CAPR Comment to Department of Interior for Wolf Delisting

June 13, 2019 by Cindy Alia

The deadline is fast approaching for commenting on Wolf Delisting, here you can see comments submitted by CAPR on May13, 2019.

DEPARTMENT OF THE INTERIOR Fish and Wildlife Service 50 CFR Part 17 [Docket No. FWS–HQ–ES–2018–0097; FXES11130900000C2–189–FF09E32000] RIN 1018–BD60 Endangered and Threatened Wildlife and Plants; Removing the Gray Wolf (Canis lupus) From the List of Endangered and Threatened Wildlife

Citizens’ Alliance for Property Rights 718 Griffin Avenue, # 7 Enumclaw. WA 98022

Comments on rule-making document Docket No. FWS-HQ-ES-2018-0097

Citizens’ Alliance for Property Rights, (CAPR) is a non-partisan organization located in Washington State, and has membership throughout the State. Members share their collective experience, tools, and expertise, and translate that collaborative experience into collaborative action. Commenting on proposed rules reflects combined interests and concerns as expressed by CAPR members, affiliates, and a wide range of communities throughout the State of Washington.

CAPR supports, and is in favor of the proposed Federal Rule, Docket No. FWS-HQ-ES-2018-0097

Current wolf-pack habitat use in Washington is based on the mean home ranges of 15 packs with known territories. While 27 packs are known to occur in Washington adequate data has not been compiled to estimate home ranges of 12 of the known packs. CAPR anticipates a federal delisting leading to a comprehensive state-wide focused management plan would result in intensified documentation and management of wolf populations that will result in a more complete understanding of the establishment of self-sustaining wolf populations throughout all regions of Washington State.

Kelly Susewind, the Washington Department of Fish and Wildlife director, submitted a letter commenting on the U.S. Fish and Wildlife Services proposed rule, Docket No. FWS-HQ-ES-2018-0097. Director Susewind stated “The Department finds the USFWS proposal to remove gray wolves from the federal List of endangered and Threatened Wildlife and return management authority in the western two-thirds of Washington to the Department appropriate and timely,”.

Wolf populations in the eastern portion of the state have received much of the attention, documentation and management activity in Washington State. It is generally perceived a state-wide management based on the success of eastern Washington experience and expertise as managed by Washington State Department of Fish and Wildlife would be of benefit to the people and wolves of the State. The State manages wolf populations in the eastern 1/3 of the state, while federal endangered species act management is in place for the remainder 2/3rds of the state, CAPR believes director Susewind is correct in his assessment of wolf population management when he stated “The state of Washington is well prepared to be the management authority for wolves statewide and would be pleased to see limited federal resources directed to other species still critically in need,”.

There currently exists a minimum of 126 wolves, 27 packs and 15 breeding pairs in the state, according to WDFW’s most recent report. While most of those wolves live in Northeast Washington, there is evidence through tracking and scat studies, of wolf populations expanding beyond the eastern third of the state. CAPR believes comprehensive state-wide wolf management is the best path forward in wolf management plans as directed through the Washington State Department of Fish and Wildlife recovery objectives intended to ensure the reestablishment of a self-sustaining population of wolves in Washington.

In Washington State, it was anticipated that the wolf population in Washington would increase through natural dispersal of wolves from adjacent populations, and the eventual return of wolf management to the State would occur and after Federal delisting. Therefore, Washington state is well prepared for the federal delisting of the wolf with a management plan for wolves within the state. The purpose of the plan is to facilitate reestablishment of a self-sustaining population of gray wolves in Washington and to encourage social tolerance for the species by addressing and reducing conflicts. An advisory Wolf Working Group was appointed at the outset, beginning in 2011 to give recommendations on the plan. In addition, the plan underwent extensive peer and public review prior to finalization. The collaborative experience as established though this working group has resulted in an expanded understanding of the effectiveness and importance of a wolf plan that includes tools to manage and understand the presence and impact of wolf populations and the best management practices required to most effectively manage wolf populations at the State level.

The Washington State plan recovery goals are codified under state law and include strategies for regional recovery and conflict management with domestic animal husbandry and with managing the ungulate population.

The specific target numbers and population distribution goals are listed in state law:

To reclassify from State endangered to State threatened status: 6 successful breeding pairs present for 3 consecutive years, with 2 successful breeding pairs in each of the three recovery regions.

To reclassify from State threatened to State sensitive status: 12 successful breeding pairs present for 3 consecutive years, with 4 successful breeding pairs in each of the three recovery regions.

To delist from State sensitive status: 15 successful breeding pairs present for 3 consecutive years, with 4 successful breeding pairs in each of the three recovery regions and 3 successful breeding pairs anywhere in the State.

In addition to the delisting objective of 15 successful breeding pairs distributed in the three geographic regions for 3 consecutive years, an alternative delisting objective is also established whereby the gray wolf will be considered for delisting when 18 successful breeding pairs are present, with 4 successful breeding pairs in the Eastern Washington region, 4 successful breeding pairs in the Northern Cascades region, 4 successful breeding pairs distributed in the Southern Cascades and Northwest Coast region, and 6 anywhere in the State.

July 13, 2019