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Wolves
Wolf History, Conservation, Ecology and Behavior
[www.wolfology.com]
Peer Review for the Idaho, Montana and Wyoming Wolf Management Plans, 2003
U.S. Fish and Wildlife Service selected peer reviewers for the Montana, Idaho and Wyoming State Wolf Management Plans, October 2003. All are recognized authorities in wolf management and/or research, and each has 15-35 years experience with wolves, large predator/prey or livestock depredation issues.

1. Dr. Warren Ballard, professor and associate chair, Texas Tech University; retired Alaska G&F research biologist;editor, Journal of Wildlife Management.
2. Rod Boertje, Alaska Department of Fish and Game biologist; wolf and predator/prey research and management.
3. Mark McNay, Alaska Department of Fish and Game biologist; wolf expert involved in Alaska wolf management planning; helped plan capture efforts in Canada during wolf reintroduction in 1995 and 1996.
4. Dr. L. Dave Mech, USDOI Geological Survey Senior Research Scientist, Minnesota; leading world-wide authority on wolves; chair of IUCN Wolf Specialists Group.
5. Dr. Rolf Peterson, professor, Michigan Tech University; project leader Isle Royale Wolf Research; leader of Midwest Wolf Recovery Team.
6. Adrian Wydeven, Wisconsin wolf expert; lead state wolf biologist/management planner for Wisconsin Department of Natural Resources.
7. Dr. Paul Paquet, professor, independent researcher, wolf/carnivore predator/prey expert in Canada; conducted privately funded feasibility studies for NE and CA/OR.
8. Bill Paul, Minnesota USDA, APHIS, Wildlife Services; wolf control/depredation expert.
9. Jim Hammill, president, Iron Range Consulting & Services; just retired as biologist and manager from MI DNR; as the Michigan state wolf expert, he planned and led Michigan wolf recovery.
10.Dr. Dan Pletscher, professor, director of Wildlife Biology Program, University of Montana; predator/prey wolf expert, Boone and Crockett Club member.
11. Dr. Kyran Kunkel, Department of Ecology, Montana State University; Montana, Minnesota and Alaska research experience in wolves; PhD on wolf/ungulates in NW Montana.
12. Dr. Todd Fuller, professor, University of Massachusetts; editor, Wildlife Monographs; wolf/carnivore expert.
I.
October 15, 2003

...This replies to your request of September 12, 2003 to evaluate the wolf management plans of Montana, Idaho and Montana as to whether each plan  will achieve its objective and and if collectively they will maintain the Northern Rocky Mountain Wolf population at or above recovery level for the foreseeable future.
Assuming adequate funding, I judge that each of the state plans will achieve its objective because each proposes monitoring and regulations that should assure that human-related wolf-taking will not reduce state pack numbers to less than 15. Given the adequate prey base that appears available in each state, and assuming that known diseases will not affect this wolf population any more than they do others, and that new diseases will not arise, this protection from human-caused mortality should insure maintaining this wolf population at 30 or more breeding packs for the foreseeable future.
....Another point that should be considered is that each plan states that monitoring its wolf population will require radio-tracking. This need could expose packs to extra efficient taking if citizens were not prohibited from using radio-tracking to help find and kill wolves. Thus each state should prohibit use of the technique.
The classification of wolves in some parts of Wyoming as predators has been mentioned as a possible hindrance to Wyoming's ability to maintain 15 packs. However, the Wyoming plan has an apparent fail-safe mechanism that allows changing the area of predator designation and regulations when numbers of packs drop to 7 aside from the assumed 8 or more packs in the park. Thus, regardless of how the wolf is classified outside the 15-pack area, or what the regulations are for the predator classification, guaranteeing a 15-pack minimum should suffice to meet the state's goal.
Finally, some news reports have indicated that Wyoming's plan conflicts with Wyoming's laws. If so, obviously such a problem must be solved before one could have faith that the Wyoming plan could be put into effect.
L. DAVID MECH
II.
October 17, 2003

....After review of the state wolf management plans of Montana, Idaho, and Wyoming, I believe that the plans for the three states will collectively maintain a recovered wolf population at or above 30 breeding pairs of wolves. I examined nine components in each state plan that I considered to be critical or necessary for implementation of a successful state wolf management plan. These nine components were: 1) state wolf population recovery goal and management guidelines, 2) management area or zones, 3) wolf population monitoring guidelines, 4) prey base monitoring and options for controlling impacts by wolves on ungulates, 5) wolf-livestock depredation control guidelines and wolf compensation payments, 6) public harvest guidelines, 7) wolf education and accidental take of wolves guidelines, 8) contingency plan if wolf population falls below recovery criteria, and 9) funding/budget. I have commented on these nine plan components in my individual review of  each of the three state management plans. I found that these nine plan components were present in each state plan, and overall I was able to accept the management concepts presented by each state in their plan.
All three state plans have a minimum state wolf recovery goal of 15 or more packs which is above the federal recovery goal of 30 collective breeding pairs equitably distributed among the three states for three successive years. The Wyoming state wolf management plan appears to be the least tolerant of allowing wolves to expand or persist in areas of the state where they are not causing conflicts, but this is somewhat understandable because Yellowstone National Park in Wyoming will always represent a protected wolf subpopulation and dispersal reservoir for wolves to continue colonizing western Wyoming. The Wyoming plan's dual classification of wolves as either a "trophy game animal" or a "predatory animal," while contentious in terminology, is similar in some respects to the Minnesota Wolf Management Plan's Zone A and Zone B concept. Each of the three state plans has an adequate monitoring program and contingency plan to keep their state's wolf population from falling below federal wolf recovery criteria during the 5-year post-delisting ESFWS monitoring period. Each plan recognizes and emphasizes the continued connectivity between the populations of wolves in the three states.
....I believe that the USFWS delisting process for the Western Gray Wolf DPS can be started early, as the process will likely take longer than expected to be completed (2-3 years or more with anticipated legal challenges). It is very likely that...that an additional 5-10 wolf packs (breeding pairs) will be added to the wolf population of each of the three states during the period of time that the delisting process takes. While the wolf recovery population criteria for each state wolf management plan may seem to be at the minimum now, by the time that "delisting" actually occurs, each state will probably have a larger, more established wolf population that may be even more difficult to manage....
I feel that the greatest unresolved issue and obstacle to federal delisting of the Western Gray Wolf DPS and implementation of state wolf management plans for Montana, Idaho, and Wyoming is the reliance by all three states on federal funding to implement their plans post-delisting. Essentially, each of the state plans is unfunded at this time except for the current federal funding being allocated to USDA Wildlife Services for wolf depredation control in each state. If federal funds are to be relied upon by the three states, a Congressional funding initiative needs to be completed before or in conjunction with the federal wolf delisting process....Possible federal funding sources are a Congressional national wolf funding initiative for state wolf management plans post-delisting, Congressional approval of the Rocky Mountain Grizzly Bear and Gray Wolf National Management Trust, and/or CARA. The success of the three state plans (or the degree to which they will be implemented) will be dependent upon the amount and annual guarantee of federal funding.
If adequate federal funds are not allocated to the three states...some states may elect not to participate in wolf management, or they will only implement "bare bones" wolf management plans....Depredation control or public harvest would likely be given the highest priority and wolf population monitoring/estimation, enforcement, and educational efforts would be given less priority....I would worry more about how the state wolf management plans are to be funded post-delisting than any perceived shortfalls in the state plans themselves....
....Additionally, state wolf management plans (Minnesota, Wisconsin, and Michigan) for the Eastern Gray Wolf DPS were developed more around the use of state funding for implementation of the plans. If Western Gray Wolf DPS states receive federal funding...the Eastern Gray Wolf DPS states will also request federal funding. This would set the stage for a huge national wolf funding request...and would generate intense competition between wolf states for any federal funds allocated by Congress.
BILL PAUL
III.
I found...Montana's plan to exhibit a responsible and respectful attitude toward the federal recovery criteria. Given time for wolves to more fully occupy available habitat in Montana, I believe the Montana plan will achieve the USFWS plan for close to 10 "breeding pairs" in Montana. The plan itself is well thought out and comprehensive.
The question I am left with from the state's perspective is how much "wolf habitat" exists in Montana and is there an educated guess as to how many breeding pairs can be supported in decades to come? This question is worth pursuing because Montana is the only state mentioned here that does not currently have 10 breeding pairs....I assume that the federal plan presumed that suitable, sufficient, and sustainable wolf habitat exists in Montana to meet their objectives far into the future. If this is true, then my question is answered. However, the Montana plan states that private lands are required to meet the federal criteria for wolf numbers, and how those private lands eventually get subdivided and utilized by humans will bear on the ability of the state to produce wolves. How does one guarantee suitable wolf habitat on private lands that may some day be subdivisions?....I would like to see the issue of suitable and sufficient habitat addressed in the delisting criteria.
....I found Wyoming's plan for 15 packs, 7 outside the parks, to be adequate to achieve the Service's plan for 10 breeding pairs. Habitat is adequate and prey resources appear more than adequate for the immediate future. I suspect that, with both increasing bear and wolf populations, prey availability will eventually decline significantly. The result on wolves will likely be a decline in pack size and an increase in territory size. With a finite amount of habitat, an increase in territory size will result in fewer sustainable packs. However, given the current use of space and far more than the required 10 breeding pairs, I see every reason to suspect that 10 breeding pairs can be guaranteed given Wyoming's plans, apparent commitment to the process, and desire to assume responsibility.
....Idaho's plan is to provide for 15 packs, and to begin remedial measures if the number of packs falls below 15 packs. Given the considerable wolf habitat in the state and the current numbers of wolves (about 346 wolves in 21 breeding pairs), I see every reason to believe that Idaho will continue to support 10 breeding pairs of wolves.
....I notice that Idaho has more than its fair share of the supposedly "equitable" distribution of wolves among the 3 states, yet Idaho has no management authority until delisting occurs. The federal entities would be wise to turn over management before the increase in wolf numbers becomes overly burdensome for Idaho and its residents. Manageable numbers of wolves are always more acceptable to the public than unmanageable numbers. For example, if the public perceives that the federal process values wolves more than humans by postponing delisting while problems escalate, then the federal government will jeopardize the trust that is necessary for the public to accept wolves. Public trust is essential to successful reintroduction of wolves.
....I recommend that the states attempt to encourage  tours to view or hear wolves, particularly in subalpine areas or areas without continuous overstory. Wolves are one of the most viewable large predators, particularly if animals are radiocollared. Wolves readily habituate to aircraft. A source of revenue will increase the acceptance of wolves.
ROD BOERTJE
IV.
October 22, 2003
....Idaho
The Idaho Wolf Conservation and Management Plan asserts the State of Idaho's intent to maintain a viable wolf population at or above the minimum recovery level for the foreseeable future, but I believe some objectives and management actions are not adequately defined within the plan.
The plan identifies management thresholds at 10 packs and 15 packs, but does not define a pack. The plan includes a map showing the location of 17 wolf packs in 2001, but an Idaho Fish and Game (IDFG) leaflet dated September 5, 2003 states that "in December 2002, the Federal Government estimated 285 wolves in 10 breeding pairs, and 19 packs were distributed throughout Idaho. " If the ratio of packs to breeding pairs is 1.9  then the triggering thresholds of 10 and 15 packs as stated in the plan could mean that only 5-8 breeding pairs existed....Therefore, if delisting requires maintenance of 10 breeding pairs as defined by the United States Fish and Wildlife Service (USFWS) (an adult male and female wolf that raise at least 2 pups until December 31) the Idaho plan as written does not necessarily meet the requirement.  However, I suspect the discrepancy is more semantic than substantive and could be easily rectified with minor edits in the planning document....
The plan specifies increasingly intensive monitoring if less than 15 packs exist but only vaguely outlines a monitoring protocol, i.e., "...focus on selected packs from representative areas across the state as support dictates"...."Monitoring of selected packs is best done by radio-collaring one or more individuals." During the first 5 years following delisting, I suggest most of the minimum 10 packs will have to be radio collared to ascertain the existence of breeding and pup survival to mid winter. A combination of track surveys, general field observations, howling surveys, hair analysis, inventory of known den sites, and other methods will be helpful, but it is difficult to differentiate between adjacent packs based on those index methods alone.  Without radio telemetry some packs will be missed and others will be double counted....
....The plan also states that population growth is unlikely to be controlled by sport hunting. This is generally true in northern Canada and Alaska where wolf distribution is continuous over thousands of square miles that are largely unoccupied by humans, but that may not be directly applicable to recovering populations in Idaho, Wyoming and Montana where human densities are much higher, human ground access is more developed and wolf distribution is not continuous. I believe that evaluating the effects of sport hunting and trapping on wolf populations in the recovery areas will be an important new area of research. I recommend harvesting monitoring programs that identify not only sex and age, but also attempt to identify pack affiliation and reproductive status of harvested female wolves during the initial 5 years of state management.
....I expect wolves in Idaho could achieve an average density of at least 7.5 wolves/1000km2 in suitable habitat, or a population of roughly 585 wolves, more than twice the current population.
....At the current wolf population size of 263 wolves in Idaho and a kill rate of 15.6 elk per wolf per year, wolves would take roughly 4,100 elk. If wolves continue to colonize vacant habitat and achieve moderate densities of 7.5 wolves/1000km2 and a population of 585 wolves, they would kill approximately 9,000 elk per year....The 5 year average annual elk harvest by hunters in Idaho 1995-1999 was 20,500 elk. With a growing wolf population in Idaho, managers may have to curtail harvest by hunters to maintain current overall mortality rates on elk. However, wolf kill rates on elk could be substantially lower if wolves selected deer in Idaho more than they do in Yellowstone.
....Idaho will probably try to manage for the minimum number of wolves required by the delisting criteria because their goal is to "...manage wolves at a recovery level that will ensure viable, self-sustaining populations until it can be established that wolves in increasing numbers will not adversely affect big game populations, the economic viability of IDFG, outfitters and guides, and others who depend on a viable population of big game animals." Further, their desire is to "...minimize the impact of wolves on the Idaho outfitting industry, Idaho sportsmen, a diverse public and all others affected by wolf reintroduction."
Managing for the minimum viable population could place IDFG in a chronically difficult management position. The plan acknowledges that obtaining population estimates is unlikely because of prohibitively high survey costs. According to Table 1 at less than 15 packs IDFG will be obligated to a livestock depredation control program that is costly, labor intensive and may depend upon non-lethal methods to avoid an inadvertent breach of the 10 breeding pair threshold. They will also be obligated to a costly and labor intensive monitoring program that may require radio collars in each pack and repetitive aerial or ground surveys to confirm production and survival of pups among most if not all existing packs. Managing at minimum population levels also removes flexibility for altering wolf distribution and numbers to reduce localized declines of wild ungulates. To allow more flexible management, IDFG could manage for wolf populations well above the delisting threshold, but that would conflict with the stated objective of minimizing impacts of wolf predation on wild ungulates and their economic dependents.
The specific impacts of wolf predation on ungulate populations and harvests in Idaho cannot be known until detailed studies are conducted and long-term trends are analyzed, but it is clear that wolf predation could significantly affect harvest management of elk and deer. The Idaho plan should explicitly recognize those potential impacts by stating that ungulate population and harvest objectives in some areas could be modified (e.g. reduced harvest by hunters) to accommodate increased ungulate mortality associated with maintenance of a viable wolf population.
Montana
Montana's Gray Wolf Conservation and Management Plan provides a comprehensive review of the challenges inherent in managing for a recovered and viable wolf population within the context of Montana's land ownership and use patterns. Montana's objective of maintaining at least 15 breeding pairs of wolves, classification of wolves as a species in need of management, and statute changes (Senate Bill 163) that remove the wolf from the list of species designated as "predatory in nature" will provide ample flexibility and regulatory protection to sustain a viable wolf population.
Among the 3 states...a higher proportion of Montana's wolf packs will roam private lands, public lands with livestock grazing leases, or near areas of high human density....The wolf population in northwestern Montana appears to have stabilized. Expansion of Montana's wolf population will require colonization of mountainous areas east of the Flathead and Bitterroot Valleys where wolf pack territories will often include or lie adjacent to human use areas....
....I believe the plan reveals a well-rounded and well-reasoned monitoring protocol. However, the estimated September 2003 population contained only 8 confirmed breeding pairs and pup production was listed as unknown for 20 additional packs. Therefore, to insure the existence of the minimum number of breeding pairs monitoring efforts may have to increase above the current level....
Wyoming
Wyoming is unique among the 3 recovery states in that most or all of the minimum population recovery objectives will be met by wolf packs that are fully protected and intensively monitored within federally managed National Parks. As of September 2003, 12 breeding packs existed within Yellowstone National Park (YNP); that population alone could fulfill Wyoming's obligation to maintain 10 breeding pairs. Wyoming's proposed population objective of maintaining 7 packs consisting of 5 or more wolves outside of National Parks should therefore adequately insure a minimum statewide population of at least 10 breeding pairs within the foreseeable future. Nevertheless, there is some small possibility the Yellowstone population could decline and the statewide population could consequently fall below the objective of 15 packs or even below the minimum threshold of 10 packs. The Wyoming plan clearly asserts that the State of Wyoming will only commit to 7 packs, but to maintain management authority the plan should provide some contingency that insures 10 breeding pairs are maintained within state boundaries regardless of population fluctuations within YNP.
....Classification of wolves a predatory animals outside of the Wolf Data Analysis Unit (DAU) means that there will be unregulated take of wolves in most of the state. That will likely preclude significant colonization of wolves in the remainder of Wyoming with the possible exception of Tribal Lands where Tribal authorities may choose to manage for wolf colonization.  However, I do not believe establishing wolves in Wyoming outside the National Parks, contiguous wilderness areas, and DAU will be necessary to meet the objective of maintaining a recovered and viable wolf population as defined by the USFWS. The size and location of the DAU should easily accommodate the objective of 7 packs and probably several more depending upon the harvest and depredation control programs establishing within the DAU by the Commission.
....It is apparent that with the zoning strategy proposed in the Wyoming plan the State intends to manage wolves near their objective of 7 wolf packs outside of National Parks and that sport harvest, lethal depredation control, and some unregulated take of wolves will be used to control overall wolf population growth. Although I believe that management strategy can meet the minimum population recovery objectives, it comes at some cost; specifically, a need to more intensively monitor the wolf population and wolf harvest than would be required with a larger, less regulated population....Management at minimum population size and pack numbers may also raise concerns about connectivity and genetic diversity of the recovered wolf population. Those concerns can be evaluated by monitoring movements of radio collared wolves between recovery areas and documenting trends in allele frequency and heterogeneity obtained from samples of harvested wolves.
....Because Wyoming will likely manage near the minimum recovery population level for wolves, negative impacts of wolf predation on ungulates should be minimal, but options for controlling wolves to reduce predation will also be minimal. The plan suggests that "Most management actions taken to reduce (predation) impacts will involve removing individual wolves at an early stage before it is necessary to remove multiple individuals or entire packs if problems continue".  However, unlike mountain lions or bears in which the individual is the predatory unit, the pack is the predatory unit in wolf populations and most predation is accomplished by the primary (alpha) adults. Removal of wolves other than the primaries within a pack can have little affect on predation rates or a pack's propensity for predation within a certain area. Conversely, removal of the primary animals will often result in premature dispersal and increased natural or human caused mortality of remaining pack members. Removal of a single wolf can eliminate localized predation if the problem animal is a single disperser not associated with a pack.
Combined Plans
I believe the Wolf Conservation and Management Plans of Idaho, Montana, and Wyoming in combination are adequate to insure equitable distribution of 30 or more breeding pairs in Idaho, Montana, and Wyoming for the foreseeable future....
....Expertise in wolf management among existing staff in each of the 3 state wildlife agencies will rapidly increase and I believe each state agency can successfully monitor and manage wolves within the prescribed guidelines if sufficient federal funding accompanies delisting.
The Montana plan briefly discusses disease related problems, the Idaho and Wyoming plans do not. Although the potential for disease to be a population-wide limiting factor is low, some diseases (rabies, canine-parvo, canine-distemper and mange) have affected wolf population dynamics in some areas. If wolf populations in the three states are managed near the delisting threshold small declines in breeding pair numbers in any of the recovery areas could result in non compliance with the mandate for 10 breeding pairs in each state. If a decline was disease related, complete protection of remaining wolves would not necessarily reverse the decline. Instead the managing authority may be required to intervene by vaccinating or treating remaining healthy animals in several packs and/or removing diseased animals in some packs.
The primary challenge for all three states will be maintaining human tolerance of wolves in rural areas when livestock/pet predations increase or when hunter harvest of elk and deer decline....After delisting, illegal killing of wolves will be enforced under state regulations and that enforcement must provide a substantial deterrent to illegal take of wolves if viable populations are to be maintained. The Idaho legislature is on record asking the federal government to remove wolves entirely from the state and that continues to be the state's policy despite their plan to assume management for viable populations. Prior to wolf reintroduction both the Wyoming and Idaho legislatures passed joint resolutions opposing reintroduction and wolf recovery. Livestock interests in all 3 states remain opposed to the presence of wolves and those interests are politically and economically important within each state. Therefore, balanced public education on the ecological benefits and economic costs of maintaining viable wolf populations must continue. The states must pursue new programs for the protection of livestock and compensation of livestock depredation, and should assume that the Defenders of Wildlife compensation program will eventually end. The Northern Rocky Mountain Grizzly Bear and Gray Wolf National Management Trust is an excellent concept for providing reliable compensation funds as well as funding for education and other management programs.
....In making its decision for delisting the USFWS must decide whether each state will commit the staff and funding to meet the prescribed levels of monitoring, education, depredation compensation, and law enforcement.
MARK E. McNAY
V.
(no date)
....Wyoming Plan
Management as directed by the Wyoming Plan may not achieve their objective of 15 packs especially initially given that all wolf packs outside national parks and wilderness areas in the northwest portion of the state will initially be classed as predators....[T]hus right at the outset of the plan, within 90% of areas occupied by wolves today, wolves be classed as predatory and would be subject to unregulated take. We must assume conservatively that many of these wolves would be killed (and some packs eliminated) since unregulated take is sanctioned, and that this could then immediately result in a drop in wolf packs below the 7 pack threshold...dictated in the plan. This then could only be mitigated...90 days later when the first review of boundaries for trophy class vs. predator class takes place. By that time there may have been significant take and, depending on that take, it may require a long time to get back to the 7 pack minimum. There is no good reason to believe that pack occupancy will not continue to be largely outside the wilderness areas, and thus it seems necessary that initially the trophy classification area must be expanded beyond the wilderness areas to include all the area of current pack occupancy (thus the 8 packs existing now outside the national parks would be only subject to regulated take which initially should be no take). When wolves expand beyond this area, they would be classed as predators and take would be OK because at a minimum you are securing the 7 packs required. This would ensure from the start...the goal of maintaining >7 packs...and only when this threshold is surpassed could unregulated take be allowed....This would seem the more conservative approach and necessary at the start....The other benefit of this action is it will allow a slight relaxation in monitoring demands....
The other problem in the plan is the state only commits to managing for 7 packs and assumes national parks will take care of the rest. The current distribution and numbers of wolves in the state would support the biology of this contention. However, we need a contingency in the plan that should there be <8 packs in the park (and thus <15 packs in the state that they indicate is their management objective) the state would adopt more conservative management to get [the] number back up to 15....
The state must be willing to move trophy classification beyond DAU boundaries if this area is not able to support the number of packs needed to supplement park packs to ensure >15 packs total. Given the abundant prey base in the northwest portion of the state, however, this should not be a real issue.
Additional concerns that will probably not result in inability to meet management objectives but that should be addressed in some manner, nonetheless:
The moving boundary line of trophy vs. predatory classification depending on population status of wolves will be confusing and difficult to enforce, especially if it occurs every 90 days. This also makes the monitoring task more...difficult....
Wyoming predatory classification is a concern, but the state claims that they will be able to monitor and manage this because reporting will be required for all animals killed under predator class. It would be helpful to have some assurance that at least some minimum level of reporting will occur given no license is required and there is no apparent way to enforce this....
Assuming the concerns related 1) to trophy classification boundary line encompassing all current wolf packs, 2) a mechanism be developed for responding to a decline in park packs below 8, and 3) an ability to move the trophy class boundary beyond the DAU boundary if necessary...be appropriately and adequately addressed, the Wyoming plan should meet its and [the] federal objective for wolf recovery. Controlled take via trophy classification should reduce risk of overharvest....Managing wolves by way of the DAU system as other game is managed in the state appears to be a proven model for other carnivores including lions and black bears. Managing for 15 packs ensures an adequate buffer to stay above the 10 [pack] threshold. The monitoring experience of WDGF and the plan they have outlined...with intensive telemetry in the early stage and working to find other protocols for the longer term appears appropriate. A conservative depredation management following current protocols used by federal government and and the state providing compensation  for losses in the trophy management area appears reasonable....This assumes that should significant depredation and resulting losses of wolves occur in the trophy class area, the state would respond by increasing the size of the trophy class area to make up for the losses....
Idaho Plan
Assuming the Idaho plan is adopted as is, it should achieve the objectives stated and ensure recovery as defined by USFWS.  The management mechanisms are biologically/scientifically sound. Management activities that change in response to falling below 15 packs should ensure a substantial enough buffer to maintain recovery....The budget proposed for monitoring and the initial attempt to focus on radio telemetry should be adequate. The conservative approach to control following the USFWS model with an incremental approach is appropriate although it would be helpful to have a few more details on this fleshed out in the plan....A proactive education program is included and should reduce illegal take.
I offer the following concerns...that need to be monitored if delisting occurs:
The philosophy within the preamble of the executive summary is somewhat troubling to prospects for long term recovery in Idaho. House Joint Memorial No. 5 asks the federal government to remove all wolves from Idaho and the current plan is adapted to "use every available option to mitigate the severe impacts on the residents of the state of Idaho..." I am unclear how this discrepancy between a management plan and a state Memorial plays itself out in the legislative, judicial, and executive branches in the state but if the Memorial takes all precedence, no plan will suffice to ensure recovery.
Also troubling is the statement on p. 23 that should no funding from [the] federal government be found, "the state of Idaho is under no obligation to manage wolves....[T]he state is not precluded from using state resources to eliminate or control wolf-related conflict."....[S]ince there is no guarantee of funds, the effect could be [the] undoing [of] restoration....
I think we need some more explicit statements in Table 1 under "Management" and elsewhere in the plan itself that should wolves drop below 10 packs that sport or other harvest will be eliminated. Wording should be similarly rigorous to what is stated under "Control" in the table.
The plan provides no definition of a wolf pack.
Montana Plan
Assuming the Montana plan is adopted as is, it should achieve the objectives stated and ensure recovery as defined by USFWS. The management mechanisms are biologically/scientifically sound. This plan serves as the benchmark for the states since it is the most progressive and detailed of the 3 and will serve wolf recovery very well....The plan details very well the actions and responsibilities of all stakeholders based on wolf population status....The initial classification as a species in need of management is the best and most conservative approach of the 3 plans. Full legal protection is provided by such a classification and harvest is not allowed until a buffer threshold of 15 packs is achieved....The definition of pack following the federal definition is also conservative....Monitoring plans are sound as they follow current federal methodology....The budget proposed for monitoring and the initial attempt to focus on radio telemetry should be adequate....The plan also provides a proactive approach to compensation that should further reduce conflicts....The plan also outlines approaches to prey management that will help reduce conflicts and ensure recovery. Montana's management of grizzly bears based on a similar stakeholder and EIS approach provides a model to further indicate their likelihood of success for wolves. A proactive education program is included and it provides details that indicate it should reduce illegal take. If the Idaho and Wyoming plans follow the Montana model there would be little or no doubt about...wolf recovery in the 3 state region nor about the ability of the states to address any conflicts in a successful, positive, and proactive manner that further enhances recovery.
Collective review
If the indicated changes are made in the Wyoming plan...and given the great ability of wolves to disperse and recolonize and their great resilience this should add a further buffer that likely will easily result in >15 packs in each state. Even when wolves get into trouble [in] some places and are subsequently controlled, data...indicates that they can readily reoccupy these areas. Further, the states appear willing to manage wolves just as they manage other large carnivores...and they all have been successful managing cougars and black bears...[A]ll 3 states speak to ensuring enough wolves to provide for movement among the 3 states and ensuring that connectivity. No state specifically describes how that will be ensured, but they at least provide a commitment to the concept....This interchange among states will need to be monitored to ensure long-term persistence of wolves in the northern Rockies.
KYRAN KUNKEL
VI.
October 30, 2003
....Idaho
I believe the State of Idaho's wolf management plan will achieve the goal of maintaining at least 10 packs in the state and likely more. The change in management actions when the wolf population falls below 15 packs (i.e. much more conservative when populations are low) should maintain populations at or above that level. Not much detail is provided on how the State of Idaho will monitor wolf populations; however, the amount of money they are requesting for wolf monitoring should be sufficient to accomplish the task.
Montana
I believe the State of Montana has produced an excellent wolf management plan....
Wyoming
The State of Wyoming's wolf management plan will probably work, but 2 of the provisions in the plan concern me:
The first has to do with the number of wolf packs. I recognize that the State of Wyoming has little authority over what happens with wildlife in national parks. I also recognize that the national parks in Wyoming will likely contain [8 or more] wolf packs for at least the near future. The State of Wyoming claims responsibility for maintaining 7 packs (not [7 or more packs]} in Wyoming outside the Parks. The reason this could be a problem is that success of delisting, and likely the trigger for re-listing, will be based on the number of wolf packs in the state, not the number outside of Parks. The state commits to a total of 15 packs, but the plan does not discuss what the state will do if the number of packs in the Park/Parkway falls below 8. Even if this were not a problem, managing for 7 wolf packs outside of the Parks will be more difficult than managing for at least 7 wolf packs. Wolf packs are dynamic everywhere, but especially where they are highly controversial. Boundaries where wolves are managed as a game animal may have to be shifted quite often. This will be painfully controversial each time it occurs.
My second concern has to do with the State of Wyoming managing wolves as a predatory animal elsewhere in the state....Recovery of many species while they were managed as a game animal has...been common in North America (most ungulates and some predators, including the mountain lion). Management as a game species allows managers to close seasons when populations are low and the objective is to increase numbers, or liberalize seasons when populations are high and the objective is to decrease numbers. Management as a predatory animal allows little flexibility. This probably won't make a difference in maintaining the desired number of wolf packs in Wyoming given the current high density of prey, but times change. The wolf is a species that will require considerable flexibility. Game animal status over a broader area would provide more flexibility....
Other comments/concerns
Each state documented the cost of plan implementation and the fact that they do not currently have the dollars necessary for implementation. The costs, while high, seem realistic to me. The best plan in the world is worthless if the plan cannot be implemented. How these costs will be covered must be settled prior to delisting.
Each of the state plans...state that the Service has determined that a recovered wolf population contains 30 breeding pairs equitably distributed among Montana, Idaho, and Wyoming. The only citation I could find for this in the documentation I received was a 2002 Annual Report. This is not what the 1987 Recovery Plan states. This should be clarified....
DANIEL H. PLETSCHER
VII.
October 30, 2003
....I believe that, collectively, these plans should maintain the wolf population at or above the recovery levels specified by the FWS, although I have concerns regarding the Idaho plan that undermine that judgment. The primary factors that underlie my overall positive assessment at this time are 1) the regional wolf population is well distributed and sufficiently numerous that it need not be considered...threatened with extinction and 2) if any of the states fail to meet its commitment to maintain at least 10 breeding packs within its borders, emergency relisting is an option....
Idaho
1a. I am not sure if the Idaho plan will maintain the recovery objective, given the mixed message of the current plan....
1b. There are too many inconsistencies in the Idaho plan which reduce its credibility.
1c. The monitoring objectives are well stated and appear to be adequate; i.e. extensive radiotelemetry monitoring of wolves will be necessary.
....The Idaho plan contains elements that suggest it is not of one mind regarding wolf recovery (here are examples):
---Page 4, lines 11-14 in the first paragraph of the Executive Summary read "The State of Idaho is on record asking the federal government to remove wolves from the state by the adoption in 2001 of House Joint Memorial No. 5. The position reflected in House Joint Memorial No. 5 continues to be the official position of the state of Idaho." This statement...is incompatible with the intent of the management plan and completely undermines the credibility of the entire document. I cannot endorse a management plan that is based on this foundation. A reader can only conclude that Idaho needs to get its house in order before it will be capable of managing wolves.
---Page 5, item # 8 emphasizes that education programs should present a balanced view of the societal impacts and costs of wolf reintroduction, yet the plan itself advocates an unbalanced view on page 18, item # 5, in stating that direct and indirect costs "will be presented" while saying nothing about benefits of wolf restoration, which include economic, social, and ecological phenomenon. In fact there is not a single positive statement about wolf restoration in the entire management plan, again reflecting the dominant negative view that I assume was intentional.
---On page 23, the 3rd full paragraph states that if the federal government fails to adequately fund the cost of wolf management, "the State of Idaho is under no obligation to manage wolves." This is not a business plan, it is a management plan for an important native carnivore; while federal help in state management of native wildlife has a long history and additional, special help with wolf management costs is a reasonable goal, the state of Idaho should be trying to demonstrate that it is up to the task of management. Political statements such as this undermine the credibility of the plan and poison the implied intent of the State of Idaho to assume management responsibilities. Note that the text in this paragraph stating "Provided, however, the State of Idaho is not precluded from state resources to eliminate or control wolf related conflict" is not a sentence. It sounds important, but I do not know what is meant.
---Page 19, end of first paragraph, states...that ISFG is authorized "to use sport hunting or any other means necessary (the italics are my addition) to maintain wolves at recovery levels; this is an important concept that must be clarified.
---Page 4, part 3 of Executive Summary, states "In general, regardless of their location, wolf packs that are not creating conflict will be allowed to persist." This is an important statement, but "creating conflict" needs to be defined. From statements elsewhere...I infer that conflict might be assumed to exist wherever wolves exist, especially given the "official position of the State of Idaho" (see above). If "creating conflict" is supposed to mean predation on domestic animals or other direct negative influence on private property, then it would be more appropriate to refer to "depredation" (defined as predation on domestic animals) rather than "creating conflict."
---Page 11-12, paragraph beginning with "Husseman and Power (1999)" perpetuates a common error in estimating predation impacts by extrapolating winter predation rates through the year. The available evidence does not establish that ungulates >1 year old continue to be killed by wolves during non-winter seasons at the same rate as in winter, although summer predation rate is perhaps the most serious gap in our understanding of wolf predation....It is especially inappropriate to imply that the year-round predation loss comes out of the winter population...because studies of wolf predation  in summer suggest that juvenile ungulates are the most important prey class. Juvenile ungulates, for the most part, are not even counted in most ungulate management areas.
....---Page 22, under "Compensation..." states that compensation for wolf depredation "should continue to be paid by Defenders of Wildlife." A state management plan, obviously, cannot dictate nor be based on what an outside organization may or may not provide in the way of financial assistance....
Wyoming
1a. I believe the Wyoming plan will maintain the minimum numerical targets specified by the USFWS.
....Page 1-2. Needs to explain how packs that overlap National Park boundaries will be "counted."
....I infer from text on page 10 that the 7 packs that Wyoming will maintain will also lie outside the Wind River Indian Reservation. If not, this point should require more extensive explanation.
Montana
....1b. The plan does an excellent job of reviewing alternate scenarios and the complex set of factors that are likely to affect wolf management in Montana in the future, plus there is an unambiguous and well-thought-out commitment to maintaining wolves as a native carnivore subject to standards of protection similar to other wildlife species.
....The Montana plan is a comprehensive, exhaustively-detailed document that reflects the high level of preparation, public dialogue and special consideration that underlie its creation. This represents an exceptional professional effort, one that will serve Montana well in the future....
ROLF O. PETERSON
VIII.
October 29, 2003
I have completed my review of the state management plans for wolf management in Montana, Wyoming and Idaho and have concluded that the plans will meet the objectives of maintaining at least 30 packs equally distributed in each state. Each state has established minimum population objectives that will ensure maintenance of the minimum numbers of wolves. Because the core recovery areas are either National Parks or wilderness areas these areas will continually provide dispersing wolves that will continue to colonize new areas. If the minimum numbers of packs in each of the state plans are maintained outside of these areas, wolves will easily exceed recovery objectives. Additionally, each state will allow wolves to expand outside existing areas so long as there are no conflicts. I believe wolves will fit into the landscape and establish in other areas. The methods that each state intends to use to monitor population objectives are sound and have been used extensively in Alaska, Canada, and other areas and should be quite adequate to maintain minimum population levels....
WARREN BALLARD
IX.
November 3, 2003
....The wolf management plans range from very complete and thorough, to somewhat limit[ed] in scope and lacking details, but as a composite they do seem to fulfill the minimum federal standards for delisting wolves in the Northern Rocky DPS. The Montana plan is very thorough, and provides an excellent example of a scientifically sound wolf conservation plan. The other plans are somewhat more limited in details or have very inflexible systems of management proposed. The plans will allow the federal wolf goals to be maintained, but the Wyoming Plan seems to limit the potential of wolves to colonize other areas of suitable wolf habitat further to the south.
....All three states recommend long term goals for 15 or more breeding packs, thus there should be a minimum of 45 packs in the area, or about 50% above federal delisting guidelines. Based on surveys in the Northern Rockies since reintroduction in 1995, each breeding pack represents a population of about 13.5 wolves, and thus 45 packs would consist of abou 608 wolves. This would be a fairly viable wolf population....
All plans propose that major portions of the funding for each plan would be from federal appropriations that have previously not been made available to states. There is no guarantee that this appropriation [will] be made. All three states express support for the importance of compensation payments for wolf depredations, but all rely on funds from a [single] private wildlife organization to fund this program. As wolf populations rise, adequate funds may not be available, or when wolves become state game or furbearer, interest in payments may become less desirable for this organization. With inadequate funds, the 3 states would be unable to adequately monitor wolf status.
....The Idaho Plan includes provisions for maintaining at least 15 breeding packs in the State and places no limit on the total population of wolves or specific distribution that will be maintained in the state. The plan includes more intense monitoring and more limited lethal controls for depredators as the population declines. Wolves would be managed similar to cougars and bears that are very successfully managed in Idaho, and indicates wolves will be a protected species with harvests only allowed at specific times, specific zones or locations, and limited to a quota or specific number of animals.
....The Wyoming management plan encourages the establishment of 15 breeding wolf pack[s] in the state. Although the state only plans to keep wolves in 7 packs outside the national parks, in 2002 there were 12 breeding packs in Yellowstone. In 2002 Wyoming had 18 breeding wolf packs in the state with 6 breeding packs outside the national parks, and [the plan] would thus allow increase by one more pack.
....The Wyoming plan is very rigid, narrow in scope, and lacks flexibility. The Wyoming Game and Fish plans to allow wolves only in wilderness areas around Yellowstone, but these appear to be mainly high mountains that do not include adequate ungulate wintering areas for year round wolf territories....
The plan discusses "trophy" and "predatory animal" status throughout the text, but does not clearly define the terms and how wolves in these 2 categories would be managed. It is not clear how trophy animals would be managed for long-term sustainability. The population of 7 packs proposed for Wyoming would probably consist of less than 100 wolves in most years. It appears the predatory status would allow anyone to shoot wolves anytime anywhere in the state outside the small area of trophy status in the northwest corner of the state. This seems like an extreme form of wolf management. It appears that trophy management, with more liberal controls available for livestock producers would be more appropriate and would provide much more sound conservation for wolves.
The limited distribution and population goals will probably make it difficult to use wolf control for ungulate population enhancement when wolves exist only in a small area; such controls could have drastic impacts of wolf numbers. Whereas broader distribution of wolves would allow more [flexibility] because such controls could focus on regional problems, but still maintain viable populations in areas where wolves are not causing problem[s]....
The Wyoming plan appears to restrict wolves from most of the state including extensive areas of public lands where other large wild mammals are encouraged. The plan also limits the potential of wolves to occupy states south of Wyoming....
ADRIAN P. WYDEVEN
X.
(no date)
....The State [of Montana]'s apparent willingness to allow wolves to find niches where [they] can exist with other land uses outside of the recent historical wolf range in SW...and NW Montana is important. Although all three plans embrace adaptive management to some degree, Montana has set the stage for more effective use of this concept by not restricting geographic areas where wolves "may be allowed to exist." Further, Montana is geographically located to accept dispersing wolves from adequate habitat in Idaho, Wyoming, and Canada. Compensation to landowners for documented predation losses to wolves is critical. Montana places funding such losses at equal priority to other aspects of wolf management, which is critical. The State is committed to an educational program, another important element to finding a balance between human use and wolf survival.
....[The Wyoming] plan will depend heavily on wolf existence in Yellowstone National Park to meet its objectives. Wolves outside National Parks and Parkway would be vulnerable to being regulated due to documented or perceived on individuals or ungulates in specific drainages. Outside of the Northwest DAU, wolves would not be tolerated....In my opinion, Wyoming's plan exposes wolves in Wyoming to risk of catastrophic loss outside of National Parks and Parkway.
....At their minimum, population goals for Wyoming's wolves would not yield a population large enough to sustain itself (i.e., 15 packs may represent as few as 60 individuals).
....Human-caused mortality is likely to be the most significant factor affecting Idaho's wolves. Presently the state code covering mistaken identity does not include wolves.
Knowledge of population is critical to management. Although at population levels below 15 packs, a commitment is made [by Idaho] to radio all packs, above this level the commitment to population monitoring seems vague.
....All plans discuss the value of a wolf education/information program. Yet, none of the plans discuss in enough detail how these programs will be delivered, what the expected outcomes are or what specific educational need they will address. I believe a "northern Rocky Mountains" human dimensions survey about wolves could give direction to educational efforts and represent a starting place from which to judge programs.
Not enough discussion is offered about coordinated efforts between states regarding wolf management. Above sharing of population trends, there would be much to gain from information sharing as wolf issues continue to emerge....
Although funding for wolf programs was mentioned in all plans, the uncertainty of future funding sources was evident. Adequately funded USDA Wildlife Services efforts in these states will be critical to the long-term wellbeing of wolves....I feel that USFWS needs to maintain and improve, if possible, funding assistance to these states at least during the period of 5 years past delisting.
JAMES HAMMILL
The comments of Dr. Todd Fuller and Dr. Paul Paquet have not been included here. Those comments, and the complete texts of the excerpts above, can be viewed at http://gf.state.wy.us/downloads/pdf/wolf_peer_review.pdf