Although I earlier posted a lot of material about the USFWS proposed changes to the 10j rule on the “non-essential, experimental” population of wolves in Idaho, Wyoming, and much of Montana, a month ago, I’ve been asked to post again now that the due date approaches — August 6.
Here is the proposed new 10j rule as it was published in the Federal Register on July 6.
What do these changes mean? Fact sheet from Defenders.
What is the worst part? It is the new allowance for killing of wolves by the government for “herd management” purposes. The proposed new rule defines “herd management” in such a way that a state could kill wolves that affect ungulate herds in any manner they choose to find objectionable. It is no longer just a reduction in the herd’s size that may merit state ordered killing, it might just be that wolves have made elk more wary and so harder for the least capable hunters to find. In other words, some of the beneficial reasons why wolves were restored under 10j rule, may now be the basis for their termination — wolves just being wolves and making the elk, deer, and moose more wild, could result in an order from them to be gunned down.
Here’s what it says in the Federal Register about wolves having an unacceptable impact on “herd management goals.”
Unacceptable impact—State or tribally determined impact to a wild ungulate population or herd, with wolves as one of the major causes of the population or herd not meeting established State or Tribal population or herd management goals.
How do you comment?
Here is what it says in the Federal Register.
1. If you submit comments by e-mail, please submit them in ASCII file format and avoid the use of special characters and encryption. Please note that the e-mail
address will be closed at the termination of the public comment period [Aug. 6].
2. Email directly to the Service at WolfRuleChange@fws.gov. Include ‘‘RIN number 1018–Av39’’ in the subject line of the message.
3. You may submit your comments through the Federal e-Rulemaking portal—http://www.regulations.gov.
4. Include your real name, your address, phone number, email address.
Will your comment make a difference?
I think the USFWS is determined to do this. However, if you raise new issues, they are bound by law to consider them, and if they don’t that can be the basis for litigation (which I assume will follow this outrage).
The most important thing to do is to send a copy of your comments or just your general objections to your US Representative and both of your US Senators. They may not know this is an issue. You don’t have a due date for contacting your members of Congress. Contact them even if you live in Wyoming or Idaho.
It does no good to contact members of Congress other than your own. So if you live in Kansas, let’s say, contact your Kansas members of Congress.
Defenders of Wildlife and Natural Resources Defense Council have ready made letters to send. These are well written and you might use them as a basis, but I think it is the lazy person’s way of contacting them, and identical form letters will be heavily discounted by the USFWS.