Help Reduce Wolf Killing in Montana

Comment before 5PM on July 21

Jul 14, 2022

Wolf hunting season returns in November and Montana’s Fish and Wildlife Commission is now considering new rules in their war against wolves. Montana Fish, Wildlife & Parks (FWP) provides the Commissioners with information to use in making decisions. FWP posted on its website a PDF on proposed changes to help reduce the statewide population of wolves as directed by the legislature.

Your comments can help reduce the senseless killing of wolves. I’ve listed in italics below some of FWP’s proposed changes. After each change, I present fact-based reasons to oppose them.

Feel free to use any of the information below in writing your comments. I urge you to write your comments in your own words.

Public comments are accepted until 5PM on July 21.

Link to comment: https://fwp.mt.gov/aboutfwp/public-comment-opportunities

(Click “TRAPPING AND WOLF SEASONS” to open the comment portal)

Biological Reasons to Kill Fewer Wolves in WMU 313

FWP proposes to combine units 313 and 316 into one unit, WMU 313. That new unit will have a wolf harvest quota of 10. FWP admits that during the previous wolf trapping and hunting season, a disproportionate number of wolves—eighteen—were killed in former WMU 313 with another three taken within former WMU 316. The agency writes: “Although this single year of harvest is not sufficient to create any long-lasting biological harm to Montana's wolf population, vocal public sentiment has favored some limitation on future harvest” within this region.

Those two infamous units, 313 and 316, are adjacent to Yellowstone’s northern border. I’m frustrated that FWP makes no reference to the fact that nineteen of the twenty-one wolves killed in those two units were Yellowstone wolves that stepped out of the park and into a free-fire zone. FWP makes no reference to the possible impact that killing so many Yellowstone wolves will have on Yellowstone’s wolf population and wolf watching in the park.

I prefer a quota of zero in that new unit but a quota of zero is not allowed under Montana administrative rules. However, a quota of one is allowed and makes sense.

With a quota of one in place, hunters and trappers who didn’t kill Yellowstone wolves that stepped out of the park would still have wolves to target elsewhere, as they have for years. FWP statistics show that 98% of all wolves in Montana live outside units 313 and 316.

I’ve found two studies that document the impact of hunting wolves near a national park.

In the first study, Bridget Borg, in her 2015 published Ph.D. dissertation, analyzed how the loss of a breeding wolf in Denali National Park and Preserve in Alaska changes the stability and growth of that breeder’s pack. Adjacent to Denali, wolves are primarily trapped. Borg studied packs that had dissolved in Denali over a 26-year period. She found that packs were more likely to dissolve if a female or both breeders were lost and the pack size was small. She found that breeder loss preceded the break up of three-quarters of the dissolved packs. In other words, shooting or trapping a breeder can destroy an entire pack.

In a second study, this one in 2016 and peer-reviewed, Borg, then working as a Denali wildlife biologist, and other authors including Yellowstone’s Doug Smith, Rick McIntyre, and Kira Cassidy analyzed how the hunting of wolves along the boundaries of Denali and Yellowstone altered wolf-viewing opportunities within the parks.

One conclusion of the 2016 study: Even when only a small number of wolves are taken by hunters and trappers outside the park, wolf sightings still decline within the park.

Another finding: “Sightings in Yellowstone increased by 45% following years with no harvest of a wolf from a pack.” In other words, if no wolves were killed in a pack outside the park, Yellowstone visitors would have more wolf sightings after hunting season ended.

Montana’s last wolf hunting season certainly harmed wolf viewing opportunities. The killing in the WMUs 313 and 316 eventually eradicated the often-watched Phantom Lake pack; their territory overlapped the Yellowstone and Montana border.

A quota of one wolf per unit in 313 and 316 would have saved the lives of at least nineteen wolves last hunting season.

A quota of one wolf in the upcoming season would save lives too. And if those saved wolves were breeders, their continued existence would help avoid the disintegration of their families. If those wolves wore collars, scientists would not lose valuable sources of information. And the ever-growing number of visitors to Yellowstone would watch, enjoy, and learn from more wolves in the park.

Economic Reasons to Protect Wolves in WMU 313

FWP writes in their PDF “based on wolf population data from 2011–2015, the period when most recent data are available, the average number of wolves in the proximity of proposed WMU 313 is 29 (range 18–40).”

Last season hunters and trappers killed 21 of those 29 wolves. That’s outrageous because wolves that step into that unit from Yellowstone are worth more alive than dead to the park and the businesses in the communities near the park’s five entrances.

Wildlife watching is a significant part of economic backbone of these gateway towns. A 2022 update to a 2005 study estimated that wolf watchers in the Greater Yellowstone Ecosystem (includes Yellowstone National Park) spend at least $82 million dollars each year.

Unfortunately, wolves are worth more dead than alive to Montana Fish, Wildlife & Parks. In 2021, the sale of 20,828 wolf licenses brought in $339,338, according to FWP records.

Hunters say that they bring money to gateway communities too. And that’s true. But they don’t bring as much as wolf watchers. According to a report by the U.S. Fish and Wildlife Service, wildlife watchers outspent hunters in 2016 by a ratio of nearly three to one.

Reasons to Kill Fewer Wolves Statewide

FWP proposes that the statewide threshold for the Fish and Wildlife Commission to review whether to stop wolf killing in the upcoming season should again be 450 wolves.

Last year, when the statewide quota for wolves to be killed during the wolf hunting season was 450, hunters and trappers took 273.

The 2020 Montana Annual Wolf Report is the most recent. On page vi, the report indicates that the state’s wolf population “may be stabilizing at around 1,150 wolves.”

FWP notes in the PDF that “research has shown that harvest must exceed 29 to 48 percent of a wolf population before a decline is observed (Adams et al. 2008, Gude et al. 2012).”

I want to see FWP use the 29 percent limit but I don’t think they will unless public opinion forces them to do so.

Here’s how the deadly math works:

If Montana’s wolf population is 1,150, then 29 percent of that is 333 wolves.

In the previous wolf hunting season, while 273 wolves were taken by hunters and trappers, FWP also reports that 52 other wolves were taken by Wildlife Services and private citizens in response to wolf depredation. This means that at least 325 wolves were killed last year. If FWP knew or estimated how many wolves were poached, the number would be even higher.

If Montana’s 1,150 wolves can theoretically recover from the killing of 333 wolves and at least 325 wolves were actually taken, then Montana has clearly reached an upper limit on wolf killing.

But the Fish and Wildlife Commission is still considering 450 wolves as a possible limit for the upcoming season.

The Commission should set the upper limit at 20 percent of the most recent wolf population. The quota should include ALL wolves killed regardless of the reason including those taken in response to depredation and by poaching.

The Lies Behind the Goal of Reducing Montana’s Wolf Population

FWP states that they are proposing these changes to help reach the objective set by the Montana legislature: reducing the state’s wolf population.

On page vii of the 2020 Montana Annual Wolf Report (most recent) is a graph that shows the minimum wolf population according to the state wolf plan is 150. While that is the legislature’s goal, I find no science-based reason to reduce Montana’s wolf population to 150.

Legislators who pushed for reducing the wolf population say that wolves kill too many elk. That is not true. In fact, the opposite is true: Montana has no shortage of elk.

FWP sets an objective for elk across the state and in specific districts and then counts elk. The count shows whether an area is over, at, or below the objective. FWP reports that statewide in Montana the elk count is above objective. In the two Montana elk hunting units, Region 3 and Region 5, adjacent to Yellowstone National Park, FWP reports that the elk count is over objective. Killing wolves in Montana is not required to protect elk.

Legislators also say that wolves take too many livestock. This is also not true. FWP’s most recent Wolf Report shows that in 2020 wolves took 99 livestock. FWP said this is similar to the number of livestock taken by wolves each year from 2011 to 2019. Meanwhile, the USDA reports that Montana ranchers have about 2,500,000 head of livestock each year. The loss of 99 out of 2,500,000 livestock is way less than one percent. And certainly doesn’t rationalize killing more wolves.

Furthermore, ranchers who lose livestock to wolves are compensated for their losses. FWP reports that during 2020 the Montana Livestock Loss Board paid ranchers $75,818 for livestock taken by wolves. The Livestock Loss Board states on its website that it pays “fair market value” for livestock taken.

In summary, the loss of livestock to wolves in Montana is miniscule and ranchers are compensated for those losses. Killing more wolves is not required to protect elk, ranchers, or livestock.

Please Comment Today

Public comment are accepted until 5PM on July 21.

Your comments can help reduce the senseless killing of wolves. Feel free to use any of the information above in writing your comments. I urge you to write your comments in your own words.

Link to comment: https://fwp.mt.gov/aboutfwp/public-comment-opportunities

(Click “TRAPPING AND WOLF SEASONS” to open the comment portal)

To Learn More About These Issues

FWP justification for proposed wolf regulation changes

2015 study on impact of hunting on wolf watching

2016 study on impact of hunting on wolf watching

Study on importance of wildlife watching in Montana

2020 Montana Annual Wolf Report

FWP report on last season’s wolf hunting and trapping

A study on how wolf populations recover from hunting and trapping.

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