Ensuring the future of elk, other wildlife, their habitat and our hunting heritage.

Tuesday, February 16, 2016

RMEF: California Wolf Plan 'Misses the Mark'

Below is a letter submitted by the Rocky Mountain Elk Foundation to the California Department of Fish and Wildlife regarding CDFW's wolf conservation plan.

February 15, 2016
Wolf Plan Comment
PO Box 26750
San Francisco, CA 94126

Dear Sirs:

Founded over 30 years ago, the Rocky Mountain Elk Foundation (RMEF) is fueled by hunters and a membership of nearly 220,000 strong. RMEF has conserved more than 6.7 million acres of quality habitat for elk and other wildlife. We also work to open and improve public access, fund and advocate for science-based resource management, and ensure the future of America’s hunting heritage.

RMEF has thoroughly reviewed the California Department of Fish and Wildlife (CDFW) Draft Conservation Plan for Gray Wolves in California Part I and Part II. RMEF has attended several meeting in the state, and staff or members have shared a number of talking points. Those are incorporated in these comments along with several other thoughts.

We appreciate efforts to compile background material for the life history of the wolf, research wolf diseases, and analyze wolf interactions with humans, domestic dogs, ungulates, and livestock in other areas of the country. This information does not exist for California, as the wolf has not been present in the state for a long period of time. However, we feel much of the plan’s analysis regarding wolves and ungulates misses the mark and does not reflect scientific research from other states or Canadian provinces. We also feel that, in some cases, important analysis was either not completed or was not reported in the plan.

The plan indicates an ideal wolf population level of nine breeding pairs. We are very curious what data interpretation was used to determine this number, and are also concerned that CDFW has very little baseline information regarding ungulate populations in areas where wolves may establish territories. Oregon has approximately 120,000 elk, and is managing for an ideal population of 11 breeding wolf pairs. California’s most recent Elk Management Plan was printed in 2010, and current hunt regulations claim 12,000 elk in the state. Of this total, 5,000 are Tule elk, and are thought to be far enough away from areas where wolves will recolonize so as to not be impacted for quite some time. That leaves only 7,000 Roosevelt and Rocky Mountain elk near areas where wolves may naturally return to the state. This is the smallest elk population to ever serve as prey species for wolves establishing territories in a western state. We have searched the literature and find no science indicating that a population of 7,000 elk can sustain nine breeding wolf pairs without a significant impact to the elk population. The plan’s Part I states, “There is concern that wolf predation has the potential to significantly impact and possibly extirpate local populations of prey.” We certainly agree with this statement, yet find no indication in either this plan or the Elk Management Plan that any assessment was done to predict what that impact might be.

We realize that California has no historical records of wolf numbers in the state or what their preferred prey species will be; however neither did Wyoming, Idaho, Montana, Washington, or Oregon. Most of those states have found that nine breeding pairs actually represent approximately 125 wolves (14 wolves per pair) when also counting the young of the year, yearlings, and two-year-old dispersers. The chart “Predicted Ungulates Killed by Wolves Per Year” (Part II, Appendix E, Page 249) reflects at most a population of 64 wolves. We believe this is only about half of what might be expected, and a more realistic number of 125 wolves for the nine breeding pairs called for would equate to approximately 3,300 elk calves, 182 cow elk, and 360 bull elk killed by wolves each year.

The plan assumes that if elk are not present in adequate numbers the wolf diet will shift to mule deer, predicting “mule deer are more abundant than elk in northeastern California and may therefore represent the majority of the wolf diet in that region.” Based on findings in the Northern Rocky Mountain gray wolf populations, this is a poor assumption. Mule deer outnumber elk in nearly every western U.S. habitat occupied by wolves, yet a switch from elk to deer as prey has not been observed. All of the western states with wolf populations have found that elk is their preferred prey species. In fact, most of those states have found that 90 percent of the wolf diet is elk. Even research on the smaller Mexican wolves in Arizona and New Mexico has shown that more than 85% of their diet is elk. The highest predation number we can find is nine percent mule deer in Montana’s Madison Valley, but most other areas found that mule deer comprised only one to four percent of wolf diet. The plan refers in several places to white-tailed deer predation by wolves, which seems unusual since there are no white-tailed deer in California.

We have followed ongoing livestock depredation by wolves in Idaho and Montana for the past 20+ years, as well as the recent livestock depredations by wolves in Oregon. When elk numbers decline to a level where they cannot support the wolf population, the wolves shift to livestock, not to mule deer. These situations lead to serious issues with the agricultural community, and often result in drastic actions against the wolf packs. We recommend managing for fewer wolves than the proposed plan calls for, thus avoiding significant decline in elk herds and the resultant negative impact on the agricultural community.

The proposed plan calls for management action to be triggered by: 25 percent or more population reduction in deer or elk herds in a three-year monitoring period; elk calf:cow ratios falling below 20:100 or deer fawn:doe ratios falling below 30:100 in a three-year monitoring period; or allocated big game tags being reduced below current levels in areas occupied by wolves. This direction gives us pause, as we have not historically seen annual CDFW monitoring taking place at levels which could detect these changes in elk and deer numbers. CDFW has put more emphasis on the wolf plan than on the prey species plans, and it is difficult to see how impact of prey species by wolves can be measured without good baseline information of elk and deer population dynamics. This section is also not clear as to the outcomes expected. It is unclear to us if the proposed management action would reduce big game tags or would reduce the wolf population to increase elk survivability. One section mentions the consideration of translocating elk into former habitat to enhance their populations. Would this action move elk to areas that were not occupied by wolves, or would elk be placed into areas where the elk population had been greatly reduced by wolves? Does the state have authority for lethal take of wolves that are significantly impacting big game populations?

While CFDW has stated that this wolf plan is not a recovery plan, RMEF would like to know what constitutes the guidelines for delisting under the State and Federal Endangered Species Acts. The desired management number is listed at nine breeding pairs, yet we find no indication of a population level that will trigger delisting of the wolf from both federal and state endangered species classifications.

There needs to be a department commitment to funding adequate population and herd composition surveys in order to gain baseline knowledge of the elk resource. Annual surveys are designed to indicate if elk herds are not performing at their expected recruitment rates, and should initiate research proposals to investigate the lack of population growth. CDFW’s apparent lack of concern for elk over many years is difficult to comprehend, especially given the fact that California is the only state with three recognized sub-species. It would seem that elk would get more recognition for the magnificent species they are!

We are very concerned about the lack of basic elk numbers due to lack of elk composition surveys, either ground or aerial. We appreciate the recent addition of two biologists to assist on the elk program in Yreka and Eureka. As these are new positions, it will take some time for the biologists to get up to speed and develop their own program measures of success.

California elk populations have not yet grown to their modest desired population objectives. The plan indicates that elk herd numbers are slightly increasing, and RMEF feels there is adequate available habitat in many parts of the state to accommodate more elk. While habitat is not currently a limiting factor for elk, the plan calls for improving habitat for prey species if their numbers show vulnerability to wolf predation. However, elk are not currently nutritionally deprived, nor will they be when wolves return to the state. It is wolf predation that will limit their population growth, not nutritional adequacy of the habitat. Fertility and fecundity rates have not been a concern for California elk in the past, nor are they mentioned as limiting factors in the plan. We question how elk populations are expected to increase once affected by wolf predation.

We believe there is a large amount of habitat that is not occupied by elk, and we question why elk herds are not expanding into these areas. The elk herds may be slowly growing, but certainly not at an exponential rate! Your records in the 2016-17 big game hunt information indicate a total statewide harvest of 135 Roosevelt/Rocky Mountain elk. This is the total elk harvest on the approximately 7,000 elk that are expected to be impacted by wolves in the near future. Based on our assumption that habitat quantity and quality are not limiting factors, annual elk herd growth should be significant in light of such limited hunter harvest. Annual population growth in most elk herds is approximately 12 to 15 percent, which should mean a herd growth of about 840 to 1,050 annually before mortalities are subtracted. Perhaps the department is missing other mortality factors currently playing out in the California elk herds. One elk mortality factor that has been unknown in many western states until recently is the predation rates of mountain lions, black bears, and coyotes. RMEF has funded elk predation research in Arizona, Colorado, Idaho, Montana, New Mexico, Oregon, South Dakota, Washington, Wisconsin, and Wyoming. Results show that in each situation the mountain lion and black bear predation rate on elk had been greatly underestimated. Now that the wolf is starting to occupy many elk ranges as a new apex predator, it is essential to understand the predation factors of each large predator and their cumulative effects on elk populations. Several research projects show that the more apex predator species impact an elk population, the greater the challenges for managing not only the elk herd, but the predator populations as well. The proposed plan addresses the notion that the impact of predators on prey populations is usually additive rather compensatory, and we agree that would be the case for elk populations in California. What considerations have been discussed on the impacts of wolf predation on the other predators present in the state? RMEF strongly recommends CDFW complete a California Environmental Quality Act (CEQA) assessment to determine the impacts of wolves on both the elk and mule deer populations. The prey base is the foundation of support for wolves and a comprehensive assessment is essential. We do not believe that this wolf plan should be approved without the results of this requested CEQA assessment.

While hunter-conservationist contributions to wildlife conservation are not always well understood by the public, it is no secret to the state wildlife agencies that are funded primarily through hunting and fishing license sales. The U.S. Fish and Wildlife Service’s most recent 2011 economic survey shows that hunters and anglers spent about $3.23 billion dollars in California, fished for 17 million recreation days, and hunted for more than 6.7 million recreation days. The upcoming 2016 survey will no doubt show an increase. In addition to the license fees and expenditures that they incur pursuing these activities, many hunters and anglers belong to conservation organizations that raise millions of dollars to help state wildlife agencies and federal land management agencies better manage habitat and wildlife species through grants, volunteer projects, and political support of their programs. RMEF has 32 very active chapters across California that raise funds for conservation work within the state. Their dedicated efforts have made California one of RMEF’s top two fundraising states for the past 10 years. To date, RMEF has funded a total of 534 California projects which have permanently protected more than 30,000 acres and enhanced more than 98,000 acres of wildlife habitat. The total value of RMEF efforts in California is more than $41.6 million, and in 2015 alone RMEF provided more than $300,000 for project funding in California.

Hunter-conservationists care about healthy habitats and all the wildlife species that they support. Wolves are coming to California, and common sense and scientific data collection for the prey species (elk and deer) and for the predator species (mountain lions, black bears, coyotes, and wolves) is absolutely essential for the agency to manage all for a balance. Predators require a healthy ungulate population, which requires that CDFW manage elk and deer for optimum numbers to meet predator needs, while also allowing a surplus of elk and deer for hunters to pursue and wildlife watchers to view. Prey animals require healthy habitat and it is incumbent upon CDFW to work with federal land managers, state land managers, and private landowners to achieve this goal. The trick is to manage habitat, prey, and predators so that all can thrive. The key is to bring about a balance with realistic plans based on the latest available science.

In summary, RMEF finds the plan a disappointment and lacking in some key areas. We also believe that the management goal of nine breeding pairs is too high and should be reduced.


M. David Allen
President & CEO


  1. rmef and its members have a long history of SSS. rmef supports canned hunting. Is rmef trying to set up canned hunting for elk and deer by getting rid of all the predators?

  2. RMEF promotes ethical hunting of wild, free-ranging elk. We have never advocated for canned or high fence hunting.

  3. Good Job David. I appreciate this effort. I would like to see an equally tough letter, with respect to the decimation of the Northern Yellowstone elk herd, Salmon Idaho, and the Lolo herds. Much of Western Washington, and Idaho's elk herds are well below recoverable levels, where bull/cow ratio's are dismal, at best, and the recruitment levels are predictably on course for extinction level events. The Northern Yellowstone elk herd is at 2.7 bulls per 100 cows, as officially reported, but I believe it is much worse.
    Thank you again, for taking a stand. It is very refreshing to see the foundation fight to stop this wolf agenda.

  4. Save Our Elk,
    We put this out in 2013:

  5. An excellent letter Mr. Allen which unfortunately falls on deaf ears in Calif. The only pro-hunter on the CA Game Commission recently resigned, being unable to work with an anti-hunting mindset. I refuse to give this state another dollar for hunting licenses and/or tags. I would hate to see any of my RMEF donations spent in Calif.