WWF official response to wolf plan

December 2, 2022   

Sarah Barry

Deputy Secretary

Wisconsin Dept. of Natural Resources

101 S. Webster St.

Madison, WI 53707-7921

Dear Deputy Secretary Barry,

The Wisconsin Wildlife Federation has reviewed the online public input process for the 2022 Draft Wolf Management Plan and requests the Wisconsin Department of Natural Resources include additional ways to increase public inclusion in the process.  Below are additional means and methods requested by the Federation to prevent or minimize exclusion of individuals and information. 

Not all residents have email or computer access in their homes.  For this reason, The Federation requests the WI DNR provide public notice in local newspapers of the review and comment period, notification of ways for those without online capabilities to access the draft plan in print and provide a mailing address to mail written comments and supporting materials.  These are additional ways to service the public and limit unintended exclusion in the process. 

Currently only the DNR’s online feedback form can be used to provide public comment.  It appears there is no means for submitting additional literature to the WI DNR for consideration in the draft plan. WWF requests the WI DNR provide and clearly label an email address on the public comment webpage to allow for submitting comments and additional literature/supporting material. 

There is no indication of the inclusion of comments from county and local governments into the draft plan.  The Federation requests the WI DNR formally seek their feedback on the draft plan in the same manner the tribes were consulted on the draft plan.  Many county and local governments have voted positions on wolves in their jurisdictions, and we believe they must be included in the process.  

Currently there are no public hearings on the draft plan scheduled on the WI DNR website.   The Wisconsin Wildlife Federation strongly requests the WI DNR hold public hearings across the state and more focused in wolf-affected zones for verbal input on the draft plan.   

The Federation does not believe the current 60-day public comment period is an adequate amount of time to gather input considering the timing of the release overlapping with hunting seasons and multiple holidays.  We request the timeline be extended to 90-days.   

The WI DNR has had this draft in process in some form since 2009 and we believe the public should be provided with additional means of notification, multiple ways to review the plan, ample time to review it, and every means possible to give feedback on the draft plan. And we think you should seek and consider local government input included their voted positions.

Sincerely yours,

Patrick Quaintance

President

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December 10, 2022   

Sarah Barry

Deputy Secretary

Wisconsin Dept. of Natural Resources

101 S. Webster St.

Madison, WI 53707-7921

Dear Deputy Secretary Barry,

At our Board meeting today, the Wisconsin Wildlife Federation, with more than 211 affiliated grassroots hunting, angling, and sporting conservation clubs and alliances throughout the state, approved the following response to the WDNR 2022 Draft Wolf Management Plan and requests the Wisconsin Department of Natural Resources take the necessary actions to address the following points in a revised draft or final plan:

Public Comment:

1. The current 60-day public comment period in not an adequate amount of time to gather input considering the timing of the release overlaps with hunting seasons and multiple holidays.  We request the timeline be extended to 90-days. 
2. Not all residents have email or computer access in their homes.  For this reason, we request the WI DNR provide multiple and widely distributed announcements of opportunities and methods for public input along with comment period deadlines.
3. There is no means for submitting additional supporting information to the WI DNR for consideration in the draft plan.  The Wisconsin Wildlife Federation requests the WI DNR provide the public with an email and mailing address to submit comments and additional supporting information.
4. The Wisconsin Wildlife Federation strongly requests the WI DNR hold public hearings across the state and hold more in wolf affected zones for input on the draft plan. 

Inclusion/Exclusion:

1. There is no provision for the inclusion of comments from county and local governments into the draft plan.  Many county and local governments have taken positions on wolf population goals and must be included in the process.
2. A functional advisory committee with a balanced mix of impacted stakeholders would vastly improve this ongoing process. 

Public Survey Methodology:

1. The public survey does not adequately represent those actively impacted by wolves.  Use of county and zip codes to select samples does not accurately reflect those exposed to wolves and impacted by wolves. We request the WI DNR actively seek out those impacted by wolves and place greater emphasis on their perspective.
2. Survey design is flawed.  Survey length discourages responses from some individuals.  Terminology is undefined and could be seen as biased.  Some questions lack balance in positive and negative responses, causing an imbalance in responses.  All these features of the survey alienate some individuals causing them to not respond.

Population Estimates:

1. Approximately 40% of the wolf tracking units are not tracked to the required three-time standard and not all units are tracked.  This lends itself to under-counting and under-reporting wolf population in those wolf tracking units. 
   1. Lone and dispersing wolves are not counted in the current population model as is done in western states.  Some states add 12% or 15% to their estimates to account for lone and dispersing wolves.  We urge lone wolves be included in Wisconsin’s population estimate.
   2. The WI DNR is not taking full advantage of public reporting of wolf sightings.  The online tool for reporting should be better advertised and the WI DNR should clarify that personal information is protected and not available as public record.
   3. GPS collar tracking provides the WI DNR with useful information on travel patterns and pack locations for counting.  Increased use of GPS collars should be considered.

1. The draft management plan is passive and lacks active conflict management for depredations of non-agricultural domestic animals such as dogs and other pets.  Increased harvest is not a method identified in the draft plan to reduce such depredations.  Include targeted population reduction in areas of heavy depredation of dogs and other non-agricultural domestic animals.  This should include all legal methods of harvest for targeted population reductions. 
2. The draft plan does not address a numeric conflict reduction goal.  We request a goal be set and included in the plan so effectiveness of methods can be measured.
3. The draft plan appears to have biases against hunting with dogs.  Hunting with hounds has the same statutory and state constitutional protections as agriculture and should have equal active measures preventing depredations. 
4. We oppose the plan wording encouraging low road densities in large tracts of public lands, which is another means to prevent hunting, fishing, trapping, and other public land use opportunities.
5. We oppose the plan wording that implies hunting conflicts are the fault of the hunter.  The draft plan needs to address using population management of wolves as a method to reduce hunting conflicts.  Hunters have Constitutional rights to hunt lands open to them despite the presence of wolves.
6. Currently there are multiple systems for sending alerts for livestock, hunting dogs, and non-agricultural animals, but the plan is missing human health and safety alerts.  Receiving the same notification with a 4-mile radius map is necessary to help prevent potential conflicts for land users, pet owners, and dog hunters around those areas.  We request the WI DNR provide equal notifications for equal protections for all land users.
7. Those who have personally experienced conflicts with wolves may have traumatic experiences and stresses.  The psychological impacts on humans caused by livestock and domestic depredations by wolves is real and needs to be considered.   The draft plan ignores the psychological impacts wolf conflicts have on humans and this needs to be addressed in the plan.

Zone Changes:

1. The plan includes the creation of buffer zones surrounding reservations, effectively giving the management of the wolf population on both public and private lands to the tribes.  We oppose the creation of buffer zones surrounding reservations that would take away the rights of private landowners and public land stakeholders.  We also oppose giving away wildlife management authority.
2. The agricultural areas in these newly created buffer zones in the draft plan will go largely unprotected and have inadequate protections for pets and livestock.  Private landowners will have unequal treatment under the law for which they are protected under the Constitution.
3. The zone restructure is now based on wolf occupancy and not based on suitable habitat.  The unmanaged wolf population has forced wolves out of prime suitable habitat into inappropriate areas, creating conflicts.  Not all areas are appropriate to have wolves.  We request the zone structure return to the original science-based, habitat-based zones.

Goal Statement/Objectives:

1. The Goal Statement in the draft plan does not address where wolves are appropriate.  The draft plan needs to take a hard look into what is good for wolves and what is good for humans.  Low interactions between the two are best.  Wolves should only reside in high-quality wolf habitat and not be managed to the maximum biological carrying capacity.  No other species in Wisconsin is managed to its maximum biological carrying capacity.
2. The draft plan implies the elimination of hunting with dogs which is Constitutionally protected.  It also implies wolves have more rights to the land than hunters. This narrative is not science-based and all such implications should be removed.
3. Objective B is missing long-term controls for agricultural conflicts.  Wolves are known to move down the road and create conflicts with just short-term controls.
4. The goal statement or objectives do not address any form of population control.  The official position of the Wisconsin Wildlife Federation is a population goal of 350 wolves in the State of Wisconsin.  We strongly request the numeric population goal of 350 wolves be maintained in the final plan.

Numerical Population Goal:

1. The draft plan allows for a subjective process for managing wolves.  The population goal was established in the 1999 plan due to lack of confidence in a subjective wolf management strategy.  There is no accountability without a numeric population goal.  The only scientific analysis of wolf habitat done to-date of Wisconsin landscape quantified the social carrying capacity as 350 wolves.  The Wisconsin Wildlife Federation strongly requests maintaining the numeric population goal of 350 wolves in the final plan.
2. For increased accountability the population goal needs to have a timeline for completion.  The goal timeline allows measuring of progress towards meeting the set population goal with milestones along the way.  We request a population goal timeline be added to the plan.

Quotas/Permits:

1. The western states have 13 years of harvest data in establishing quotas to reach their wolf population goals.  We recommend including this data in the draft plan to aid in establishing quotas. 
2. Permit issuing methodology should be based on the likely harvest methods used in the season they will be issued.
3. Western states have been unable to reduce their wolf numbers consistently despite high levels of human take.  As wolf expert David Mech said, “Wolves are prolific, disperse long distances, readily recolonize new areas where humans will allow them, and are difficult to control when populations become established."

Delisting:

1. For lethal wolf conflict control and population management to take place federal delisting is required.  To-date the Wisconsin Department of Natural Resources has had no visible involvement in planning, researching, and federal delisting efforts with the USFWS or with legal representation in delisting efforts.  The Wisconsin Wildlife Federation strongly requests the WI DNR have a strong and visible presence, and active involvement in all federal delisting efforts that impact Wisconsin and in support of all other states actively working towards delisting wolves in their states.

The Wisconsin Wildlife Federation requests the Wisconsin Department of Natural Resources incorporate the above actions and requests for updates into the 2022 Final Wolf Management Plan. 

Sincerely yours,

Patrick Quaintance