December 9, 2010
Dear Washington Fish and Wildlife Director Phil Anderson,
This letter is a formal request for the removal of the gray wolf from the state Endangered Species list in the Eastern Washington region. This request, according to WAC 232-12-297 (6.1), “should be addressed to the director. It should set forth specific evidence and scientific data which shows that the species may no longer be failing, declining, or vulnerable, pursuant to section 3.3.“
Per WAC 232-12-297, we have including the following biological information.
The recovery of the gray wolf in Eastern Washington and other portions of the West has already been established by the U.S. Fish and Wildlife Service when it removed of the gray wolf from the federal Endangered Species list for the Northern Rocky Mountains (NRM) region in 2009. A 2012 review of the biological status of the wolf, conducted by USFWS Wolf Management and Science Coordinator Mike Jimenez, stated, ”by every biological measure, the NRM Gray Wolf Distinct Population Segment (DPS) is fully recovered.”
The USFWS biological data affirms this point. An April 2, 2012 Service Review said:
“In 2011, the gray wolf population in the NRM DPS (Idaho, Montana, Wyoming, the eastern one-third of Washington and Oregon and a small portion of north central Utah) increased approximately three percent from 2010. Wolf packs, and especially breeding pairs, largely remained within the core recovery areas, but breeding pairs were again confirmed in eastern Oregon and Washington. On December 31, 2011, the NRM DPS contained at least 1,774 wolves in at least 287 packs. At least 109 packs met the definition of a breeding pair. We estimated there was a minimum of 431 wolves in the Northwest Montana Recovery Area, 499 in the Greater Yellowstone Recovery Area, and 797 in the Central Idaho Recovery Area. By state, within the NRM DPS, there were an estimated minimum of 653 wolves in Montana, 328 in Wyoming and 746 in Idaho. Twenty-nine wolves were estimated to be in eastern Oregon and 18 wolves (3 packs, 2 breeding pairs) were found within the NRM DPS in eastern Washington…the minimum recovery goal of an equitably distributed wolf population containing at least 300 wolves and 30 breeding pairs in Montana, Idaho, and Wyoming for at least 3 consecutive years (managed to maintain over 150 wolves and 15 breeding pairs in each state) has been exceeded in NRM DPS since 2002.”
This data, collected early in 2012, did not recognize the six additional Washington wolf packs confirmed by the Washington Department of Fish and Wildlife later in 2012. These additional packs positively augment the conclusive federal data that the wolf is recovered in eastern Washington and is no longer “failing, declining, or vulnerable” as required in state law for delisting.
We assert that the USFWS data has met the burden of proof showing recovery of the gray wolf in eastern Washington. For the Washington Fish and Wildlife Department to ignore this satisfaction is to ignore the science and data that shows wolves as recovered.
The USFWS also went on to say:
“By every biological measure, the NPM DPS wolf population is fully recovered. Resident packs have saturated suitable habitat in the core recovery areas and the population has exceeded recovery goals for 10 consecutive years. Dispersing wolves routinely travel between NRM states and Canada and successfully breed, demonstrating that the 3 sub populations function as a large NRM meta-population. Consequently, genetic diversity in the NRM remains very high…The status of the wolf population in the NRM DPS has consistently exceeded recovery goals in 2002 (as demonstrated by increased pack distribution and number of wolves, packs and breeding pairs in 2011).”
Additionally, the review noted how delisting had not harmed the population in the NRM:
“Delisting has not threatened the NRM wolf population, nor increased any threats to it.”
This data and subsequent conclusions show that the biological evidence is there to support delisting the wolf in eastern Washington, even without adding the additional state data from 2012.
That additional data, including the very public incidents of wolf depredation this summer on the Diamond M Ranch and in southern Stevens County, demand that a new course be taken in terms of managing this animal so it does not become and burden and detriment to the areas it inhabits.
If Washington State fails to transition from a recovery mindset to a management approach at this crucial time, especially when the data is showing such a transition is necessary, we can anticipate further issues with the wolf that will create financial and social disruptions.
In accordance with WAC 232-12-297 we anticipate a response to this letter within 60 days. If our request is denied, a full explanation of the causes and a refutation of the state and federal data is expected.
Scott Nielsen, President, Stevens County Cattlemen’s Association
Stevens County Cattlemen's Association 