The Washington Department of Fish and Wildlife (WDFW) is seeking public comment from February 22 to April 11, 2022, on proposed rule changes to address wolf-livestock conflict deterrence.
In September 2020, Governor Jay Inslee directed the WDFW to initiate rulemaking to institute practices that would reduce the number of livestock killed or injured by wolves and the number of wolves lethally removed because of depredations of domestic animals.
So why should Western Washingtonians care about this proposed rule and what is happening East of the mountains?
We should care because removing a species can change the world.
Wolves are a keystone species, defined as “an organism that helps define an entire ecosystem. Without its keystone species, the ecosystem would be dramatically different or cease to exist altogether.”
Keystone species are often predators, like wolves, who have low functional redundancy. This means if they were to disappear from an ecosystem, no species would be able to fill the void left by its absence.
So, what do wolves do for an ecosystem?
Wolves keep the prey populations from getting too large, which ensures that a greater variety of species survive and thrive. Overgrazing of natural resources influences other populations of birds, small reptiles and plant organisms which can threaten their survival.
They usually kill weak or diseased animals also helps sustain a healthy environment. A 2020 study from Colorado State University showed that Chronic Wasting Disease (CWD) infected deer were four times more likely to fall to predation than their healthy counterparts.
By simply existing wolves (and other predators) may potentially help slow down disease in deer, primarily CWD.
In addition, wolf kills create an abundant and dependable food source for many other species. Researchers have documented wolf kills benefiting coyotes, bald eagles, golden eagles, grizzly bears, black bears, ravens, magpies, red foxes and at least 20 other species.
As of the end of 2020, there were 132 wolves in Washington State, with 46 more reported by the Confederated Tribes of the Colville Reservation. Over the years, many packs have been wiped out over cattle grazing rights.
The motivation for removing predators is easy to understand, but will doing so achieve the desired results? One of the oldest ways of dealing with predators is to cull or remove them, and time after time, it just doesn’t work.
The proposed rule change, if adopted, would amend the language of Washington Administrative Code (WAC) 220-440-080 to require that, to authorize lethal removal of wolves, the WDFW director (or WDFW staff designee) would need to confirm an owner of domestic animals has proactively implemented appropriate non-lethal conflict deterrence measures.
This would also create a new rule (WAC 220-440-260) that directs WDFW staff, in consultation with willing, affected livestock producers, as well as affected federal, state, and tribal agencies, to author conflict mitigation plans that would establish area-specific criteria for the use of non-lethal and lethal measures to mitigate wolf-livestock conflict in areas of chronic conflict.
“If adopted, the proposed change to WAC 220-440-080 would align the code with the agency’s long-standing commitment to non-lethal conflict mitigation strategies,” said Wolf Policy Lead Julia Smith.
“The proposal creating WAC 220-440-260 aims to address areas that have experienced significant levels of livestock depredation and subsequent wolf removals year after year, an especially difficult scenario for all communities concerned about wolf conservation and management. This proposal focuses limited time and resources to areas where the most livestock and wolf loss has occurred in the state.”
In addition, a Draft Supplemental Environmental Impact Statement (DSEIS) that analyzes the environmental impacts of four alternative rulemaking options and a Small Business Economic Impact Statement (SBEIS) that evaluates the potential costs to businesses in the livestock industry resulting from the proposed rule and rule change was developed as part of the rulemaking process.
During this public comment period, WDFW is looking for input on the draft proposed language for both WACs and feedback on the DSEIS.
Please use this link to review the rule change materials and share feedback on the proposed rule language. Written comments can also be submitted via email to WolfConflictDeterrence102@PublicInput.com, or members of the public can call 855-925-2801 (enter project code 3861) to record their input.
- Please use this link to review the SEPA materials and share feedback on the DSEIS. Written comments can also be submitted via email to SEPAWolfConflictDeterrence@PublicInput.com, or members of the public can call 855-925-2801 (enter project code 6659) to record their input.
A Public Hearing is expected to be scheduled for April 2022. The final SEIS is planned to be issued in May, and the Fish and Wildlife Commission will consider the proposal in May of 2022. The rule and/or rule changes that may result from this process are proposed to be effective in January 2023.
Visit the Department’s website for more information on the proposed rule and the rule-change process. More information on wolves in Washington can be found at https://wdfw.wa.gov/species-habitats/at-risk/species-recovery/gray-wolf.
When asked her opinion of the proposed rule change, Samantha Bruegger Executive Director for Washington Wildlife First, said “The proposed rule does not address the problems that the rulemaking petition sought to solve, and is not responsive to the request from Governor Inslee to implement “clear and enforceable measures” to address wolf-livestock conflicts. The state’s endangered wolves deserve better protection, and the citizens of Washington deserve a rule that will hold the Department of Fish and Wildlife accountable and require it to meet certain standards before it kills state-endangered wolves.”
“Ultimately, I would urge the Department to start over again, using the carefully crafted language proposed in the rulemaking petition. In the past year and a half, the Department has done nothing to improve on that language but has instead watered it down to the point that it imposes no additional restrictions on its authority. As a result, the proposed rule does nothing but solidify that the Department Director can authorize the killing of endangered wolves without any transparency, accountability or adherence to meaningful standards. The people of Washington, whose tax dollars pay for the Department to operate its wolf-killing program, deserve better, and wolves most certainly deserve better.”
But aside from the rule change being the correct administrative thing to do, it should be changed because all animals deserve a place in the ecosystem. We may not like what one animal does, but that does not give us the right to remove that animal.
One of the most enduring and moving sounds anyone can hear is a wolf’s howl as darkness falls. Whether it is a feeling of tranquil peace or utter fear, it is an emotion that can only be evoked by wild wolves that are free to reign in the land that was once theirs.