EIS Public Comment: Establishment of a Nonessential Experimental Population of the Gray Wolf in the State of CO
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RyGuy
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Some context if folks aren't aware, to help you make substantive comments (the only kind FWS will consider). CPW has requested that FWS issue a 10(j) rule designating the reintroduced population as an experimental population. This will give CPW broader management latitude after wolves hit the ground, including the ability to allow livestock producers to lethally remove predating wolves. This EIS is not going to influence the effort to reintroduce wolves. It's going to influence how they are managed once they are here.
D
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It is unfortunate there is a not a stop gap that says "wolves are already here, let's see how that plays out first" before we spend money and time importing more.
D
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@Oak, any talking points or verbiage you would like us to focus on in commenting here? Not asking you to do the work for me, just sounds like you have a firmer grasp and I'd rather leave impactful comments. I'd like to make sure our management takes into account what we've already seen in MT, ID, WY and act accordingly
I guess it depends on whether one supports the Service's issuance of a 10(j) rule. As I said, CPW has asked for it so that they have broader management discretion. It will potentially reduce impacts to stakeholders and perhaps increase acceptance and overall success of the program. In general, if you support a proposed action you can usually find your talking points within the scoping notice, as the agency informs the public of why they are proposing the action.
In this case, the FWS is proposing a couple of potential actions for which you can comment. In addition to issue a 10(j) rule, they could also establish an assurance agreement under 10(a)(1)(A) which would allow "any act otherwise prohibited by section 9 for scientific purposes or to enhance the propagation or survival of the affected species, including, but not limited to, acts necessary for the establishment and maintenance of experimental populations pursuant to subsection (j)" for the existing population. Essentially, it gives them the authority to manage the wolves that are already here as well as the introduced wolves.
Text from the NOI that could be used/modified to express support for the proposed actions:
"The section 10(j) rule would address components of the gray wolf restoration and management plan developed by the State of Colorado. The rule would reduce potential impacts to stakeholders while ensuring that reintroduction and management of wolves is likely to be successful and benefit conservation of the species as a whole."
"Currently, the Service lists the gray wolf as endangered. To facilitate reintroduction efforts, the State of Colorado requested that the Service designate wolves in Colorado as an experimental population under section 10(j) of the ESA. This designation would reduce the regulatory impact of reintroducing a federally listed species in a specific geographic area (within a proposed boundary), contributing to the species' conservation."
in short, i think this is something hunters should be commenting favorably on. this will provide greater management flexibility and should especially benefit livestock producers as conflict arises.
we're long past talking about and commenting to agencies on how we don't want wolves, ship has long since sailed, I think is one of Oaks primary points.
we're long past talking about and commenting to agencies on how we don't want wolves, ship has long since sailed, I think is one of Oaks primary points.
elkduds
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Comment submitted, thanks to OP and others on this thread.
D
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Thanks @Oak for the tips. Comments submitted
RyGuy
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kwyeewyk
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It is an interesting list of issues they're seeking comments on considering the scope of the EIS being limited to issuing 10(j) rule/10(a) permit or not. Honestly it seems difficult for the average person to provide truly substantive comments on most of these topics, beyond personal opinions. I'd like to hear some of the ideas you all might have for some of these for those willing to share.
We solicit input on the following issues:
(1) The regulatory approaches we are considering for managing reintroduced gray wolves in Colorado.
(2) Other approaches, or combinations of approaches, we should consider with respect to managing reintroduced gray wolves, including potential management actions in adjoining States.
(3) Specific requirements for NEPA analyses related to the proposed action and alternative approaches.
(4) Considerations for evaluating the significance of impacts on gray wolves and other affected resources, such as other listed or sensitive wildlife and plant species, cultural resources, and socioeconomic resources or activities.
(5) Information regarding other resources that may be affected by the proposed action.
(6) Considerations for evaluating the interactions between affected natural resources.
(7) The potential costs to comply with the actions under consideration, including those that would be borne by the Federal Government and private sectors.
(8) Considerations for evaluating the significance of impacts on species, locations, or other resources of religious or cultural significance for Tribes and impacts to cultural values from the actions being considered.
(9) Considerations for evaluating climate change effects to gray wolves and other affected resources.
(10) How to integrate existing guidance and plans, such as the Colorado wolf management plan (under development), into the proposed regulatory framework.
We solicit input on the following issues:
(1) The regulatory approaches we are considering for managing reintroduced gray wolves in Colorado.
(2) Other approaches, or combinations of approaches, we should consider with respect to managing reintroduced gray wolves, including potential management actions in adjoining States.
(3) Specific requirements for NEPA analyses related to the proposed action and alternative approaches.
(4) Considerations for evaluating the significance of impacts on gray wolves and other affected resources, such as other listed or sensitive wildlife and plant species, cultural resources, and socioeconomic resources or activities.
(5) Information regarding other resources that may be affected by the proposed action.
(6) Considerations for evaluating the interactions between affected natural resources.
(7) The potential costs to comply with the actions under consideration, including those that would be borne by the Federal Government and private sectors.
(8) Considerations for evaluating the significance of impacts on species, locations, or other resources of religious or cultural significance for Tribes and impacts to cultural values from the actions being considered.
(9) Considerations for evaluating climate change effects to gray wolves and other affected resources.
(10) How to integrate existing guidance and plans, such as the Colorado wolf management plan (under development), into the proposed regulatory framework.
I think the same could be said for Idaho, Wyoming and Montana. They were all 10j and look at the mess getting them delisted was after they well exceeded delisting goals. I don’t think it’s a stretch to think they would still be listed if it wasn’t for the congressional delisting
I wish Colorado luck and support native critters on the landscape but wonder what the point of spending money and time on reintroduction is when they’re already present
This rule isn't about "spending money to reintroduce wolves". This rule isn't what kept the court battles going/wolves listed. It is a rule that will give managers and producers more tools and protections when dealing with wolves. MT, if memory serves, had a 10(j) population and non-10(j) population. Ask wolf affected producer in northern MT how that worked out.... you wanted to be south of the line if you had conflict.
While the 10(j) isn't a perfect rule to operate under it affords the state, and the service a lot of latitude. As Oak said above, if the service does not issue a 10(j) rule wolves will have full status. Under that status "management or control" are much much more difficult.
What has been allowed under 10(j) has varied over time and through the legal battles as well. During WY's last "listed" run lethal take permits were no longer allowed or issued. I guess short story, if you are going to get wolves through migration or through introduction, my $.02 is you want a 10(j) covering them all, and you want as many management options (including lethal) covered under that rule as possible.
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