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- For question number 6 (on the form) “What topics of the plan does your comment address? (select all that apply)”: Select all the topics that apply to your comment or if you’re unsure, select “I don’t know/general comment”.
Chapter 2 – Background and Key Elements for Conservation and Management
- Additive and compensatory predation:
- Predation may replace predation by bears, lions, and other predators; the plan must discuss this concept.
- Review and incorporate the recent findings from Yellowstone (Smith et al. 2020).
- Expand discussion of the positive affects of wolves.
- Use recent work from CSU that specifically addresses the economic values of wolves.
- More comprehensively, recognize the potential positive effects of wolf predation on ungulate distribution and disease.
- Address the non-monetary benefits of wolves, including existence value.
Chapter 3 – Reintroduction Implementation
- Incorporate individual animal welfare concerns, e.g., for wolves injured during handling. . Any wolves injured during the process of capture, relocation and release should be considered for rehabilitation and relocation to a wolf sanctuary if possible.
Chapter 4 – Recovery of Wolves in Colorado
- Remove all references to Phase 4 (game species status, regulated public hunting), in Chapter 4 and any other occurrence except for the summaries of the Technical Working Group (TWG) and Stakeholder Advisory Group (SAG) recommendations.
- The voters defined the wolf as a nongame species (CRS 33-2-105.8) and intended, thereby leaving no path to game status. The final plan should close the door on any further consideration of game status.
- The SAG recommended the plan not include a decision about Phase 4.
- Revise delisting numbers from Phase 2 (state threatened) to Phase 3 (nongame) upward based on best available science.
- The draft criteria would not attain the standard of a “self-sustaining population” (CRS 33-2-105.8), as defined in conservation biology (Redford et al. 2011).
- The plan criteria depend on outdated estimates from the Northern Rockies, which do not apply directly to Colorado.
- Carrying capacity estimates are 750 to 1500 wolves in Colorado (Carroll et al. 2003, 2006).
- Add a geographic component to delisting criteria.
- Conservation science is clear that geographic distribution is an important part of recovery. 200 wolves could occupy as little as 8% of the available habitat.
- Clarify scientific concepts and cite science.
- Self-sustaining population:
- The plan must clearly define criteria must per Redford et al. (2011) and confirm as the explicit goal of the plan.
- Minimum viable population:
- Use the 100/1000 breeding individuals (i.e. 50 breeding pairs to prevent genetic bottleneck) “rule” for population viability (Frankham et al. 2014).
Chapter 5 – Wolf Management
- The impact-based management framework should cite the SAG consensus that “Nonlethal methods should be explored and encouraged before lethal; lethal methods should not generally be a first line of defense” as the overarching policy.
- Wolves should never be killed to prop up any other species. The SAG did not recommend this, with the extremely unlikely exception of other threatened or endangered species.
Chapter 6 – Wolf-Livestock Interactions
- Expand discussion of conflict minimization.
- Conflict minimization receives less than one page of discussion (pg. 50), it should be expanded and specifically recognize the opportunities to work with non-profit groups to implement methods.
- Incorporate the full SAG consensus recommendation for preventative, nonlethal conflict minimization.
- Describe the many available techniques for conflict prevention.
- Recognize that ~17% of wolf packs become involved in livestock depredation; most wolves never attack livestock.
- Modify compensation guidelines.
- The draft compensation plan is much more generous than intended in CRS 33-2-105.8.
- As written, the compensation guidelines, especially with the short attention given to conflict reduction, could result in unacceptably high compensation payments. CPW must evaluate the potential cost of the program at least partly through careful analysis of compensation for losses of livestock to wolves in other states.
- Incentivize the maximization of prevention as a prerequisite compensation.
- The plan should clarify that there is no SAG recommendation; the draft plan is based on the ranchers’ alternative.
- If paying for missing livestock at all, pay only 50% (rather than 100%) as these are probable, not verified losses.
- Whatever compensation plan is finalized should have a sunset clause ending it at the transition from Phase 2 to Phase 3.
- The land deserves to be made whole from, and the public deserves to be compensated for, the decades of loss.
Chapter 7 – Monitoring, Ungulate Management, Research, and Reporting
- Specifically recognize that elk numbers and hunter harvest in the Northern Rockies have increased since wolf restoration
- Recognize more explicitly the likelihood that while some may blame wolves for reductions in hunting opportunity, the ability to scientifically prove such an effect is highly questionable
Chapter 8 – Education and Outreach
- More explicitly outline what methods, and where and when CPW will reach out to inform the public about the potential for both positive and negative impacts of wolves.
Chapter 9 – Funding
- The plan should cite the requirement in CRS 33-2-105.8 of general fund support for wolf management.
Carroll, C., M.K. Phillips, N.H. Schumaker, and D.W. Smith. 2003. Impacts of landscape change on wolf restoration success: Planning a reintroduction program based on static and dynamic models. Conservation Biology 17:536-548.
Carroll, C., M.K. Phillips, C.A. Lopez-Gonzalez, and N.H. Schumaker. 2006. Defining recovery goals and strategies for endangered species: The wolf as a case study. BioScience 56(1):25-37.
Frankham, R., C.J.A. Bradshaw, and B.W. Brook. 2014. Genetics in conservation management: Revised recommendations for the 50/500 rules, Red List criteria and population viability analyses. Biological Conservation 170:56-63.
Redford, K.H., et al. 2011. What does it mean to successfully conserve a (vertebrate) species? BioScience 61(1):39-48.
Smith, D.W., D.R. Stahler, and D.R. MacNulty (eds.). Yellowstone Wolves: Science and Discovery in the World’s First National Park. University of Chicago Press, Chicago, Illinois.