Sun 7/14 – Mon 7/15: We’re up to over 600,000 comments to protect the wolves!!! But there are a lot of copies…Let’s pile on some new ones. Deadline – Monday 7/15, 11:59 pm EST

Action – If you think your comment might be considered a copy, please submit it again with more personal add-ons. Or try writing one for the first time. 

Way back in April, we asked everyone to write comments to prevent the Trump Administration from removing Endangered Species Act protections from wolves and declaring open season of an animal that is still functionally extinct in much of its former range. (Why? See “Background” below) We asked that people read other people’s comments here for inspiration if they needed it but to channel their 7th grade creative writing class and mix it up. The government will throw out DUPLICATE/OR NEAR DUPLICATE COMMENTS.  However…There are still a lot of exact duplicates!
If you feel that maybe your comment will be considered a copy, or just have some writing-zen going, please submit again.  (These are the starts for what look like the most popular copies)

  • (David Bernhardt) I am alarmed that the Trump Administration is ..”
  • I am appalled by the Department of the Interiors decision to strip …”
  • Scientists estimate that hundreds of thousands of wolves once inhabited …”

The proposed regulation to wipe out wolves is here

Howl back/comment here

Deadline this Monday (tomorrow- 7/15 ) at 11:59 PM EST.

Walk through these quick questions to spice up your comment with personal insights… Be passionate, be concerned, be snarky, be you!

  • Have you ever heard a wolf howl in the middle of the night? Were you sleeping in a tent? Did it make you feel that you were truly in a wild place?
  • How would you feel if it were impossible to ever hear it again?
  • Have you ever seen a wolf or some other large predator, like a bear, a mountain lion, or even a bobcat moving in its natural environment? Or even just their tracks? Is it one of the things you still talk about? “People want to see bears. They want to see wolves. They want to see mountain lions. It’s part of the natural heritage of the United States. We should be stewards of the system, not wiping out species and damaging ecosystems.” – Michael Mares, president of the American Society of Mammalogists.
  • Do you travel specifically to see animals in their natural environments?
  • How would you feel if you read that the last wolves were extinct in the US?
  • What would you tell your kids about why they were gone?
  • What would you say over lunch to David Bernhardt?

Then start (or re-start) your comment with something from the heart: 

  • Please don’t remove wolves from the Endangered Species List because…
  • I am terrified that…
  • I remember camping as a kid and…
  • When we went to Yellowstone…
  • Your own unique statement of why wolves, wildlife in general, nature, etc. are important to you _______________.

Then, throw in some facts. Choose 2 or 3, rewrite them in your own voice. 

The facts are clear and indisputable—the gray wolf no longer meets the definition of a threatened or endangered species.Today the wolf is thriving on its vast range, and it is reasonable to conclude it will continue to do so in the future.” Dept. of Interior Sec. David Bernhardt,  committed foe of the Endangered Species Act, remains “not-a-scientist” and “not-a-wildlife-biologist”.

Since the green area in the map below represents the wolves historic range and the little red areas represent their current range, we and David will just have to disagree on the word “vast”. Also the word “fact”. (Our comments tend towards “snarky”)


  • History:
    • Scientists estimate that about 2 million wolves once inhabited North America.
    • After the arrival of European settlers, wolves and their prey were the subject of widespread killing, including by government extermination programs. (See “Background” below)
    • Fewer than 6,000 gray wolves remain in the lower 48 states.
    • In 1967, wolves were finally recognized as endangered and given federal protections.
    • Today wolves occupy less than 10 percent of their historic range and are still absent from many places they could live again, including the Adirondacks, southern Rocky Mountains, Dakotas and much of the West Coast.
  • Can wolves survive if they’re delisted? Um…no.
    • Wolves are not recovered in key parts of their range. Without federal protection, wolves in historically occupied areas like the southern Rockies and Northeast may never be able to establish viable populations despite suitable habitat and availability of prey. Federal protections are still essential, just as the bald eagle was allowed to expand before its federal protections were removed. The federal government manages about 55% of the land in the state, including 9.5 million acres of roadless areas, and the state hosts an estimated 300,000 elk or 30% of the nation’s total elk population. According to Wolf Biologist Dr. L. D. Mech, “Re-establishing wolves in western Colorado could connect the entire North American wolf population from Minnesota, Wisconsin, and Michigan through Canada and Alaska, down the Rocky Mountains into Mexico. It would be difficult to overestimate the biological and conservation value of this achievement.”
    • USFWS’s proposal to remove federal protections is premature, puts wolves at serious risk of never achieving natural recovery, and signals a disappointing shift in its commitment to endangered species recovery.
    • In Idaho, Montana, and Wyoming, where wolves have already lost federal protections, trophy hunters, trappers, and others have killed more than 3,500 wolves just since 2011.
  • Why are wolves necessary to a healthy ecosystem?
    • Wolves, like other predators, regulate prey animals numbers and behavior, keeping them from overpopulating and damaging their environment. This allows other species of animals and plants to compete, expanding biodiversity.
    • Scientists are just now beginning to understand the critical role predators like wolves play in maintaining healthy ecosystems.
    • Wolves help slow the spread and prevalence of deadly diseases, including Chronic Wasting Disease, an ultra-lethal degenerative neurological illness now invading wildlife-rich ecosystems across the American landscape.
    • Wolves generally kill prey that are the most vulnerable, such as weak, sick, old, or young animals. By killing sick prey individuals, wolves remove infectious agents from the environment, reducing transmission to other prey. The scientific community argues that in this manner, wolves help reduce the spread of Chronic Wasting Disease.
  • How do wolves contribute to a healthy economic system?
    • Local economies and small businesses are supported by tourists who flock to wolf habitats for a glimpse of wolves or to hear their multi-pitched songs. A 2006 study of Idaho, Montana and Wyoming found that wolf presence in the Yellowstone ecosystem created a $35.5 million annual revenue stream. The FWS found that wildlife watchers outspent hunters in 2016 by a ratio of nearly 3 to 1. While wildlife watching expenditures increased 28% between 2011 and 2016 to a whopping $76 billion, total expenditures by hunters fell 30% to $26 billion.
Read the description below the video on how the people participating in the project used local transportation, hotel accommodations, grocery stores, gift shops, outdoor equipment rental shops, restaurants, etc. and we spend their money thoughtfully to show their support for businesses that rely on “healthy” wolf populations.
  • Why to farmers and ranchers want to kill wolves?
    • Wolves prey on cattle as they do on every other ungulate in North America, but overall are only responsible for 0.02% of livestock losses.
    • Government data shows that nine times more cattle and sheep die from health problems, weather, theft and other issues than from all carnivores combined, including wolves, coyotes, domestic dogs and cougars.
    • Cattle ranchers want to continue to use lazy unmonitored management of their herds on our land, which puts them into wolf territory AND allows them to destroy native grasses and foul waterways.. (See “Background” below.)
  • Why should farmers and ranchers re-think wolves?
    • Wolves help their herds healthy by  discouraging deer, elk and moose from staying too long in the grasslands, which prevents diseases (such as brucellosis) from potentially spreading from wildlife to cattle.
    • Wolves prefer smaller prey like prairie dogs to more dangerous prey like cattle. Keeping these animals in check helps prevent the holes that are dangerous to cattle..
    • Wolves keep other predators, like fast-reproducing coyotes, at bay.
    • Wildlife-friendly conservation strategies require a new mindset but it’s already being done successfully. Consumers can help them get to that point by buying beef that is certified “wildlife friendly”. (See “Background” below)
  • What started the war on wolves?  In 1915, Congress, hoping to increase beef production for World War I, allocated $125,000 to exterminate wolves, starting in Nevada. More in “Background” below.

Scientific articles to support talking points

  • From and here.
  • From Center for Biological Diversity here and here
  • Aspen recruitment in the Yellowstone region linked to reduced herbivory after large carnivore restoration: This study provides evidence of widespread changes in plant communities resulting from large carnivore restoration, extending outside a protected national park to areas with hunting, livestock grazing, and other human activities.
  • Wolf Hunting and the Ethics of Predator Control: John Vucetich and Michael P. Nelson apply “argument analysis”, a basic tool of scholarly ethics, to the controversial concern about the appropriateness of hunting wolves. Advocates of wolf hunting offer a variety of reasons that it is appropriate. Vucetich and Nelson inspect the quality of these reasons using the principles of argument analysis. Their application of this technique indicates that wolf hunting in the coterminous United States is inappropriate.
  • Effects of Wolf Mortality on Livestock Depredations: Concludes that increased wolf mortality leads to an increase in livestock depredation.
  • Modeling the relationship between wolf control and cattle depredation: “The parameter estimate for wolves killed is significant and positive (0.119), indicating that as more wolves are removed, the number of cattle depredated increases, much as Wielgus and Peebles indicated.”
  • Ecological and economic benefits to cattle rangelands of restoring an apex predator: This study analyzes dingoes’ ecological and economic impact on cattle operations in Australia: “Our simulations demonstrate that trophic cascades initiated by dingoes killing native herbivores are expected to be strong enough to improve the biomass of native pastures and, as a consequence, the gross margins of cattle enterprises. These results not only challenge the conventional perception of dingoes as an economically damaging pest species that must be controlled, they also contribute quantitative estimates of the expected ecological and financial benefits of this apex predator.”
  • Co-Adaptation Is Key to Coexisting with Large Carnivores: “A variety of measures exist to reduce the impacts on humans of having large carnivores in shared landscapes, ranging from economic compensation and incentives, information campaigns, spatial zoning (e.g., habitat protection from human development), technical changes to livestock husbandry, the restoration of wild prey populations, and allowing limited hunting of large carnivores, among others. … However, during humanity’s long history of interacting with carnivores, we have also learned to adapt to carnivore presence, minimizing the need to reduce their population sizes.”
  • EVALUATION OF A TEST AND CULL STRATEGY FOR REDUCING PREVALENCE OF CHRONIC WASTING DISEASE IN MULE DEER (ODOCOILEUS HEMIONUS): Re targeted culling of CWD-infected deer and concludes: “Although we detected some infected individuals well before clinical signs would have been discernible to a predator, at the herd level our testing effort likely was not as persistent or effective as that of natural predators. Our findings could lend credence to the potential role of predation−of sufficiently high intensity and duration−in helping suppress CWD outbreaks if CWD-positive individuals are preferentially targeted by predators.”
  • Mountain lions prey selectively on prion-infected mule deer: This study finds evidence thatpredators target animals infected with CWD, and suggest that predators may limit prion transmission/contamination at kill sites. “Adult mule deer killed by mountain lions were more likely to be prion-infected than were deer killed more randomly in sympatric populations, suggesting that mountain lions were selecting for infected individuals when they targeted adult deer … Other studies indicate that coursing predators like wolves (Canis lupus) and coyotes (C. latrans) select prey disproportionately if they appear impaired by malnutrition, age or disease.
  • A Model Analysis of Effects of Wolf Predation on Prevalence of Chronic Wasting Disease in Elk Populations of Rocky Mountain National Park: Study results suggest that predation by wolves could have potent effects on disease prevalence under certain conditions. Although non- selective predation, as might occur with culling, for example, may also be effective in eradicating the disease in a closed population, our results suggest that natural predation could substantially reduce the time required to eliminate the disease.

Background – Your tax dollars are being used to make wolves extinct. at the behest of farmers and ranchers.

The USDA Wildlife Services spends over $100 million a year to exterminate over 2.3 million native and wild animals a year at the request of ranchers who bring us “cheap” hamburgers. Their targets are usually predators like wolves, coyotes, bobcats, bears, and mountains lions, but the collateral damage includes thousands of non-target animals and birds, including endangered species and household pets, who are trapped or poisoned by mistake. Even people have been injured when they’ve accidently triggered spring-loaded M-44 cyanide cartridges meant to kill coyotes.

A growing body of research has found the agency’s war to protect livestock against predators is altering ecosystems in ways that diminish biodiversity, degrade habitat and invite disease. The public’s attitude towards wild animals has also evolved. “People want to see bears. They want to see wolves. They want to see mountain lions. It’s part of the natural heritage of the United States. We should be stewards of the system, not wiping out species and damaging ecosystems.” – Michael Mares, president of the American Society of Mammalogists.

How did all this start? In 1915, Congress, hoping to increase beef production for World War I, allocated $125,000 to exterminate wolves, starting in Nevada. The “Branch of Predator and Rodent Control” officially began under the Animal Damage Control Act of 1931, which gave the new agency broad authority and limited oversight. Federal trappers dropped strychnine out of airplanes, shot eagles from helicopters, laced carcasses of dead animals with Compound 1080, a poison notorious for killing non-target species, and slaughtered coyotes, wolves, mountain lions and grizzly bears across the West. Over the decades, it has been responsible for killing millions of predators, helping to wipe out gray wolves and grizzly bears in the lower 48 states. The agency was renamed “Wildlife Services” in 1997. Really.

Have we tried to stop this? Periodically, efforts have been made to reign in the agency’s worst excesses. In 1964, a panel of scientists wrote that “The program of animal control has become an end in itself and no longer is a balanced component of an overall scheme of wildlife husbandry and management.” In 1971, President Nixon signed an executive order banning poison for predator control. President Ford later amended the order to allow the continued use of sodium cyanide. In 1999, the American Society of Mammalogists passed a resolution calling on the agency, “to cease indiscriminate, pre-emptive lethal control programs on federal, state and private lands.” “The irony is state governments and the federal government are spending millions of dollars to preserve species and then (you have) Wildlife Services out there killing the same animals,” said Michael Mares, president of the American Society of Mammalogists. “It boggles the mind.

Why are we still funding this? Despite modern data on the positive effects predators have on ecosystems and better and more effective non-lethal predator management, the agency continues funding only lethal control methods. Generations of ranchers have been trained to expect that the federal government will destroy predators on request as well as troublesome creatures like prairie dogs, who compete with cows for vegetation and/or create dangerous holes. (Ironically, these smaller creatures are the preferred prey of coyotes.) “It’s deeply ensconced in the culture,” says Camilla Fox of Project Coyote, a national organization that advocates for conservation and predator-friendly agriculture. “If people knew how many animals are being killed at taxpayer expense – often on public lands – they would be shocked and horrified.” “The livestock industry is the last wildlife-genocide program in the United States,” says Bruce Apple, the director of an Oregon-based environmental organization appropriately called Rest the West. “All-out war is declared on a diversity of species every day to benefit a single industry.”

The “Cheap Burger” costs start here: Ranchers who use Wildlife Services often also use what one rancher called the “Columbus” method – releasing unsupervised prey animals in the spring onto federal grazing allotments that contain predators, and then “discovering” their herds in the fall. This “hands-off’ management makes complete decimation of predators more attractive and leads to devastation of the public’s rangeland. Cattle and sheep displace native grazers, while causing severe soil erosion, desertification, dispersion of noxious weeds, and damage to streams, watersheds and riparian areas. (Atlantic) “Cattle aren’t native to this country—they come from Europe, where a wetter, greener, and more resilient landscape than that prevailing in the West accustomed them to a sedentary grazing style, earning them the nickname “vacuum feeders. …Heavily domesticated, safe from predators owing to the government’s killing program, the American beef cow behaves like a spoiled houseguest, frequently hanging out along rangeland stream banks all day long. The West’s native grazers—primarily elk, deer, antelope, and bighorn sheep—eat in a roving, less intensive manner.

The fees are peanuts: In 2019, grazing fees for federal land were lowered to the legal minimum of $1.35, (the same price paid in 1985), for (1) cow and a calf, or (5) sheep, far below the $21.60/month average charged by private land. Some of the wealthiest people in America are taking advantage of these bargain sale prices, including the Mormon Church and tycoons like William Hewlett and David Packard, the Koch brothers and Bruce McCaw.  Each of these billionaires hold huge amounts of grazing permits, and benefit from an annual estimated one billion dollars in taxpayer subsidies, while causing long-term damage to one of the public’s most treasured assets. (Koch on free markets “...if you get the benefits, but you’ve socialized the cost, get other people to bear the cost, then you get unproductive behavior, and the system breaks down.”). The 2012 Interior Economic Report admits that the absurdly low grazing ratescreates an incentive to use federal forage before using other forage sources and perhaps to use federal grazing allotments more intensively than privately owned rangeland.

The game is rigged: Struggling ranchers and welfare cowboys alike promote the myth that predators kill lots of cattle (actually less than 1%), and if an animal goes missing or is killed, they demand that our government step in with lethal means to protect their “product”. We taxpayers also compensate them directly for predator losses, which encourages report inflation – where a dead or missing animal is attributed to animal predators without proof. USDA data show that nine times more cattle and sheep die from illnesses, birthing problems, weather, poisoning, and theft (4,003,847), than from all predators combined (461,159).

The Best Solution!: The best solution is stop killing predators and get livestock, one of the biggest contributors to global climate change, native species extinction and the overuse of antibiotics and pesticides, off public land. Not only is it clear that livestock grazing on public lands is out of place with modern values, the whole business doesn’t even make economic sense…

A quick moment for comparitive economics. From the 2017 Dept. of the Interior Economic Report, grazing activities supported an estimated $2.5 billion in economic output and about 41,000 jobs. The Bureau of Land Managemeng (BLM) and Forest Service (FS) typically spend more managing their grazing programs than they collect in grazing fees$79.0 million was appropriated to BLM for rangeland management in FY2017, and collected $18.3 million in grazing fees. In contrast, recreation and tourism at Interior sites supported an estimated $29.0 billion in value added, $51.6 billion in economic output, and about 418,000 jobs. And it’s not like you can have both without compromise. “livestock grazing greatly reduces the value of a landscape for recreation.  With polluted water, degraded wildlife habitat, hundreds of thousands of miles of barbed wire fence that tear clothes, gates that are nearly impossible to open and close, predator killing to protect livestock, aggressive guard dogs, and many other impacts, livestock grazing eliminates or detracts from the value of the landscapes that would otherwise support much more wildlife and unhindered recreation.

Second best: A partial solution is to demand higher fees for environmental restoration work and require ranchers to maintain the safety of their herds with non-lethal “predator management” strategies, keep the numbers of herd animals allowed per acre to a sustainable number, require daily interaction and management of herds to protect the range, move cattle before the land’s limit is reached and “retire” land from grazing allotments before damage reaches irreparable limits.

Some positive signs:

  • In 2018, Wildlife Services lost a lawsuit in Idaho brought by Western Watersheds Project, Wild Earth Guardians, Center for Biological Diversity, and Predator Defense against Wildlife Services. “Wildlife Services will now have to fairly evaluate how killing thousands of coyotes in southern Idaho each year affects the environment,” Talasi Brooks, a staff attorney for Advocates for the West. Audit records from 2013 have revealed violation of state and federal laws as well as lack of transparency from Wildlife services.
  • Also in 2018, Shasta County announced that the county has suspended its contract with the notorious federal wildlife-killing program known as Wildlife Services. The program has killed more than 35,000 animals a year in the county. Other counties currently not contracting with Wildlife Services include Siskiyou, Mendicino, Sonoma and Marin Counties.
  • In 2017, a San Francisco federal court approved an agreement halting controversial methods such as aerial gunning to kill “nuisance animals” in Northern California. Reuters reported that under terms of the accord, Wildlife Services, will suspend for at least six years its practice of gunning down coyotes from helicopters and airplanes and using traps to kill creatures in wilderness areas in 16 counties in California. It bans the use of M-44 cyanide devices, den fumigants and lead ammunition. It bans any use of body-gripping traps, such as strangulation snares and steel-jaw leghold traps, in designated wilderness and wilderness study areas
  • In 2017, Travis County cut ties with Texas Wildlife Services in favor of their city’s wildlife management program, which emphasizes education over killing.

Things we should require of ranchers who want to keep using our land… 

  • Even though they don’t use it, the USDA Wildlife Services has a fact sheet on non-lethal predator management.
  • Apparently one can teach cattle to act more like their cousins, wild bison, who surround and protect their weakest members, using “predator awareness” training.
  • Keep older non-breeding mother cows instead of selling them off. They are often the most defensive members of their herds.
  • Raise smarter cows breeds that are historically better at protecting themselves.

     Ancient White Park Cattle;  Photo by Louise Johns
  • Use wildlife-friendly conservation strategies:
  • Recognize that wolves help their herds healthy by  discouraging deer, elk and moose from staying too long in the grasslands, which prevents diseases (such as brucellosis) from potentially spreading from wildlife to cattle.
  • Stop killing predators’ preferred prey, like prairie dogs.
  • Recognize that wolves tends to keep other predators, like coyotes, at bay.
  • Recognize consumer demand for food and other products from farms and ranches  that are committed to coexisting with our native predators, and people are willing to pay a higher price for them.
  • Use pasture – management techniques to protect a herd’s food supply and the land. Like this guy does

What can we do? Do we have to give up meat to save wolves and the earth?

According to a major study recently published in Nature, “On our current path, emissions from food production could surge by 87 percent by 2050, “reaching levels that are beyond the planetary boundaries that define a safe operating space for humanity. Even if we completely decarbonize the energy system, we would still really need to tackle the emissions that are associated with the food we eat.” However, in the meantime…

  • You don’t have to be a vegan to be a climate-friendly eater. If Americans cut our beef intake by 40%, as recommended by the World Health Organization, to just under six ounces a day per person, we’d be doing our part to slash global food-related emissions by nearly a third.
  • A move to a “flexitarian diet”—1.5 ounces of meat a day, or about three hamburgers-worth a week—would help the world cut these emissions by 52 percent, giving the climate a shot.
  • Buy “grass-fed” beef. Well-managed pastureland also retains topsoil remarkably well—switching from cornfields to pastureland, according to Ontario’s Ministry of Agriculture, Food and Rural Affairs, cuts soil erosion by 93 percent. A USDA study found that Great Plains pastureland stores 54 percent more CO2 per acre than cropland. Also, more than half of all corn and 98 percent of all soy grown in the United States goes to raise livestock, even though feeding this diet to cows promotes virulent strains (PDF) of E. coli and liver abscesses—which farmers treat with high doses of antibiotics, which decreases their effectiveness for us.
  • When you have a choice, buy certified “Wildlife Friendly” meat.
  • If you choose a vegetarian substitute, make sure it doesn’t involve hexane or other toxic chemicals.
  • Several European countries have weighed a meat tax. Springmann calculated that here in the United States, a 160 percent tax on processed meat like ham and salami could slash consumption by a quarter.

So, what does that burger cost?

You can read this article here, or watch this.



2 thoughts on “Sun 7/14 – Mon 7/15: We’re up to over 600,000 comments to protect the wolves!!! But there are a lot of copies…Let’s pile on some new ones. Deadline – Monday 7/15, 11:59 pm EST

  1. Wolves are are an absolutely vital and important species in the US eco system. They absolutely have a right to be protected from malicious over-hunting/culling. I demand that they be allowed to continue to be included on the “endangered species list” and that the Trump administration stop trying to KILL off wild-life for short term profit or recreation!


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