April 1, 2023

Wolf Meeting and Talking Points Expanded Boundary

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Wolf meeting tomorrow, 8-13-14 at the TorC civic center. Public input meeting at 6 PM; information session from fish nd wildlife service at 2 PM. [This is]About the new proposed draft rule and Environmental Impact Statement the rule is based on. Please come and speak if you can. Map and short zone explanation attached. Talking points attached.

Designate three wolf management zones with a larger Zone 1 within the expanded MWEPA:
• Zone 1 is an area within the MWEPA where Mexican wolves would be allowed to occupy and where wolves may be initially released or translocated. Zone 1 would include all of the Apache and Gila National Forests (the existing BRWRA) and any or all of the Sitgreaves National Forests; the Payson, Pleasant Valley, andTonto Basin Ranger Districts of the Tonto National Forest; and the Magdalena Ranger District of the Cibola National Forest.
• Zone 2 is an area within the MWEPA where Mexican wolves would be allowed to naturally disperse into and occupy and where wolves may be translocated. In Zone 2 initial releases of wolves on Federal land would be limited to pups less than five months old. Pups less than five months old, juvenile wolves and adult wolves could also be initially released on private land under Service and state approved management agreements with private landowners and on tribal land under Service approved management agreements with tribal governments.Zone 2 would include the area of the MWEPA not included in Zone 1or 3 south of I-40 to the international border with Mexico
• Zone 3 is an area where Mexican wolves would be allowed to naturally disperse into and occupy but where neither initial releases nor translocations would occur. Zone 3 would include the area of the MWEPA not included in Zone1 or 2 south of I-40 to the international border with Mexico.

ZoningMap

Mexican wolf Draft EIS and Rule Change

Talking points for Agriculture

1. Any population change in the wolf recovery program must be based on a recovery plan that has been published in the federal register and vetted by the public . The most recent recovery plan in place meeting those requirements is the 1982 plan. None of the ongoing attempts at recent planning have been subject to peer review in accordance with 59 Fed. Reg. 34207 July 1 1994

2. Recovery planning needs a defined number of wolves to allow the public to understand clearly the objectives of the recovery of Mexican wolves in the SW.

3. Livestock on federally administered grazing allotments are private property legally occupying the range to disallow take of wolves attacking livestock is wrong. Ranchers should be allowed to defend and protect their domestic animals regardless of land ownership, without having to beg for a permit.

4. FWS isn’t using best available science or information in the DEIS. Nowhere is there a requirement that county data and reports must be peer reviewed to be used by the agency in rulemaking. Thus far FWS has cited no data to support the finding of no significant impact to livestock community by this program, nor the harm that has been documented to the human element particularly the children in areas where wolves are present.

5. FWS failed to mitigate livestock depredation and ranch sales due to wolf depredation in wolf occupied areas. nothing in their draft suggests they will do so this time.

6. FWS has failed to mitigate the impacts to children in wolf populated areas, in fact have largely ignored the habituation problem of these wolves. There is very little in the DEIS and Draft Rule that allows for mitigation of these significant problems.

7. FWS has failed to consider cumulative effect of economic losses and social impacts when this program is coupled with all the other environmental planning that is going on in our state.

8. FWS has failed to address catastrophic affects on wolf habitat.

9. Cooperative agreements with private landowners to host wolves on private land can and likely will have significant impact on neighboring ranches domestic animals and the human element on adjacent private lands, this should not be available.

10. FWS must stay within the bounds of the DEIS and draft Rule, during the last rulemaking process, David Parsons significantly changed the draft rule and EIS and there was no public vetting of his teams decision-making. This DEIS cannot be significantly altered other than to incorporate ongoing comments in the current commenting cycle. Parsons now works for an environmental organization devoted to preserving predators.

Remember, DOW CBD WEG Sierra Club and all the other environmental and animal rights organizations, will be bussing in people to speak, crowding the comment session and complicating this meeting with public grandstandings perhaps even a howl in like they did in Albuquerque last year. It got them a cover on the Albuquerque Journal. If you are up to a little public grandstanding to ensure the media gets our side of the story feel free to do so, I have protest signs and we can stage a protest ourselves if necessary.

Public comment session, stick to realistic points similar to but not limited to those above, and the injustice and unfairness behind the management of the program.

There is no, No Wolves alternative, this program is far far beyond that issue the reality is, the courts have ruled this is legitimate. Even if there was a No Wolves alternative, and it was chosen, the population explosion we have now would allow the agency to immediately re-list this animal with full ESA status critical habitat and a no take policy under the ESA and there would be wolves out here forever with NO removals for problem animals and private property curtailment due to the critical habitat status.

Within the past year our association Gila Livestock Growers Assn. has tried to fulfill some basic scientific testing that would have allowed us the basis for petitioning for de-listing of this animal along with the de-listing of the northern population, our access to historic samples fell through and our time has run out to do it before the new rule is in place. We will have to undergo the rulemaking process and try to find historic samples for testing at a later date.

At this meeting, we have to show the agency they will not and cannot get away with pretending there is no significant impact to our communities and industries whether it’s tourism, ranching or outfitting. pick a subject stay on point ignore the hecklers. Prepare for bizarre and really bad behavior from the wolf support activists.

When I was in Albuquerque last November for the preliminary meetings someone sat next to me and handed me the prayer attached here. Please print it and take it with you if you need to.

Prayer

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