proposal to accept Wyoming's management plan for gray wolves and remove gray wolves in that state from the list of Threatened and Endangered Species (RIN 1018-AU53). The plan now supported by your agency is strikingly similar to the proposal the U.S. Fish and Wildlife Service has rightly opposed until recently.
Wyoming's plan would classify wolves as "predatory animals" in the majority of the state, allowing wolves to be shot on sight by anyone at anytime. Trapping, baiting, and possibly even poisoning would also become legal.
Wyoming officials have already announced plans to kill all but 100 wolves as soon as possible, and to manage wolves at the lowest population levels that are legally permissible going forward.
Both of these proposals threaten the future of wolves in the Northern Rockies, and both should be rejected.
Thank you for considering my comments.