Montana Shooting Sports Association President Submits Comments On Wolf Delisting
December 4, 2008
Gary Marbut, President of the Montana Shooting Sports Association, has submitted his comments to the U.S. Fish and Wildlife Service as part of the public comment period required before the Service can proceed with a second attempt to remove the gray wolf from federal protection under the Endangered Species Act. Below is a copy of those comments.
~~~~~~~
November 12, 2008
NRMGrayWolf@fws.gov
Subject: “RIN number 1018-AU53″
U.S. Fish and Wildlife Service
Western Gray Wolf Recovery Coordinator
585 Shepard Way
Helena, Montana 59601
In re: Comment — Canadian Wolf Delisting and Designating the Northern Rocky Mountain Population of Wolf as a Distinct Population Segment
Submitted electronically.
Dear Sirs,
The Montana Shooting Sports Association (MSSA) is the primary organization asserting the rights and prerogatives of hunters in Montana. MSSA has members throughout Montana. MSSA was opposed to the initial “introduction” of Canadian Wolves into Montana, supports the earliest removal of these wolves from protection by the federal government, and opposes any Distinct Population Segment designation for the following reasons:
First, MSSA incorporates by reference here all comments previously submitted on March 31, 2006. Those comments are posted at:
http://www.mtssa.org/wolfdelist.phtml
Second, MSSA has the following additional comments to add to the record:
Argument has been made that “genetic diversity” and “genetic connectivity” of wolf populations must be assured before wolves may be delisted in the northern Rocky Mountains. We assert that these conditions are not required under the Endangered Species Act. We also assert that there currently exists sufficient “genetic diversity” and “genetic connectivity” of Northern Rockies wolf populations to pass any rational, unbiased test. We assert that wolf advocates had years to raise these issues, but either slept on their rights or committed fraud though deliberate silence.
Further, wolf introduction efforts, coupled with failure to delist, does has never adequately addressed the issues of wolf transportation and transmission of disease and parasites that may affect people, domestic animals and other wildlife.
Finally, the introduction of Canadian wolves into the Northern Rockies may have eradicated the different and endangered wolves already living here, making the release of Canadian wolves itself a violation of the Endangered Species Act.
Genetic diversity. This topic is over-hyped. Those involved in animal husbandry will affirm that genetic diversity is not any sort of prime requirement for healthy animal populations. Many animal breeders actually concentrate bloodlines in order to produce desirable traits in offspring, without any species degradation. This has been done since before biblical times.
In addition, scientific testimony was presented in the lawsuit in federal court to reverse the previous delisting effort to document that some populations of wolves begun in isolated location(s) with only one male and one female, and with no additional injection of genetic material, are thriving - that lack of genetic diversity is no handicap to species survival whatsoever.
Further, the Canadian wolves that were released in Montana by the USFWS were drawn from several different parts of Canada, giving that released population a genetic diversity base far exceeding that necessary for a healthy population.
Actual practice and historic observation inform us that the only genetic diversity issue of any real consequence whatsoever is that there be both males and females. Once that diversity threshold is achieved, all rational genetic diversity needs have been met.
Those who advocate genetic diversity have offered no proof that genetic diversity among wolves is either desirable or necessary. If genetic diversity is so important, why has it taken wolf advocates over a decade to discover and articulate it? Why was argument for genetic diversity not made when the Endangered Species Act was crafted, or when the several state wolf management plans were devised? If the argument of genetic diversity has been apparent to the wolf advocates for a decade but they have deliberately not raised it until the 11th hour could that long silence be a type of fraud?
Genetic diversity is a thin, ruse argument. It is grasping at straws. Anyone who claims merit in that argument is either agenda-driven and using the argument as a facade, or they are living in la-la land.
Genetic connectivity. This argument is also a ruse. First, wolves social makeup is strongly antagonistic to genetic connectivity. Wolves regularly and reliably kill other wolves, with other genetic makeup, that stray into the area claimed by a pack. So, wolves actively resist genetic connectivity, no matter how much nature-loving environmental activists wish it were otherwise.
Second, without need for genetic diversity, as discussed above, there is simply no need for genetic connectivity.
Third, there is already a potential for genetic connectivity that is probably an order of magnitude greater than anything that might be required for a genetically-stable population. For example, a few years ago a wolf collared and released in Montana was found as road-kill in Texas. This wolf had traveled an incredible distance.
There are three populations of wolves discussed in the Northern Rockies; the population migrating from Canada in northwestern Montana, the population introduced into the Yellowstone Park area, and the introduced population in central Idaho. There are documented wolf packs west of Missoula, both north and south of Interstate 90, and area that is roughly equidistant from the three general populations mentioned preceding. It is axiomatic to presume that the wolves west of Missoula came from one of the other three wolf population centers. Ergo, if wolves can reach the center of the existing population triangle, wolves are then quite capable of reaching any part of the triangle from any other part of the triangle. To say otherwise is to defy rational thought.
If there is inadequate intermingling of wolf genetics (according to some), it is mostly because wolves kill strange wolves at the first opportunity. Perhaps the advocates of genetic connectivity ought to be assigned the task to force the mating of wolves strange to each other (sorry, no protective clothing or protective devices allowed). Let’s get on the record just how well wolves tolerate that.
Laches. Wolf advocates have long known terms of delisting. Those objecting to delisting had years to raise new issues concerning delisting, but they never did. They cannot claim ignorance of pending delisting. There have been multiple opportunities to new raise issues in comment on state management plans, listing and delisting, yet genetic diversity and genetic connectivity have never before been central to the wolf advocates’ position. See laches and 1-3-218, M.C.A., “Vigilance. The law helps the vigilant before those who sleep on their rights.”
Disease and parasites. Precious little attention has been paid to the diseases and parasites for which wolves may be vectors. Wolves are certainly hosts to or potential vectors for many dangerous diseases and parasites that affect other wild animals, livestock and humans, e.g. distemper, rabies, anthrax, brucellosis, echinococcus granulosis, and others. Because wolves are so highly mobile, their role as vectors is a huge liability to other species also subject to the diseases and parasites they may carry. Therefore, the potential exists for wolves to have a vast and incalculable negative impact upon other species, domestic, wild, and of course, humans.
For more information about disease and parasite transmission, I reference Wolves in Russia by Will Graves, and incorporate that book by reference in this comment.
I submit that the liability associated with far-ranging wolves as disease and parasite vectors argues strongly for aggressive wolf management by the affected states.
Eradication of native wolves. In her book Yellowstone Wolves, Kat Ubrikit makes a compelling case that a separate subspecies of wolf inhabited the greater Yellowstone area, including Montana and Wyoming, than the subspecies of Canadian wolf released by the FWS. This subspecies looks different, has different social structure, and hunts differently. There is a history of far too many documented sightings of this native subspecies for there to be any rational doubt that it existed prior to the release of Canadian wolves. Facing the near-certainty that this native subspecies existed and inhabited Montana and Wyoming, then the thoughtless or arrogant release of the Canadian subspecies was an overt violation of the Endangered Species Act.
By reference here, I incorporate the entirety of Yellowstone Wolves by Kat Ubrikit.
These reasons and those submitted on March 31, 2006 are all arguments why it was a mistake for wolves in Montana to come under federal protection, why it was a mistake for Canadian wolves to be introduced into Montana, and why it is important to remove all federal protection and allow state control at the earliest possible date.
Sincerely,
Gary Marbut
President, Montana Shooting Sports Association
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Good to see the start of those who are interested in the preservation of out great herds of deer and elk, giving hell to the SOBs that instituted this sham in the first place…The only way to control the wolf population is going to be too late to do any good until after all our herds are exterminated….unless they feel the heat of our combined efforts.
Awe shucks, there’s them NATIVE WOLVES again that some people don’t believe IDAHO/MONTANA/WYOMING already had present prior to this ESA lie and illegal re-introduction of an ALIEN wolf.
Now here is a non scientific statement: “have a vast and incalculable negative impact “. I am sure that will impress the legal minds dealing with this issue.
“Awe shucks, there’s them NATIVE WOLVES again” . And I will ask AGAIN, for at least the third time, since wolves have such high reproductive rates, why did the natives not “explode” and fill the available habitat? They apparently had plenty of time. SSS perhaps? Too many gut shot wolves?
Super Sensative Socialist with a gut ache, take a court of bamboo shoots with water and write us in the morning.
Greg is avoiding the issue as usual. When he can’t answer a question he switches the topic.
Just more of your bull ticky : “Super Sensative Socialist with a gut ache, take a court of bamboo shoots with water and write us in the morning.” Was court supposed to be quart?
Lee, did you trade places with Bea? Or just change sexes? Since you two work for the same master, do you two change identities, or just sexes? Does your anti-hunting organization pay you for each post, or are you on their payroll to post whenever you want?
“And I will ask AGAIN, for at least the third time, since wolves have such high reproductive rates, why did the natives not “explode” and fill the available habitat? They apparently had plenty of time. SSS perhaps? Too many gut shot wolves?”
Since you asked such a dumb question, I wonder why any specie never came back without man’s help….ya think maybe they found a place where they could live in safety and not be found, could be reason enough…? And maybe there just wasn’t enough game in that area to provide unlimited reproduction? Reminds me of the way the Fand G in Florida denied there were any panthers elsewhere in the state, when we had them walking under our treestands…According to them, you couldn’t authenticate it if it wasn’t there to look at..
The brain trust of the wolf lovers are the ones saying that in order for wolves to sustain a population, they must have a minimum number. So, what is that number? 1?, 12?, 100?, 500?, 1000?, 20,000?
I don’t think there is any # that would please them.
These are people with way to much time on there hands They always have to have a cause no matter how ridiculous. What they need is a job Maybe if they did something other than cry about something all the time they would be tired enough from work to just take a break..
It’s a stupid question Lee, not worthy of my time. It is an insinuation that several people across three states are liars and made up the Native Wolves actuall existence. They did exist and the reintroduced alien canadian wolves killed them out.
I knew you would not get the message I left in the last reply, it is court held by to Jap soldiers who decided to make a prisoner drink the ingredients listed. Bamboo with water torture and eventual death sentence.
They used more than a quart of water. In this case I decided in the court of my mind you should agree in the court of your mind to do this to your self as you are a useless indoctrinated fool, hiding behind a half name like the coward you are and then of course your a twit, sucker and easy to bait. I should take you bear huntin sometime.
I see you never avoid issues until you lose them, or are over whelmed with truths. But by all means keep posting please, I think your cute, funny, and I’m sure your boyfriend does to.
And on the typo spell checks front, people that resort to these childish attacks got nothing to prove and defeat themselves with their own stupidity. Welcome to that club as well. Mr. Lee Beatrical anti hunter wolf lover.
Greg,
Well said.
Lee might enjoy this tid bit of information as well, YOU ARE NOT ANONYMOUS ON THE INTERNET, your fake names and half names are useless. I have already Identified four bloggers in Sun Valley using fake names or psuedo names.
Http://blog.sunvalleyonline.com/index.php/2008/10/09/you-arent-anonymous-on-the-internet/
This blog which provides links to the agencies any one of us can hire to identify via trace methods leads to the culprits phone number eventually where the posts are originating from.
Lee, or Bea, or who ever might as well just use your real names because your known anyhow. And this is just a further insult any how by saying I am protecting my identity from dangerous thugs who own guns and hunt. NO YOUR NOT, you attack us with your drivel and are COWARDS.
Thats why I use my real name all the time and stand tall on my beliefs, and my own research.
To the folks that blog here and use half names but are honest and polite using respect and wish to only enjoy a blog site you agree with you are not being cowards. But keep in mind going to anti places of your presuasion they know you. Your PC leaves a foot print.
Now I am a hunter of animals and facts, and I can track a spider across the floor so you been warned. If I want something I will find it.
Tom asked the question “they must have a minimum number. So, what is that number? 1?, 12?, 100?, 500?, 1000?, 20,000?”
http://www.biologicaldiversity.org/news/press_releases/2008/wolves-02-27-2008.html
“The region’s population of 1,500 wolves still falls short of the 2,000 to 5,000 wolves that independent scientists have determined to be necessary to secure the health of the species. Wolves in the northern Rockies are endangered due to genetic isolation, lack of interchange between wolves in Yellowstone, central Idaho, and northwestern Montana, and an insufficient number of wolves. With continued recovery efforts, legitimate wolf recovery in the region is readily attainable.”
That is about the number currently found in the Western Great Lakes in a much smaller area than the NRM.
It’s impossible to accept biased “independent” studies from organizations that have an agenda. It’s also impossible to accept information that is readily proven false by as many if not more sources.
United Nations earth justice, Croaked the frog…CROOOOAAAAAAAKKKKK. I just moved four wheel barrels of horse shit this morning from the pen to the pile……now this “indepedent” humane society funded nonsense about 1500 wolves and they want more wolves, crap…we’ve all seen before. Should be called wolf justice as it is phoney as a two dollar whore.
Charles E. Kay has a Ph.D. in wildlife ecology and is adjunct professor of political science at Utah State University and a Research Fellow for the Independent Institute. There is much in this report that supports your views. I include this quote because it deals with a minimum viable population size.
“To meet the legal mandate of the Endangered Species Act and biological requirements for minimum viable population size, 1,500 to 2,000 wolves as one interbreeding population will be required (see Figure 2). Although the science of determining minimum viable population size is still developing, numbers alone are not the only criteria (Soule 1987). Genetic variation must also be considered. Maintaining genetic variability is important because inbreeding has serious consequences for the long-term health of any population. Restrictive mating systems, where a few individuals do the majority of breeding, greatly reduce a population’s effective size.”
http://www.independent.org/publications/policy_reports/detail.asp?type=full&id=6
That’s correct but your quote is somewhat taken out of context when you consider the entire scope of Dr. Kay’s research and findings. He also says that in the case of the reintroduced wolves, Canadian wolves were used and selected because they already contained genetic diversity, reducing the need to interbreed “distinct population segments” of which there are none.
When you read more of Dr. Kay’s work you also find where he writes about how 1500-2000 wolves ranging in these three areas .
“Needless to say, 1500 to 2000 wolves will have a much greater impact on ungulate numbers, hunting opportunities and livestock operations than that projected in government reports.” (Wolves in the West by Dr. Charles Kay)
“Since wolf populations can increase by 100 percent or more each year and since wolves are known to disperse up to 200 miles or more, wolves will quickly repopulate the entire West.” (Wolves in the West by Dr. Charles Kay)
Dr. Kay also says it most accurately when he says that most of time wolf populations discussed and manipulated are not based on any science and are only used for political manipulation in order to achieve desired results.
I said there was a lot of information that supports your view in Dr. Kay’s report.
I think we should quit messing about and get more wolves from Canada, every state west of the Mississipi river should get 2000 wolves dumped out, problem solved. Then we can share the love together.
Farb - Unofficially there are a lot more states with wolves than most of us want to think. The same with cougars. I get contacted on a regular basis from groups wanting my help to verify that these creatures exist in any state we can find. I tell them thanks but not thanks! Nobody in their right mind would sign their own death sentence by helping that cause.
Agreed, I was just thinking give em what they want, the sooner their cause crashes the better. Instead of dragging this carnage out lets get it over with.