April 8, 2010
Director, Rocky Mountain Region
Defenders of Wildlife
303 W Mendenhall
Bozeman, MT 59715
Western Wildlife Conservancy
68 Main Street
Salt Lake City, UT 84101
Dear Mr. Leahy & Mr. Robinson:
I am in receipt of your letter of March 30, 2010. I will address your points factually and straightforward.
We would be happy to meet with you to discuss conservation issues and the destruction of specific herds of
elk in North America. We believe; however, that your organizations and others are contributing greatly to
perhaps one of the worst wildlife management disasters since the destruction of bison herds in the 19
century. Until the lawsuit relative to re-listing the wolves is settled or until you withdraw your support for
such, there really isn’t much need to meet as we continue to be at opposite ends of this issue.
Once again, I will state that elk are not flourishing where wolves are present. Contrary to what you have
suggested many times to claim otherwise is disingenuous and “cherry picking” data. Elk populations are
being exploited at a high rate by predators, primarily wolves and somewhat by grizzly bears. However,
since the introduction of the Canadian gray wolf into Yellowstone this exploitation has become worse for
elk numbers in the same areas. Yet, you would have the public believe otherwise.
The numbers and facts do not lie and they are as follows:
The Northern Yellowstone herd, trend count has dropped from nearly 19,000 elk in 1995 before
the introduction of the Canadian gray wolf to just over 6,000 elk in 2008. At the same time wolf
numbers in this same area are on a steady increase. Nowhere can I find where a 60% reduction of
this herd was a goal of the wolf introduction.
(Source: 2009 Wolf-Ungulate Study Montana Fish, Wildlife & Parks)
The Moose population in Yellowstone National Park trend count shows a decrease to almost zero.
(Source: 2009 Wolf-Ungulate Study Montana Fish, Wildlife & Parks)
The Gallatin Canyon elk herd trend count between Bozeman and Big Sky has dropped from
around 1,048 to 338 in 2008.
(Source: Montana Fish, Wildlife & Parks)
The Madison Firehole elk herd trend count has dropped from 700 to 108 in 2008.
(Source: Montana Fish, Wildlife & Parks)
The calf survival rate for those same elk herds mentioned above, where wolves (and bears) are
present, is extremely low amounting to as little as 10% or less recruitment or survival rate. Nearly
any wildlife professional will tell you this is an unacceptable recruitment or survival rate.
Acceptable wildlife science tells us that a 25-40% survival rate is necessary for herd sustainability.
Further, a recent MSU study shows those elk that remain in the Northern Yellowstone herd are in
below standard health as they are not feeding where and how they normally do and the females are
not getting pregnant as they should, due to hormonal imbalances. How and why did this behavior
(See Montana State University Study by Professor Scott Creel in July 2009; funded by the
National Science Foundation)
Wolf numbers have far exceeded what sportsmen, ranchers, wildlife conservationists and the
public at-large were told was a desirable goal. Specifically, 30 breeding pairs and 300 total wolves
was the goal line when wolves were released in 1995. The minimum number of wolves is now
over 1,700 according to Montana Fish, Wildlife & Parks and a number of animal rights groups
such as yours believe those numbers should be 2,000 to 5,000.
This is the most disingenuous and deceiving issue relative to the entire Canadian gray wolf
introduction and your groups and others perpetuate this every chance you get. We call it, “keep
moving the goal line” politics. It is doubtful even you believe that 2,000-5,000 wolves in this area
is sustainable. However, this allows you to keep saying “We haven’t reached the goal line yet”. It
is sad wildlife management has to come such political posturing.
Wolf population goals established at the introduction in 1995 have been surpassed by some 300-
500%. Yet groups like yours continue to move the goal line and yes, continue to cherry pick your
facts to push an agenda.
Studies show that each wolf kills up to 23 elk from November through April; that equates to up to
40,000 elk killed in six months. This number does not include those elk killed for food by wolves
from May through October. While the number of elk killed per wolf from May through October is
less than the number from November through April, it is still considerable; and that is just the elk
killed for food. These numbers do not account for those elk simply killed by wolves (surplus
killing) and yes, that does happen. Nowhere near the majority of these elk kills are simply the sick
and the old.
The habitat loss that you cite in your letter is yet another critical reason why wolves must be
properly managed and managed now. As elk ranges shrink and are encroached upon, the elk have
less chance for survival in areas where wolves are concentrated. Elk become trapped with less
habitat available. Your organization talks about elk and wolves coexisting on the same terms as if
it were the Old West again. It clearly is not and that is why man must manage wildlife as we have
for over a century.
Canadian gray wolves introduced in Yellowstone in 1995, simply are not endangered, it is quite
the opposite. There are thousands of these wolves in North America. Remember this reintroduction
was classified as an experimental, non-essential re-introduction in the first place.
Your groups would have today’s public believe that it is essential. These wolves are not
You contradict yourself as you point out in your letter how there is a “legitimate federal role in
ensuring states manage wildlife in the best interests of all Americans…”, yet you circumvent and
disagree with the federal opinion (USFWS) that the wolves are recovered. Further, you disagree
that these wolves should not be listed as endangered and be managed by the states at this time.
You can’t have it both ways but you continue to try as long as you can get away with it. Do the
federal authorities know what they are talking about or not?
It is likely that your groups have reaped large donations from your campaign to keep wolves on
the endangered species list. This is a common tactic for animal rights groups. It is apparent that if
the entire wolf controversy went away it would represent a considerable revenue loss for you.
I don’t see what your costs are relative to the wolf recovery program as it is likely you are getting
federal funds to pay some or all of your legal fees under the Judgment Fund or EAJA funds. Could
you confirm for us and the public at large if you are receiving such federal funds (taxpayer funds)
to offset your legal fees? Frankly, I don’t believe most of the public know about or understand the
Judgment Fund or EAJA but they should. It sheds light on potential motives and tactics.
Idaho’s elk numbers in units where wolves exist are far worse, with two units showing over 80% decline
since wolves were introduced. If wildlife conservation was your true agenda you would not stand for such
losses of any species. The facts are there – the numbers do not lie! Our elk herds cannot be sustained if
wolf numbers continue to expand without proper management. What is happening now is not sound
management, it is simply an assault. Re-listing wolves will worsen the issue dramatically.
Your letter states, “(Defenders) position is not one of opposition to sustainable hunting practices or to the
important role that hunting plays in conservation. Responsible hunters are some of the most knowledgeable
wildlife conservationists and we seek and find common ground with them regularly. It is unfortunate we
have not been able to do so with RMEF recently but would like to work together in the future.” You have
never sought common ground with us once that I recall.
Let’s consider those words a moment. We do not believe that your organizations subscribe to hunting as a
viable conservation tool; in fact we believe you and other animal rights groups have an overriding agenda
to decrease hunting until there is none. If you truly want to “work together” as your letter suggests, then
you will step forward and show a sincere willingness to manage wildlife as they should be managed and
not continue to promote a hidden agenda or continue to move the goal line. In fact, I invite you to come to
my office and let’s resolve this issue for the sake of those responsible hunters and those responsible
non-hunters you reference. Enough of the legal maneuvering and posturing, let’s resolve this now.
Plain and simple, wolves are predators, nothing more and nothing less. They need to be managed like other
predators by the folks who manage the rest of our wildlife, the state wildlife agencies. This wolf amnesty
program is poor wildlife management. The American sportsmen deserve better respect for all they have
contributed to wildlife while groups like yours play games with the system.
Your letter states you have called for a scientific review of the wolf recovery program. Who are your
scientists conducting the review? We have never heard of this scientific review? We can find no
announcement of such nor can we confirm it. Why isn’t the wildlife science of three of the leading western
states (Wyoming, Montana and Idaho) and the USFWS credible? Is it that you are not getting the answers
you are looking for? If so, that is not subscribing to science that is manipulating it to get a desired answer.
We live within the rules and game management policies of all the state agencies and when we haveRocky Mountain Elk Foundation
differences of opinion we go to them and work it out like adults. The United States has the best system of
wildlife management in the world, yet you reject the system of states managing their wildlife. Among your
tactics are filing lawsuits to stall and extend the process and then point fingers at others like RMEF and say
we are polarizing the conflict! Managing wildlife in court is a recipe for disaster.
Again, you seem to contradict yourselves in your letter; on one hand you trumpet the success of the overall
elk populations in these three states (which are managed by those states, I might add); and on the other
hand you reject those same three states’ ability to manage wolves. That is a curious contradiction. Either
these states know what they are doing or they don’t.
No one is promoting an annihilation of wolves, so let’s stop pretending such exists. However, there is a
great need for sensible balance and the current wolf numbers have long since crossed over the tipping
point. If your organizations do not begin to subscribe to sound wildlife management soon, this disaster will
lay squarely on your hands for history and the public to judge. Feel free to use the date enclosed in this
letter when talking to media and legislatures in the future. As I said at the beginning, the numbers and the
facts do not lie.
M. David Allen
President & CEO