Will N. Graves 900 Hillen Drive
Millersville, MD 21108
3 Oct 1993
ATTN : Ed Banks, US Fish & Wildlife Service Project Leader
Dear Mr. Banks,
Thank you for the opportunity to comment on the DEIS regarding “The Reintroduction of Gray Wolves to Yellowstone National Park & Central Idaho.” I support Alternative 3, the No Wolf Alternative.
1. Diseases, Worms, and Parasites. I was surprised that the DEIS did not make a detailed study on the impact issue of diseases, worms, and parasites (page 9). I believe an EIS is not complete without a detailed study covering the diseases, worms and parasites that wolves would carry, harbor, and spread around in YNP and in Idaho. The study should cover the potential negative impact of these diseases on wild and domestic animals, and on humans. I believe the potential negative impact of these diseases is a valid reason not to reintroduce wolves into YNP and to Idaho.
Countless articles about the diseases, worms, and parasites carried, harbored, and spread around by wide ranging wolves have been published in a magazine sponsored by the former Soviet Ministry of Agriculture. For example, a Soviet biologist reported that gray wolves are carriers of a number of types of worms and parasites which are dangerous for animals and for humans. According to this biologist, the main <Rff!’” is cestoda. Over approximately a ten year period, the Soviets conducted a controlled study on this subject. They made the following observations. When and where wolves were almost eliminated in a given rese.arch area, (where almost all wolves were killed by each spring and new wolves moved into the controlled area only in the fall) infections of taenia hydatiqena in moose and boar did not occur in more than 30 to 35% of the animals. The rate of infections were 3 to 5 examples in each animal. When and where wolves were not killed in the controlled areas in the spring, and where there were 1 or 2 litters of wolf cubs, the infections in moose and boar of taenia hydatiqena reached 100% and up to 30 to 40 examples of infection (infestation) were in each moose and boar. Each year the Soviets studied 20 moose and 50 boar. The research was documented and proved that even in the presence of foxes, racoons, and domestic dogs, ONLY THE WOLF was the basic source of the infections in the moose and boar. Examinations of 9 wolves showed that each one was infected with taenia hydatiqena with an intensity of 5 to 127 examples. This confirmed the soviet conclusions. The damage done by taenia hydatiqena to cloven footed game animals is documented by Soviet veterinarians. My concern is that if gray wolves in the former USSR carried and spread to game animals dangerous parasites, then there must be danger that gray wolves in YNP and in Idaho would also spread parasites. Why should we subject our game animals, and possibly our domestic animals to such danger?
If wolves are planted in YNP and in Idaho, I believe the wolves will undoubtedly play a role in the epizootiology and epidemiology of rabies. The wolf has played an important role, or perhaps a major role, as a source of rabies for humans in Russia, Asia, and the former USSR. From 1976 to 1980 a wolf bite was the cause of rabies in 3.5% of human cases in the Uzbek, Kazakh, and Georgian SSRs and in several areas of the RSFSR. Thirty cases of wolf rabies and 36 attacks on humans by wolves were registered in 1975-78 only in the European area of the RSFSR. In the Ukraine, wolf rabies constituted .8% of all cases of rabies in wildlife in 1964 to 1978. The incidence of wolf rabies increased six fold between 1977 & 1979, The epizootic significance of the wolf has been shown in the Siberian part of the former USSR. Between 1950 and 1977 a total of 8.7% of rabies cases in the Eastern Baikal region were caused by wolf bites. In the Aktyubinsk Region of Kazakhstan, of 54 wolves examined from 1972 to 1978, 17 or 31.5% tested positive for rabies. During this period, 50 people were attacked by wolves and 33 suffered bites by rabid wolves. This shows that healthy wolves also attack and bite humans. Recent Russian research states that as the numbers of hybrid wolves increases, the likelihood of a healthy hybrid wolf attacking humans also increases. Russian wildlife specialists state that when there is no hunting of wolves, the possibility of wolves attacking humans also increases, as the wolves lose their fear of humans.
Wolves not only have and carry rabies, but also have carried foot and mouth disease and anthrax. Wolves in Russia are reported to carry over so types of worms and parasites, including echinococcus, cysticercus and the trichinellidae family.
Prior to planting wolves into YNP and Idaho, I respectfully request a detailed study be made on the potential impact wolves will have in regard to carry, harboring, and spreading diseases.
I believe bringing wolves into YNP and into Idaho will increase the cost of meat and animal products. It will take a lot of work and cost a lot of money for our ranchers to protect their animals from wolves. Why should we subject our ranchers to these increased costs?
2. Prey Animals Normally Killed by Wolves. I do not understand the wide discrepancy in the number of prey animals projected to be killed annually by one grey wolf in YNP/Idaho, and the numbers of prey animals killed annually by one grey wolf in Russia. The Soviets have professionally documented the number of prey animals “normally” killed by one wolf in one year. I realize there are many factors involved. However, Soviet literature states that one grey wolf will kill SO deer each year (about 1 per week), or up to 90 saiga (Saiga tatarica L.) or 50 to 80 boar, or about 8 to 10 moose. I understand that the US estimate is one wolf will kill one deer every 23 days. Why is there such a difference in these figures?
Russian and Soviet literature is filled with examples reporting that wolves kill extremely large numbers of game and domestic animals. In the Krasnoyarskij Region wolves kill 30 to 40,000 reindeer and 700 to 800 moose each year. In the Putorana Plato, just east of Norilsk, wolves kill about 20,000 reindeer each year.
3. Lustful Killing by Wolves. It is well documented that wolves are lustful killers. Look at some of the figures. Here are some examples from Soviet literature. Eight wolves killed 50 reindeer in about two days. In 1978 one wolf killed 39 reindeer in one attack, and another wold killed 29 in one attack. A pack of wolves killed over 200 sheep in a few short attacks. There are many, many examples of lustful killing of animals by wolves in the former USSR.
In Sweden in 1977 one wolf killed between 80 and 100 reindeer in 19 days. Is there any doubt that a high majority of Swedish reindeer owners (over 70%) reject efforts to protect wolves?
Does the FWS expect that wolves in the US will not carry out lustful killing attacks, especially during periods of crusted or heavy snow? What would these attacks have on the populations of small game herds? Do the US estimates on the number of prey expected to be taken by wolves account for any lustful attacks?
4. Wolf Attacks on Humans in the Former USSR. In the former USSR, it was not unusual for wolves to attack or threaten humans. (Details are available.) Some of these attacks were done by non rabid wolves. There are remote villages in Siberia that have been under siege by wolves. The villagers would not dare go out of their houses at night for fear of wolf attacks. I believe bringing wolves into the US will create a threat to humans that is just not necessary. There is extensive information in the world about the behavior of wolves. Gray wolves attack and kill humans in Asia, so I do not support planting. them anywhere in the US.
5. . . . Wolves Affect Structure of Prey Populations. Wolves not only reduce the size of prey populations, but also have a marked effect on the structure of the prey population. Detailed research by the Soviets showed that in areas inhabited by wolves, about 50% of the moose and deer calves do not reach the age of six months. In areas where the wolves had been exterminated, the loss of calves of moose and deer was only 7 to 9%. The negative effects of wolves on populations of ungulates is especially apparent in years when there is heavy snow or crusted snow. In just one severe winter, wolves can almost completely destroy the ungulate population in the area. In these conditions, wolves pay little attention to the animals they killed, because it is so easy for the wolves to kill the almost helpless animals. Documenting these lustful killings is almost impossible due to the conditions.
6. Cost. I do not support spending 6 million dollars to reintroduce an experimental wolf population. In this high deficit period, we need to cut all unnecessary spending, and this is a good area to cut. During the years of the USSR, wolves cost the Soviets about 45 million dollars per year. The US need to keep our “wolf costs” to a minimum.
7. Reduction in Harvest of Female Elk. Why should we let wolves kill female elk rather than let US hunters bag them? Let us keep the wolves out, and if the ungulate population becomes to large for food and cover, then we should let hunter bag the excess game. Part, or even all of the meat could be given to the poor. I believe wildlife managers should use hunters to control excess populations of game, and not wolves.
8. States Manage Own Land & Resources. I believe eadh state should have primary authority and rights to manage its own land and resources.
9. The Wolf is the Most Dangerous & Damaging of all Predators of Fauna. Am eminent Soviet professional wrote that if all the predators of fauna were placed in a list according to the degree of damage and danger to humans, the wolf, without a doubt, would be in first place at the very top of the .list, and would far outdistance its closest competitors.
I believe it is time to stop idealizing the role of the wolf in nature. The wolf is a powerful, vicious, dangerous, damaging and lustful predator. The wolf is an almost perfectly designed killing machine. Some Soviet researchers state that US wolf specialists generally overestimate the selectivity role of the wolf in nature. Wolves do kill weak and deformed animals, but wolves kill many perfectly fit, healthy animals. Wolves select prey animals based on many circumstances. It is a fact that wolves prefer females that are in late stages of pregnancy and young animals. There are many people who, try to emphasize that wolves select only old, weak, sick or deformed animals for prey; the facts do not support this belief.
I recently read a book for children about wolves. The book showed a white tail deer about two years old, and stated that this is a healthy deer and thus does not have to be afraid of wolves since a healthy deer can run faster than a wolf. If you accept this as fact, then how do you explain that thousands upon thousands of perfectly healthy, fit deer are killed each year by wolves. It is time for us to teach the truth about wolves. I still meet people who believe that wolves in the northers regions of Canada do not kill reindeer for food - that the wolves prey only on lemmings. Then they say that a “specialist” on nature proved that by a detailed study about wolves which he published in a book.
Wolves cause some prey to suffer terribly. Some Soviet technical literature about wolves describes in detail how wolves kill their prey. It is not a pleasant subject. It may take several days for a few wolves to kill a large, male moose. During this time the wolves are actually eating the moose alive. Wolves often eat sheep when they are still alive.
After reading Russian and Soviet literature about wolves for so many years, and talking to Russians who have had experiences with wolves, I have come to the conclusion that many American wildlife biologists have become enamoured/infatuated with the wolf. To these American wolf experts, it appears that “the wolf can do no wrong.” Although I am not a biologist, I have learned a lot about wolves and their behaviour in Czarist Russia and in the USSR. What I have learned has convinced me that it would be a mistake to plant wolves in the YNP and in central Idaho.
September 9, 2013
The Honorable Sally Jewell Secretary
United States Department of the Interior
1849 C Street NW
Washington, DC 20240
The Honorable Dan Ashe Director
United States Fish and Wildlife Service
1849 C Street NW
Washington, DC 20240
Dear Secretary Jewell and Director Ashe:
It is my duty as Chairman of the Arizona Game and Fish Commission to forward the attached Commission Resolution passed by this body at our September 6 Commission meeting in Show Low, Arizona, to express our disappointment at the refusal to hold public scoping hearings in Arizona regarding the proposed expansion of Mexican wolf conservation, an expansion that will almost certainly deliver a preponderance of the program’s social, financial, and biological costs to the citizens of Arizona.
As your partners in this effort since the program’s birth, the passion of the resolution’s language reflects our regret at what seems like an opportunity being missed by the Department of Interior and the U.S. Fish and Wildlife Service to show their respect for those who share the working lands of Arizona with this species and who will live with the consequences of this program, potentially in perpetuity.
The best meetings in Sacramento, Albuquerque, or even the nation’s capital, will not suffice as substitutes for meeting on the affected land with the affected parties.
Sincerely,
The Arizona Game and Fish Commission
A RESOLUTION OF THE ARIZONA GAME AND FISH COMMISSION CONCERNING SCOPING HEARINGS ON THE EXPANSION OF MEXICAN WOLF CONSERVATION
WHEREAS, the Arizona Game and Fish Commission and Arizona Game and Fish Department (AGFD) have been partners with the United States Fish and Wildlife Service (USFWS) in Mexican wolf conservation since the effort’s inception; and
WHEREAS, the Endangered Species Act (ESA) envisions a significant role for state fish and wildlife agencies in endangered species conservation and recovery efforts; and
WHEREAS, since the Mexican Wolf conservation effort promulgated under section 1O(j) of the ESA, Arizona has been the only state in which primary releases of Mexican wolves have been allowed; and
WHEREAS, the primary capacity for the Interagency Field Team has been supplied by personnel from AGFD, and
WHEREAS, the congressional record clearly reflects congressional intent that rules promulgated under section 1O(j) of the ESA will reflect an agreement between the USFWS and the affected states; and
WHEREAS, the National Environmental Policy Act requires adequate public notice and opportunity to comment which should involve public hearings near the location of the proposed action; and
WHEREAS, the USFWS has received written requests to hold public scoping hearings in Arizona directly from the AGFD, Graham County, Greenlee County, Navajo County, Apache County, Gila County, and specifically from US Congressman Paul Gosar, US Congresswoman Ann Kirkpatrick, and Senator Jeff Flake; and
WHEREAS, the USFWS has publicly announced its decision to hold scoping hearings in Washington, DC, where there are no plans to conserve Mexican wolves; and to hold public scoping hearings in Sacramento, CA where there are no plans to conserve Mexican wolves; and
WHEREAS, the USFWS has elected to hold a public scoping hearing in Albuquerque, NM as the only state in which Mexican wolf conservation would be involved; and
WHEREAS, the USFWS has specifically not elected to hold any public scoping hearings in Arizona; and
WHEREAS, the citizens of Arizona will unarguably be the most affected by the decisions to be made;
NOW, THEREFORE, BE IT RESOLVED that the Arizona Game and Fish Commission expresses its extreme concern that the USFWS has refused to hold public scoping hearings in Arizona regarding proposals to expand Mexican Wolf conservation efforts;
BE IT FURTHER RESOLVED that the Arizona Game and Fish Commission demands that the Secretary of the Interior and Director of the USFWS reconsider this decision and schedule public scoping hearings in the State of Arizona with at least one meeting to occur in a community geographically located within the proposed I O(j) area.
ADOPTED on the 61 day of September, 2013 by the Arizona Game and Fish Commission.
Arizona Game and Fish Commission
