To The Point

To The Point

by Caren Cowan

How significant are YOU?

According to the U.S. Fish & Wildlife Service (FWS) Draft Environment Impact Statement (DEIS) on Mexican wolves, not at all.

Unless you have been living in a cave – and where we sit today – we may want to move into that cave with you, it is well known that the FWS has been working to expand the Mexican wolf recovery program… despite the fact that in the 16 years wolves have been being released, the Service has been unable to come up with a viable plan for these zoo raised predators. And, despite the fact that there is no recovery plan in place.

The FWS is working under a court-mandated settlement to do something – anything that looks like progress by 2015. Clearly, they will be sued again by both proponents and the people they are forcing wolves on as soon as they complete the current processes. The document is open for comment until September 23, 2014. Although requests have been submitted for an extension of the comment period for this sweeping plan, it is not expected that one will be granted. We expect the Final EIS to be published in January 2015 and implementation of the preferred alternative to begin immediately after that.

We don’t have to reach too far back to remember when there was a comment deadline one afternoon on an environmental assessment and the action was take less than 24 hours later.

You can find the entire DEIS at and I strongly encourage you to spend some time looking at this voluminous document. I will caution, however, that this is not bedtime reading unless you plan on not sleeping or at least having significant nightmares.

In case you don’t have the time to spend on the document, I am going to share what I consider to be significant pieces of the proposals with you here as well as come of the choice comments made at the hearing on the proposal held in mid-August in Truth or Consequences, New Mexico. It is reported that similar comments were made at the hearing in Pinetop, Arizona two days earlier.

It is worth explaining the setting for the hearing. In a first for any government hearing, we were greeted at the door by five (5) uniformed police officers who wanded every person for weapons every time they entered the building. Once you walked into the building, there were two (2) sign-in tables. As you signed in, you were told that commenters would be selected via a lottery and only two (2) minutes would be allowed for comments. We learned later that part of the two minutes was to be used for self-introduction including the spelling of your name.

After sign-in you were stamped on the inside of your left wrist with an illegible stamp. We still haven’t figured out the purpose of the stamp. It washed off easily… unless there was invisible ink contained as well? Just kidding!

There was a two-hour question and answer period, followed by a two-hour break and then a three-hour hearing where verbal comments were put into the record. There was no interaction between the FWS and the commenters. There was a hearing officer who ran the hearing portion.

The pro-wolf folks were well organized as usual, but they were unable to turn out the number in T or C that they have in past gatherings in Albuquerque. Although there was promise of buses to haul people to the hearing, it didn’t appear that any were needed. At one point the cowboys may have outnumbered the wolfers, but that wasn’t reflected in the people who commented.

Names for testimony were called out in groups of 10. Ranching families and their supporters called ranged from two to four out of every 10. Unfortunately many of ranchers became frustrated with the hearing early in the process and went home before their names were called.

There are four (4) proposed alternatives ranging from the “preferred alternative” to the “no action” alternative. If we have to pick an alternative, Alternative 1, the preferred alternative, would appear to hold the most promise because of the management abilities suggested. Unfortunately we have 16 years of broken promises and outright lies from the FWS to outweigh the potential good of that alternative.

Additionally there is virtually no prey base to support the wolves in the expansion zones created by Alternative 1. In 1998 we were told that the wolves would life mostly off deer and some elk. That was questioned at the time and what the expectations of those who live on the land have occurred. There hasn’t been enough deer for the predators to live on so there has been much more livestock, pets and elk eaten alive to support the wolves. As the program expands to everything south of I-40, there are almost no elk for prey so the wolf diet cannot help but be made up by livestock and pets, or worse.

We are often tricked into the lesser of the evils with these sorts of proposals – and at the ballot box. We must be cautious not to be enticed by false promises or to acquiesce the lesser of the evils in this wolf proposal and think hard about who supports us on this an other issues as we head to the ballot box in October and November.

The no action alternative would leave things as they are, which is intolerable for the people who are now forced to live with animals who have little choice but to kill livestock and pets to survive.

It is worth noting that many other alternatives were proposed during the process, including one from the Arizona Game & Fish Department, the Arizona Cattle Growers’ Association and others in Arizona and another by the Arizona/New Mexico Coalition of Counties as well as others. None of these alternatives were even considered by the FWS.

About that significance…

Here is just one place that your insignificance is pointed out in the DEIS. Please note that the xx areas are blanks left by the FWS apparently because they haven’t finished that portion of the document… guess those numbers are not significant to us insignificant people. Not only do the xx not reflect what is really happening on the ground, but there is no mention of the value of the at least xx,xxx and is taking $xxx,xxx out of ranching families’ pockets annually at today’s cattle prices.



We expect implementation of the proposed action and alternatives to achieve a larger and more widely distributed experimental population of Mexican wolves which will result in the depredation of more cattle in a larger area than would occur under the No Action alternative. xx cattle per 100 wolves are projected to be lost annually due to wolf depredation. Should the experimental population reach approximately 300 wolves at the end of 12 years as projected in Appendix F a loss of approximately xx cattle due to depredation in proposed Management Zones 1 and 2 could occur. Short-term losses of livestock are expected to be variable between years and between areas and could therefore have a disproportionate impact on an individual rancher/livestock producer. In the short term, an individual rancher/livestock producer could sustain a substantial loss of livestock in a given year. The continuation of an existing compensation program will help reduce monetary losses of individual livestock operators and no significant long-term effects on overall livestock production in the project study area is expected.

As we testified at the hearing, calves are worth $1,000 to $1,200 a head today, while cows are worth toward $3,000 a head. Take that out of your wallet 10 or 12 times or more a year and just see how insignificant that is. Unfortunately that means little to folks who are being paid by your tax dollars and who have insurance and retirement paid for by you as well. There are no consequences to them or their children if they make mistakes in these processes. We pay for those mistakes too.

It must be noted that the next section of the DEIS states:

Approximately 118 cattle per 100 wolves are projected to be lost annually due to wolf depredation. Should the experimental population reach approximately 300 wolves in the project study area at the end of 12 years as projected in Appendix F a loss of approximately 337 cattle due to depredation could be expected. This is a small percentage of the total number of cattle (nearly 2 million) in the project study area.

These numbers defy logic.  We are told that there are 83 known wolves in the “wild” now. Those living on the ground believe that number is much larger. We were told at the hearing that there is a record number of pups this year… although they won’t count unless they are part of a pack (including a male and a female) at the end of the year.

Let’s just take the 83 wolves… that’s 83 percent of the 100 used in the statement. That 83 percent of 118 equals 98 head of livestock just this year. While we believe the number of losses is higher, let’s just go with the FWS number. The statement contemplates that over they next 12  years the number of wolves will only triple to 300. Biologists tell us that wolf numbers will increase exponentially from here on in so 300 is certainly a disputable number.

The FWS says that over 12 years the loss of cattle will be 337. I don’t know how they get to that number. If you take the 98 head that are projected to be killed with the wolves that are out there now and multiply that by 12 you get 1,176 head. I am not mathematician enough to figure out the expanding number year by year in the FWS projection over 12 years, but their 337 head number just don’t make sense or reflect reality.

Just taking one year at 300 wolves and multiplying the 98 head one time comes out to 29,400 head of cattle (and I used a calculator). That may remain an insignificant number when they are using a two million head number for the southern portions of Arizona and New Mexico. But if we are just pulling numbers out of the air, let’s take that 29,400 for 12 years and we get 352,800 head of cattle.

We are told that cattle are only eight to 17 percent of the wolf diet. Let’s have a look at wildlife impacts. The DEIS says:

Wild ungulates are the primary prey species utilized by Mexican wolves and elk makes up approximately 77 to 80 percent of their diet. Less than significant impact to wild prey populations, specifically elk populations is expected from implementation of the proposed action and alternatives. However, elk are abundant in the project study area and are considered to be widespread, abundant, and secure at the global, national, and statewide levels, according the U.S. Forest Service.

Please note that the game management agencies in Arizona and/or New Mexico are not cited. And does this not beg the question why we are not looking at wolf populations at the global and national levels in this process?

There was a  choice statement that further pointed out the insignificance of the people of Arizona and New Mexico. It said something to the affect that no populations of concern would  be impacted by the DEIS. Clearly, young families, the elderly, Hispanics or Indians are not of concern.

The state of Texas appears to be out of the woods if you read the DEIS. It says that the small portion of Texas that was in the 1998 Final EIS is being taken out. What that really means that a much larger (but insignificant) portion of Texas is now in harms way. Any wolf that crosses into Texas from New Mexico or Mexico will be fully endangered. That means that there are NO management alternatives that can be applied. Wolves are free to prey on anything and everything they want.

Finally, in Alternative 1 there is a section that allows private property owners to release wolves on their property with the proper oversight. A request to allow wolves to be released on the Vermejo has been turned down under the current rules. The new proposal will clear the way for that.

I am out of space and have only looked at two pages of the DEIS in depth. The wolf advocates are not happy with the document either. Their standard message was that Alternative 3 was the only viable alternative… and that needed expansion into the northern Arizona and the Grand Canyon. As they commented at the hearing, they each did their own rancher bashing after the standard points.

There were two folks from Valencia County who simply cannot wait to have wolves among their chickens, goats and horses. Let’s just start with those folks first with releases.


Submit comments on the draft proposal before September 23, 2014. Canned comments will not get the job done. YOU need to tell your personal story about how wolves will impact you and your family.

Submit your comments electronically here:!documentDetail;D=FWS-R2-ES-2013-0056-6056

Or by U.S. mail or hand delivery to:

Public Comments Processing,
Attn: FWS–R2–ES–2013–0056;
Division of Policy & Directives Management;
U.S. Fish & Wildlife Service 
Headquarters, MS: BPHC, 5275
Leesburg Pike, Falls Church, VA 22041–3803.

Additional points you may want to include:


  • You want USFWS to eliminate the Mexican Wolf Recovery Effort due to Genetic Impurities and the continued existence of native wild un-hybridized wolves in Mexico.
  • The DEIS has not complied with all applicable federal laws and regulations including but not limited to Environmental Justice and Small Business Administration and more.
  • The DEIS is flawed and must be


supplemented with all of the appropriate