Dear Secretary Haaland,
In this letter, I want to focus on Montana, one of the Northern Rockies states where wolves, as you know, are still not protected by the Endangered Species Act. I’ll describe how Montana’s war against wolves was started under false pretenses and has been unfairly waged. Both issues speak to why Montana’s wolves should be immediately protected by you under the ESA.
The campaign to pass Montana’s new anti-wolf legislation was spearheaded by state senator Bob Brown and representative Paul Fielder. Both live in northwestern Montana and claimed that the area had too many wolves eating too many elk. Though data from Montana Fish, Wildlife & Parks (FWP) did not support their claim, the legislation passed. The legislature declared war on wolves. And not just in supposedly overrun northwestern Montana but across the entire state.
The war on wolves progressed to Montana’s Fish and Wildlife Commission. All but one of the commissioners was appointed by governor Greg Gianforte, who was caught illegally trapping a wolf and received only a slap on the wrist. The commission—following the legislature’s new directive to reduce Montana’s wolf population—set thresholds for the number of wolves that could initially be killed in each of the state’s seven wolf hunting regions.
It wasn’t surprising that the highest thresholds were set in Region 1 (195 wolves) and Region 2 (116 wolves). Those two regions are in northwestern Montana where Brown and Fielder live. The next highest threshold was set in Region 3 (82 wolves). Region 3 includes Wolf Management Units 313 and 316—both adjacent to Yellowstone National Park. Into those units step Yellowstone wolves after crossing an invisible boundary that separates the park from Montana. In Yellowstone wolves are protected. In Montana they die.
As of this writing, with only weeks to go before the wolf hunting season closes on March 15, more wolves have been killed in Region 3 than have been killed in either Region 1 or Region 2—the areas that Brown and Fielder falsely claimed are overrun with elk-eating wolves.
As the killing of Yellowstone wolves traveling in Units 313 and 316 escalated, Yellowstone’s superintendent, Cam Sholly, wrote a letter to Gianforte. He gave the governor data on how Yellowstone wolves were being disproportionately impacted. He explained that FWP data shows that in Region 3 wolves were not having a negative impact on elk or livestock. He asked Gianforte to stop the hunting and trapping in the two units.
Gianforte did nothing but refer Sholly to his hand-picked Fish and Wildlife Commission. On January 28, weeks after Sholly wrote to Gianforte, the commission finally met to decide if wolf hunting should be stopped in Region 3. Many people, including myself, attended that meeting virtually. By the meeting’s end I was even more concerned about Montana’s wolf management than I was when the meeting began.
One of my concerns was for the data—or lack of data—that Montana Fish, Wildlife & Parks presented to the commission. FWP is, after all, supposed to provide the commissioners with accurate and timely information needed to make decisions. While the meeting was required because the wolf kill in Region 3 was approaching the 82-wolf threshold, at the start of the meeting neither the commission nor FWP knew the actual number of wolves killed to date. Was it 76 or 78?
As the meeting continued, I also grew concerned about how the commission ignored or rejected the input of individuals and businesses that want to reduce killing and increase coexistence.
Early in the meeting, Commissioner Byorth—the only commissioner not appointed by Gianforte—made a motion to immediately stop hunting and trapping in Units 313 and 316 because of the disproportionate impact on Yellowstone wolves. Commissioner Walsh seconded that motion. Chair Robinson said there would be discussion before voting.
During that discussion, Commissioner Cebull offered closing 313 and 316 immediately but leaving the rest of Region 3 open until 82 wolves had been killed regionwide. Then Vice Chair Tabor made a motion to continue the killing until 82 was reached, then initiate 48-hour notice, then close the region. Finally, Byorth withdrew his previous motion and moved for immediate closure of Region 3 when the number of dead wolves reached 82.
With that motion on the table, Chair Robinson called for public comment. To everyone’s surprise, Robinson limited the comment period to 30 minutes; this had not been previously announced. Only seventeen people were able to comment. I could not understand one of the speakers due to his poor connection. The other sixteen commenters supported stopping the killing immediately in Region 3 or in Units 313 and 316.
After the comment period ended, the commission continued discussing. Walsh proposed halting the killing immediately in 313 and 316—as this would be consistent with the letter from Superintendent Sholly and the comments the public just made. Byorth concurred with Walsh but Tabor did not; he still wanted 82 killed before stopping.
After more discussion on whether 76 or 78 wolves had been killed to date, Chair Robinson said that even though the number of dead wolves was uncertain, it was time for a vote. The motion to stop the hunting in Region 3 when 82 wolves had been killed passed unanimously.
It wasn’t until the end of the meeting, after the commission had decided to continue killing wolves, that FWP staff confirmed that 76 wolves had been killed to date. Why hadn’t FWP staff confirmed this number before the meeting even started?
That isn’t the only question in this war against wolves. It turns out that the math used to arrive at that 82 threshold is incorrect. The Billings Gazette reported that Utah State University scientist Dan MacNulty described a commission agenda item where the agency wrote that since 18% of the wolf population lived in Region 3, 18% of the 450 wolves to be taken should be killed there. But, as he pointed out, 18% of 450 is 81, not 82.
“Why does one extra wolf matter?” MacNulty wrote on his Twitter page. “First, it could be a wolf that Park visitors spend many hours and thousands of dollars to watch; dollars that pay for Montana guides, lodging, restaurants, etc. Second, it could be a wolf that the Park spent thousands of dollars to radio-collar in support of Park monitoring and research. Data from this collar will contribute to numerous projects, many involving students and researchers at Montana schools.”
As it turns out, because of the commission’s unwillingness to close Region 3 until 82 wolves had been killed, even more wolves have died. The total from FWP as of February 23 in Region 3 is now 85 wolves, not 82 (19 killed in 313 and 316). As MacNulty said, each one of those three additional wolves matters.
The mistakes made by the commission and FWP aren’t just in miscalculating how many wolves have been or will be killed. Mistakes have been made in the regulations that control the killers. One such mistake was revealed during a lawsuit brought about by Trap Free Montana and Wolves of the Rockies—conservation groups that have sued the commission and FWP over discrepancies in wolf regulations. Earlier this month during a court hearing in Helena, the state’s long-standing prohibition against aerial hunting of wolves was examined. According to testimony by an attorney who up until recently worked for FWP, that prohibition against aerial hunting was in error. That’s right, it’s actually legal to hunt wolves from the air in Montana.
Of course, this error by FWP benefitted wolves, kept them from being spotted or shot from the air. But whether a mistake helps or harms wolves is secondary to this question: If FWP made such a major mistake regarding aerial hunting, what other mistakes has the agency made that have a harmful impact on Montana’s wolves?
With mistakes in math, with a disregard of public opinion, with going beyond the agreed upon threshold, and with making a serious mistake regarding regulations, FWP is not competently managing wolves. Instead, FWP has become a tool for Montana’s governor, legislature, and the Fish and Wildlife Commission to use in their war against wolves.
Secretary Haaland, I urge you to use your authority to emergency relist wolves in Montana and the Northern Rockies while USFWS does its review of the situation.
Sincerely,
Rick Lamplugh
Gardiner, MT
(A version of this letter also sent via email to Secretary Haaland and as a comment to US Fish and Wildlife Service.)
Award-winning Indie author Rick Lamplugh writes and photographs to protect wildlife and wild lands.
His award-winning book In the Temple of Wolves; its sequel, Deep into Yellowstone; and its prequel, The Wilds of Aging are available signed. His books are also available unsigned or as eBook or audiobook on Amazon.
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