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WSU Administration vs. WSU Expert on the Killing of the Profanity Peak Wolves

posted Sep 2, 2016, 11:34 AM by Scott Slocum   [ updated Sep 2, 2016, 11:48 AM ]


To: Washington State University administration.
Contact: Robert Strenge, WSU News, 509-335-3583, rstrenge@wsu.edu

Re: WSU press release: 
WSU News headline.

This overly-harsh and under-informative press release takes a side in an emotional battle, rather than attempting to bring forward a reasonable dialogue.

The "facts of the case" are not the simple findings that the WSU administration seems to want them to be; rather, they're complex interpretations of human interactions with the natural world and the political environment.

"This livestock operator elected to put his livestock directly on top of their den site; we have pictures of cows swamping it, I just want people to know." 
And the reaction of the WSU administration:

"In actuality, the livestock were released at low elevation on the east side of the Kettle Crest more than 4 miles from the den site and were dispersed throughout the allotments based on instructions found in the Annual Operating Instructions (AOI)."

In this exchange of statements, professor Wielgus exaggerated for rhetorical effect, using the phrase "directly on top of their den site." Readers took that as a metaphor, that the operator had neglected to put reasonable space between the livestock and the hunting territory of the predators at a critical point in the predators' annual cycle. That action by the operator was either foolishly, biologically inadvisable, or intentionally, politically provocative, or both. A wildlife expert with years of experience and accumulated frustration with this type of behavior by livestock operators might well be expected to express some of that frustration in a phrase that's more immediately understood by his readers: "directly on top of their den site."

For its part, the WSU administration failed to understand the biological thresholds that were crossed in this case. A distance of four miles between a Gray Wolf den site and the introduction point of a herd of cattle does not necessarily constitute a barrier between the wolves and the cattle. Duh. If the Annual Operating Instructions (AOI) don't cover such a case, then they're in need of improvement.

Likewise, the exchange of statements of what the livestock operator has and has not done, in the past and in this case, failed to engage with one another or with the complexities of this situation. 

I'm very disappointed by this heavy-handed and counterproductive lack of effort (and in its place, a reliance on empty "authority") by the WSU administration. Professor Wielgus does good and important work that reflects well on WSU and the State of Washington. In this case, the opposite cannot be said to be true.

"Fur-Ever Wild" exhibits--and the fur farm just behind them

posted Dec 22, 2015, 2:06 PM by Scott Slocum   [ updated Jan 7, 2016, 7:05 PM ]

One of Minnesota's many fur farms, Fur-Ever Wild, has been in the headlines recently. It's not a quiet operation. It offers tours of caged wildlife; lessons for Boy Scouts and other interested parties on trapping, skinning, and fur production; "education" for the urban public on how farm animals and captive wildlife are kept and processed; fur and taxidermy sales; hog, goat, and horse meat production; horse and dog boarding; and feed sales.

Blogs and Articles.

An index of some of the articles and documents about Fur-Ever Wild is available on the Petition site "Stop fur farm from exploiting and killing Endangered Gray Wolves for Their Fur" (Kosel 2015), including a 2012 court deposition in which the various legal entities associated with Fur-Ever Wild and their operations are described in detail (Petter 2012).

Another general introduction is available in a personal narrative of a tour of the wild-animal exhibit (Welcome to MN 2015), including links to legal documents (USDA APHIS 2012, HSUS 2013) and other articles.

Many blogs and short articles have been written about Fur-Ever Wild. Basic complaints center on the inadequate space the operation provides for its captive wild animals, inadequate sanitation, and inadequate barriers between people and wildlife. Further complaints include the illegal keeping of species (i.e. Gray Wolf and Canada Lynx) that are listed under the U.S. Endangered Species Act (ESA), the public exhibition of young animals that are later privately killed for their fur, and the solicitation of funds for the public exhibitions without reference to the private operations.

The Fur Industry.

Several good reviews, analyses, and FAQs of the fur industry are available online (Born Free USA 2009, Change for Animals Foundation 2012).


A couple of the common misconceptions in these blogs and articles is that 1) Fur-Ever Wild kills every animal for its fur, and 2) Fur-Ever Wild has ever claimed that it doesn't kill any animal for its fur (i.e. that it only sells the fur after the animal's natural death).

To the contrary, the actual arrangements seem to be that 1) certain, popular and photogenic wild animals are kept for exhibition until their natural deaths (at which time, they're skinned for their fur) and 2) other wild animals (which might or might not have previously appeared on exhibit) are routinely bred, raised, and killed for their fur (and, presumably, their meat).

Why clarify the misconceptions? To get to the actionable issues, and take action on them.

Actionable issues.

What are the "actionable issues?" Two of them seem to be 1) The confinement of wild animal species listed under the U.S. Endangered Species Act (ESA), and 2) the confinement of "Protected Wild Animals" that are normally protected as "Game" animals.

And the flip side of that question: which issues don't seem to be actionable? Those seem to include 1) the publication and presentation of misleading information in the guise of "educational" material; 2) the captive breeding of certain wild animal species (e.g. mink, fox, bobcat) according to agricultural standards on fur farms; and 3) the simultaneous operation of A) a public wildlife exhibition by a non-profit "educational" organization, B) a private fur-production facility by an affiliated organization, C) a private meat-production facility by an affiliated organization, D) a private boarding, breeding, and sales facility for horses and dogs by an affiliated organization, etc.

Why are some issues not actionable in court?

Because as long as there's a market for farmed fur, there will be fur farms. As long as people are willing to pay admission to roadside animal exhibits, captive-wildlife petting zoos and photo shoots, etc. there will be exhibits of this kind. As long as people seek out or are willing to settle for incomplete and misleading "educational" experiences, those experiences will be made available by the lowest bidder.

Why are other issues actionable in court?

Because of National, State, and Local Laws, Statutes, Rules, Codes, Ordinances, etc. (including U.S. Endangered Species Act, U.S. Animal Welfare Act, U.S. Lacey Act, and MN Statute Sections 97A.105, 97A.041, 346.155, 97A.401--see more about these in the References section below)

How are current laws lacking?

I haven't caught up on all of the blog articles, legal documents, etc., and I'm not a lawyer or anything like that; but the picture I'm starting to see is one of permanently-constructed "loopholes" in our government regulations concerning the treatment of "protected wild animals" on fur farms. Big loopholes. Not bigger than the ESA, but bigger than, say, the hunting and trapping programs that the MN DNR operates to regulate the taking of "protected wild animals."

In other words, wild animals are often protected more in the wild than they are in captivity. That's a problem.

Wildlife-based industries, including the fur industry, are big business; and the farmed-fur industry is by far the largest part of the fur industry. The fur industry seems to be able to hold its own in court against the conflicting concerns of fish & game management, wildlife management, non-game wildlife management, management of wildlife in the Public Trust, etc.

These court cases and other actions we've been reading about in connection with Fur-Ever Wild have been, and will be, revealing this subject to much-needed public examination. Concerned citizens need to learn, to moderate our own consumer behaviors, and to speak up on the subject of the management of wildlife in the Public Trust.


Approximate chronology of events at Fur-Ever Wild. The literature reference is "Petter 2012" unless otherwise noted.

  • Prior to 1992: Operated a farm on Dodd Blvd, adjacent to the current facility.

  • 1992: First captive wolf.

  • 1998: Bought the adjacent farm on 235th Street. Built a new barn and house.

  • 2001: Added raccoons.

  • 2002: Added foxes.

  • 2003: Added bobcats, lynx.

  • 2004: Added Jake the cougar cub.

  • 2005: Added Leena, the second cougar, planning to breed her with Jake.

  • 2005: Obtained the initial MN DNR license for the fur farm.

  • 2006: Formed the non-profit organization Wolves Woods & Wildlife, Inc.

  • 2006: Reported to Eureka Township on the number of animals in stock.

  • 2006: Began reporting to the USDA APHIS on the exhibited animals.

  • 2007: Added the third cougar.

  • 6/7/2005: Eureka Township Exotic Animal Ordinance was established (Ord. 3, Ch. 7, Sect. 3, some part of it dated 8/13/2007). The "grandfathering" clause allowed existing operations to continue with the numbers of exotic animals that were allowed before the establishment of the Ordinance (Heidelberger 2015b).

  • 2010: Added the fourth cougar.

  • 11/15/2010: Barn destroyed in fire.

  • 8/2011: Construction began on the replacement barn.

  • 2011: Eureka Township issued a stop-build order on the replacement barn, determining that it was not an agricultural building (allowed) but a public facility (not allowed) (Petter 2012, Chick 2013).

  • 2011: Formed the corporate business entity "Fur-Ever Wild, Ltd."

  • 2012: Formed the single-proprietorship business entity "Fur-Ever Wild."

  • 2012: First litter of cougar kittens was born from Jake and Leena.

  • 12/19/2012: Ms. Petter described Fur-Ever Wild and Wolves Woods & Wildlife operations in a Deposition for MN District Court (Petter 2012).

  • 2013: Area residents sued in MN District Court to require Eureka Township to enforce its exotic animal Ordinance (Adler, 2015).

  • 3/7/2013: Ms. Petter proposed changes to Eureka Township Ordinances to specifically allow agri-tourism (public exhibition of animals, etc. on farms) (Chick 2013).

  • 8/12/2013: Eureka Township Board granted an exception from the exotic-animal Ordinance for Fur-Ever Wild. Chairman Storlie, a cousin of Fur-Ever Wild co-owner Dan Storlie, advocated for and voted for the exception (Lemmons 2015).

  • About 2015: Fur-Ever Wild bought land for a second facility in Deadwood, SD.

  • About 2015: Eureka Township Board stated (and MN District Court ruled?) that the Fur-Ever Wild fur farm was allowed under Township Ordinances for livestock production. That ruling was later reversed by the MN Court of Appeals (see below, 4/27/2015).

  • 4/27/2015: MN Court of Appeals found that Township Ordinances did not allow the production of exotic animals as livestock (Heidelberger 2015b). Township Ordinances define an "Exotic Animal" as "any animal that is not normally domesticated in the United States or is wild by nature..." and specifically exclude companion animals and exotic animals from their definition of the term "Livestock."

  • 4/27/2015: MN District Court was assigned the question of whether the grandfathering clause of the Township Ordinance would allow Fur-Ever Wild to continue with the number of exotic animals that were allowed on 6/7/2005. (That MN District Court finding has not yet been recorded on this timeline.)

  • 5/19/2015: The Animal Legal Defense Fund (ALDF) sent a complaint to USDA over violations of U.S. Animal Welfare Act (Backus 2015, Heidelberger 2015a). USDA animal-care inspector found "no noncompliant items" during a routine inspection on 6/3/2015 (Heidelberger 2015b).

  • 6/8/2015: Eureka Township ordered Fur-Ever Wild to "permanently remove all exotic animals." Township Resolution 2015-11 in response to the finding of the MN Court of Appeals (Adler 2015, Heidelberger 2015b). Township attorney said the legal procedures to enforce the order would take months (Adler 2015).

  • 7/6/2015: Deadwood, SD established a new wild/exotic animal Ordinance. A grandfathering clause allowed existing operations to continue, but prohibited the addition of new wild/exotic animals (Conrad Pearson 2015).

  • 8/12/2015: A for-sale sign was seen on the Fur-Ever Wild land in Deadwood, SD (Griffith 2015).

  • 12/2/2015: ALDF announced its intention to sue Fur-Ever Wild for violations of the U.S. Endangered Species Act (ESA) by keeping Gray Wolves captive, and harvesting their fur and other body parts (Cronin 2015, Hanson 2015, Heidelberger 2015c, Lima 2015, Kirby 2015, Zurowski 2015).


Adler, Erin. 2015. "Lakeville-Area Fur Farm Fur-Ever Wild Sparks Controversy with S.D. Expansion." Star Tribune. July 21. http://www.startribune.com/lakeville-fur-farm-fur-ever-wild-sparks-controversy-with-south-dakota-expansion/317665251/

Backus, Megan. 2015. "Wolf Pup Exhibitor Endangers Animal and Human Health." Animal Legal Defense Fund (ALDF). May 19. http://aldf.org/press-room/press-releases/wolf-pup-exhibitor-endangers-animal-and-human-health/

Born Free USA. 2009. "Cruelty Uncaged: A Review of Fur Farming in America." Born Free USA. http://www.all-creatures.org/articles/ar-cruelty-uncaged-furt.pdf

Change for Animals Foundation. 2012. "Ten Things Everyone Should Know about Fur." Change for Animals Foundation. http://www.spca.org.sg/documents/tenthingsfur.pdf

Chick, Jennifer. 2013. “Proposed Zoning Ordinance Changes Have Eureka Township Residents Questioning What Animals Can Be Allowed.” Sun This Week, March 1. http://sunthisweek.com/2013/03/01/proposed-zoning-ordinance-changes-have-eureka-township-residents-questioning-what-animals-can-be-allowed/

Conrad Pearson, Jackie. 2015. "Deadwood Adopts Dangerous Wild/exotic Animal Ordinance." Black Hills Pioneer, July 22. http://www.bhpioneer.com/article_2a082022-3088-11e5-be5f-939bc791d200.html

Cronin, Aisling Maria. 2015. "Minnesota Petting Zoo Exposed for Killing Endangered Gray Wolves for Their Fur." One Green Planet. December 13. http://www.onegreenplanet.org/news/minnesota-petting-zoo-exposed-for-killing-endangered-gray-wolves-for-their-fur/

Hanson, Hillary. 2015. "Petting Zoo Accused Of Slaughtering Endangered Animals For Fur." Huffington Post. December 10. http://www.huffingtonpost.com/entry/petting-zoo-fur-ever-wild-wolves-fur_56687c8ce4b0f290e52199a2

Griffith, Tom. 2015. "Wildlife Attraction to Close; Property for Sale." Rapid City Journal, August 12. http://rapidcityjournal.com/news/local/wildlife-attraction-to-close-property-for-sale/article_e394f570-7fba-5243-af91-f754b41a6e02.html

Heidelberger, C. A. 2015a. "USDA Called to Investigate Minnesota Wolf-Fur Farm on Eve of South Dakota Hearing." Dakota Free Press. May 19. http://dakotafreepress.com/2015/05/19/usda-called-to-investigate-minnesota-wolf-fur-farm-on-eve-of-south-dakota-hearing/.

Heidelberger, C. A. 2015b. "Township Orders Removal of Exotic Animals from Minnesota Fur Farm." Dakota Free Press, June 12. http://dakotafreepress.com/2015/06/12/township-orders-removal-of-exotic-animals-from-minnesota-fur-farm/

Heidelberger, C. A. 2015c. "ALDF Ultimatum to Petter: Quit Exploiting Pelting Wolves or We Sue." Dakota Free Press. December 2. http://dakotafreepress.com/2015/12/02/aldf-ultimatum-to-petter-quit-exploiting-pelting-wolves-or-we-sue/

HSUS, WWF, Born Free USA, et al. Petition to USDA APHIS. 2013. "Petition for Rulemaking to Prohibit Public Contact with Big Cats, Bears, and Nonhuman Primates," January 7. http://bigcatrescue.org/wp-content/uploads/2014/10/Public-contact-petition-amended-1-13-and-comments.pdf

Kirby, David. 2015. "Activists Move to Sue Operator of a Gray Wolf Fur Farm." TakePart. December 7. http://www.takepart.com/article/2015/12/07/activists-sue-operator-wolf-fur-farm

Kosel, Shari. Petition to Eureka Township, MN. 2015. "Petition: Stop Fur Farm from Exploiting and Killing Wolf Pups," May 1. https://www.change.org/p/stop-fur-farm-from-exploiting-and-killing-wolf-pups

Lemmons, Chad. Affidavit. 2015. "Affidavit of Eureka Township v. Fur-Ever Wild, Exhibit 8" December 30. https://drive.google.com/folderview?id=0B2JsJ39wDt3KZ002cnhhVk80bWc&usp=sharing

Lima, Natalia. 2015. "Animal Legal Defense Fund Files 60-Day Notice of Intent to Sue Fur-Ever Wild." Animal Legal Defense Fund. December 2. http://aldf.org/press-room/press-releases/animal-legal-defense-fund-files-60-day-notice-of-intent-to-sue-fur-ever-wild/

MN Statutes Section 97A.105: Game and Fur Farms.

  • Regulates facilities that produce certain captive-reared wild animals, including furbearing mammals, game birds, bears, and mute swans.

  • Enforced through MN DNR Rules Chapter 6242: Shooting Preserves and Game Farms.

  • This seems to be the section of MN Statutes under which the fur-farming operation of Fur-Ever Wild is licensed and regulated.

  • https://www.revisor.mn.gov/statutes/?id=97A.105

MN Statutes Section 97A.041: Exhibition of Wildlife.

  • Regulates the treatment of wildlife in captivity for public exhibition.

  • Enforced through MN Rules Chapter 6244: Captive Wildlife.

  • This seems to be the section of MN Statutes under which the traveling exhibition of Fur-Ever Wild's affiliate "Wolves Woods & Wildlife" is licensed and regulated.

  • https://www.revisor.mn.gov/statutes/?id=97A.041

MN Statutes Section 346.155: Possessing Regulated Animals.

  • Regulates the ownership of certain wild cats, bears, and primates--with exceptions for small-game mammals (thus it does not regulate the ownership of bobcat, cougar, or lynx). It allows those in business in 2004 with a USDA license to continue that business.

  • Enforced, perhaps, by Rules in common with MN Statutes Section 97A.401: Game & Fish Special Permits for Possessing Wild Animals.

  • https://www.revisor.mn.gov/statutes/?id=346.155

MN Statutes Section 97A.401: Game & Fish Special Permits for Possessing Wild Animals.

  • Regulates the taking and captive possession of wild animals, including feeding, watering, sanitation, veterinary care, handling, and disposal.

  • Enforced by MN Rules including Section 6244.1000: Animal Health and Husbandry.

  • https://www.revisor.mn.gov/statutes?id=97A.401

Petter, Teresa. 2012. "Deposition of Teresa Lynn Petter, Fur-Ever Wild." MN District Court, Dakota County, First Judicial District. https://drive.google.com/file/d/0B2JsJ39wDt3KYkd2eDh0Y1NIUGs/view

USDA APHIS. 2012. "Violation by Wolves Woods & Wildlife: Puma Cubs Exposed to Public Contact." U.S. Department of Agriculture, Animal & Plant Health Inspection Service (USDA APHIS). https://www.aphis.usda.gov/foia/enforcement_actions//2012/September/Animal%20Welfare%20Act%20(AWA)/7060s/MN120073%20T.%20Petter%20Wolves%207060%20Redacted.pdf

U.S. Endangered Species Act.

U.S. Animal Welfare Act.

U.S. Lacey Act.

Welcome to MN. 2015. "Minnesota Allowing Farmers To Breed Gray Wolves For Their Fur?" May 29. http://welcome2mn.blogspot.com/2015/04/minnesota-allowing-farmers-to-breed.html

Zurowski, Cory. 2015. " 'Tis the Season for Slaughtering Gray Wolves at Fur-Ever Wild in Lakeville." City Pages. December 17. http://www.citypages.com/news/tis-the-season-for-slaughtering-gray-wolves-at-fur-ever-wild-in-lakeville-7901098

Photo of a wolf at Fur-Ever Wild. By Michelle, Welcome Minnesota.
Wolf at Fur-Ever Wild. Photo credit: Welcome Minnesota.

Mech et al. vs. ESA protections for the Gray Wolf

posted Nov 25, 2015, 10:22 AM by Scott Slocum   [ updated Nov 25, 2015, 10:29 AM ]

To: U.S. Secretary of the Interior, Sally Jewell. (https://www.doi.gov/feedback)
From: Scott Slocum. (www.SS-Slocum.info)
Cc: Director of the USFWS, Dan Ashe. (dan_ashe@fws.gov)
Re: In support of ESA protections for the Gray Wolf.

Thank you for the opportunity to comment on this controversy, as it comes to the attention of the legislative, judicial, and executive branches of the U.S. government. 

I'm writing in opposition to the 11/19/2015 letter from Mech et al. to the U.S. Secretary of the Interior concerning the delisting of the Gray Wolf in the western Great Lakes States (Mech et al. 2015). I'll address three of that letter's shortcomings below.

Misstatement #1: "efforts... to delist or down-list gray wolves in the western Great Lakes states have been foiled or reversed by litigation typically based on legal technicalities rather than biology."

One of the many facts that's ignored here is that Judge Howell's 2014 federal court opinion (Howell 2014) was based in part on the critical biological point (in its discussion section, C4) that the Minnesota Wolf Management Plan for Zone A and Zone B effectively established "an unregulated killing zone for wolves" in Zone B (a killing zone of the type that was successfully challenged in Wyoming). The extent of this problem with the Plan and its implementation in Zone B made it unnecessary for the court to address other problems with the Plan and its implementation in Zone A.

Misstatement #2: if a species is not delisted once it meets its recovery goals, it "creates public resentments toward the species and the ESA." 

As if those "resentments" weren't there from the beginning. I know that in Minnesota, they were there from the beginning. 

Granted, the signers of Mech et al. have certainly had many, many personal communications upon which they could base a statement like this. At least, they could have made it more supportable: something like "there is a great deal of resentment, in certain segments of public opinion, that the Gray Wolf remains listed under the ESA in the Western Great Lakes States." Indeed, with a more-supportable statement, they might have gotten away without having any scientific survey results at all (which, of course, they don't have). 

This ends up to be only another unsupportable element of a short letter with little in the way of support. 

Misstatement #3: the authors list their credentials as a way of making up for their lack of work on the letter itself.

By far, the most substantial part of this letter seems to be the listing of the credentials of its signers. This seems to be an attempt to "pull rank" on the presumably younger and arguably more accountable and responsible scientists who wrote open letters on the subject to the people and the U.S. Congress on 2/18/2015 (Vucetich et al. 2015) and 11/23/2015 (Treves et al. 2015) in support of continued protection for the Gray Wolf under the ESA.

As I've written before, I see potential in the framework of federal delisting followed by State management. On the other hand, I see failings in that framework. I'd like to think that the solution would be to fix it; but until it's fixed, it would seem that the only way to continue the necessary and appropriate protections for the Gray Wolf in the U.S. (particularly in the western Great Lakes States) will be to continue its listing as endangered or threatened under the ESA.

Discussions are needed, but given the bills (and budget-bill riders) that have been surfacing in Congress with the intent to silence those discussions (and proceed directly to the failed framework of federal delisting followed by State management), they're not taking place. I hope you'll oppose the efforts to silence those discussions, and instead facilitate them and bring them to a scientifically-, legally-, and socially-acceptable resolution.

Scott Slocum


Howell, Beryll A. 2014. Federal Protections Restored for Great Lakes Wolves. U.S. District Court. December 19. MPR News article: http://www.mprnews.org/story/2014/12/19/wolves

Mech, L. David, Steven H. Fritts, Adrian P. Wydeven, Tom Heberlein, Ed Bangs, Scott Craven, Lu Carbyn, and Tim Van Deelen. 2015. “Scientists to Feds: Great Lakes Wolves Not Endangered,” November 19. Detroit Free Press article: http://www.freep.com/story/news/local/michigan/2015/11/18/scientists-great-lakes-wolves-endangered/76015486/

Treves, Adrian, John Vucetich, Jeremy T. Bruskotter, Bradley Bergstrom, William Lynn, Michael Paul Nelson, Robert Crabtree, and Paul Paquet. 2015. “Scientists to Feds: Great Lakes Wolves Should Remain Protected,” November 23. http://faculty.nelson.wisc.edu/treves/reports/Wolf_conservation_open_letter.pdf

Vucetich, John, Rolf Peterson, Adrian Treves, Lisa Naughton, Michael Paul Nelson, William J. Ripple, Daniel D. Roby, et al. 2015. “An Open Letter to Members of Congress from Scientists on Federal Wolf Delisting.” February 18. HSUS blog: http://blog.humanesociety.org/wayne/2015/02/scientists-letter-wolves-congress.html

Gray Wolf, by Gary Kramer, USFWS

2016 MN LCCMR Grant Requests for Wolf Study and Education

posted Jul 16, 2015, 11:10 AM by Scott Slocum   [ updated Oct 16, 2015, 7:08 PM ]

There are a couple of good-looking grant proposals into the Legislative-Citizen Commission on Minnesota Resources  (LCCMR) this year for wolf research and education.

Update: 9/17/2015

Unfortunately, this project was not granted a hearing by the LCCMR.


Hackett, Maureen. 2015. "Protecting Minnesota's Livestock, Wildlife, and Farmers." Grant Request 034-A. LCCMR. Howling for Wolves. http://www.lccmr.leg.mn/proposals/2016/original/034-a.pdf.


Kline, David. 2015. "Expanded 'Wolves at Our Door' Program." Grant Request 099-C. LCCMR. International Wolf Center. http://www.lccmr.leg.mn/proposals/2016/original/099-c.pdf.

LCCMR headline
Full list of 2016 grant requests to the MN Legislative-Citizen Commission on Minnesota Resources (LCCMR): http://www.lccmr.leg.mn/proposals/2016/2016_proposals_by_topic_area.html

Wildlife Services pretends to assess its operations in Idaho

posted Jun 27, 2015, 12:35 PM by Scott Slocum   [ updated Jun 27, 2015, 12:45 PM ]

To: USDA Wildlife Services.

Re: Predator Damage And Conflict Management In Idaho.

Document ID: APHIS-2014-0105-0072.

Document URL: http://www.regulations.gov/#!docketDetail;D=APHIS-2014-0105


Thank you for the opportunity to provide feedback on the draft Environmental Assessment (EA) on Wildlife Services operations in Idaho.

I won't attempt, here, to respond to the entire document, but I do have a response to an overall aspect of it: its natural bias for "business as usual" and against a thorough examination of the problem and the potential for Integrated Pest Management (IPM) to solve it. It's a complex problem that calls for a complex solution. This draft EA attempts to offer oversimplified solutions so that it can conclude that they won't work, and that no changes should be made.

Options oversimplified

This draft EA attempts to reduce a complex situation to a few, oversimplified alternatives--all but one of which would be unworkable--in order to arrive at the predetermined conclusion that Wildlife Services should continue to operate as it has in the past, without integrating new policies or practices.

IPM Ignored

This draft EA ignores the complex alternatives and potentials of Integrated Pest Management (IPM, or as it's referred to here, "integrated PDM" or "integrated predator damage management").

As I understand IPM, it's a combination approach that's taken when there's more than one solution to different aspects of a problem in agricultural management. IPM applies the most effective combination of solutions, in their most effective sequence and schedule, in order to optimize the cost/benefit ratio of the management program.

For example, the lethal and non-lethal approaches to minimizing human/coyote conflict include the following:

Lethal depredation control:

  • Degree of targeting in predator removal:

    • Taking out known individuals in response to specific depredations.
    • Taking out a large percentage of the predator population annually.
  • Methods of removal:
    • Trapping.
    • Poisoning.
    • Land-based shooting.
    • Aerial shooting.
  • Removal agents:

    • Wildlife Services agents.
    • Predator-control contractors.
    • Livestock producers.
    • Recreational sportsmen.

Non-lethal depredation control:

  • Predator-deterrent fencing:

    • Especially at the most vulnerable times: birthing, Spring, early Summer, dusk, dawn.
    • Especially in the most likely places: near cover, near den, etc.
    • Mobile, as part of a rotational-grazing program.
  • Carcass disposal:
    • Buried on-site.
    • Protected by predator-deterrent fence on-site.
    • Contracted off-site.
  • Electronic alarms:

    • Radio-collared predators (location).
    • Radio-collared livestock (heart rate, motion).
    • Radio-collared livestock-guardian animals.
    • Motion detectors.
    • Video monitoring.
  • Physical interaction with predators.
    • Range riders driving rotational grazing.
    • Livestock-guardian animals herding and moving with livestock.
    • Human response to electronic alarms.
    • Human response to livestock-guardian animals.
    • Motion-sensitive lighting.
    • Deterrent lighting.
  • Animal husbandry.
    • Regular, personal supervision.
    • Monitoring for health.
    • Protecting and treating weakened individuals.

This is just the quick list that came to my mind as I thought about it today. I'd expect this EA to be more exhaustive and integrative than this, but I see that it isn't. That's a problem.

It seems to me that in drafting this EA, Wildlife Services has oversimplified the situation in order to make the predetermined conclusion seem more obvious. It has ignored the IPM approach, and attempted instead to make the situation look like an "either-or" choice between one narrow-minded approach or another (e.g. either all status quo, all advice and no action, all private, or all non-lethal).

Non-lethal cost/benefit ratio and subsidy options neglected

In addition to neglecting the analysis of cost/benefit ratios among the alternatives (essentially leaving that analysis to the private sector), the draft EA doesn't sufficiently explore the following non-lethal options:

  • Requiring non-lethal precautions before subsidizing lethal control.

  • Subsidizing non-lethal precautions.

The arguments of the draft EA against the subsidy of non-lethal options are not convincing. Agreed, most livestock producers do take various non-lethal precautions at one level or another. Agreed, they don't all take the same level of precautions. But that doesn't mean that fair government subsidies for non-lethal precautions would favor some producers more than others, or that fair subsidies would interfere with existing programs.

Agreed, for livestock producers who have taken appropriate non-lethal precautions, it's in the public interest to provide compensation for the loss of livestock and the expense of lethal control. But that doesn't mean that the only funding option for non-lethal control would be the end of funding for lethal control, or that such a radical shift in funding would be in the public interest. The common-sense option, here, is to integrate government funding in the most effective way along the lines of IPM.

It's not acceptable for this draft EA to set up such a "straw man" argument for a funding shift, and then attempt to dismiss it with an irresponsible statement like "this proposal will not be considered in detail because of the problems associated with unequal access to federal fiscal assistance."


The draft EA needs to be more open-minded in regard to the alternatives. Agreed, that's not simple to do; but given the public interest in wildlife and environmentally-oriented agriculture, and the considerable budget of Wildlife Services operations in Idaho and nationwide, it would be appropriate.  


Our Wisconsin, Our Wildlife: meet the barstool biologist

posted May 28, 2015, 4:25 PM by Scott Slocum   [ updated May 28, 2015, 4:30 PM ]

I wish I wrote this. The reason analyses like this are rare is because 1) they don't have the thankful religious audiences that flock to the feet of the barstool to praise the original nonsense, and 2) they take hundreds of times more effort to write than the barstool pieces they analyze. So the one who did all of the work ends up feeling, like the one who actually did the shared homework assignment, that he's been cheated by the system. 

Except that he hasn't.

Good job, Our Wisconsin, Our Wildlife

Our Wisconsin, Our Wildlife. 2015. "Meet the 'Barstool Biologist' Who Thinks He Speaks for 'Everyone' in Wisconsin about Wolves." May 22. https://ourwisconsinourwildlife.wordpress.com/2015/05/22/meet-the-barstool-biologist-that-thinks-he-speaks-for-everyone-in-wisconsin-about-wolves/.


National Wolf Recovery Plan

posted May 6, 2015, 2:10 PM by Scott Slocum   [ updated Jan 14, 2017, 6:46 AM ]

A National Wolf Recovery Plan has been proposed by Michigan Tech environmental scientist and wolf expert John Vucetich et al

It would define clear boundaries for "Gray Wolf range," continue to assist livestock producers and pet owners in avoiding and recovering from losses, and--as long as necessary within the newly-defined boundaries--maintain protections for the Gray Wolf under the U.S. Endangered Species Act as a "threatened" species (thus allowing lethal depredation control).

An alternative proposal for a blanket downlisting of the Gray Wolf to an ESA status of "threatened" has been reviewed in an other blog entry here.

This proposal for a National Wolf Recovery Plan, in contrast to the simple downlisting proposal more thoroughly thought-through and well-balanced, is what's needed to allow this nation and its State wildlife-management agencies to proceed with wolf recovery and conservation.


Vucetich, John A., Jeremy T. Bruskotter, M. P. Nelson, and M. Phillips. 2015. "Framework For Envisioning Gray Wolf Recovery." 
This "framework" document by Vucetich et al. is apparently a work in progress. As of 1/14/2017, it doesn't seem to be available at its original URL. Hopefully, an updated version will be available from the authors.

Lamplugh, Rick. 2015. "Let's Build a National Wolf Recovery Plan." Rick Lamplugh.
This blog entry by Rick Lamplugh referred to and partially summarized the "framework" document by Vucetich et al.

Humane Society of the United States, Center for Biological Diversity, Fund for Animals, and Born Free USA. 2015. "Petition to Reclassify Gray Wolves as Threatened in the Conterminus United States Under the Endangered Species Act." http://midwestadvocates.org/assets/resources/Wolf%20Quota/Gray_Wolf_Downlisting_Petition___FINAL_%2801_27_15%29.pdf
This document supports the petition to list the Gray Wolf as "threatened" in the lower-48 states. It includes a summary of the "framework" document by Vucetich et al.

Wolf recovery map from the "framework" document by Vucetich et al. It divides the lower-48 states into four regions with different natural histories involving man and wolf, identifies pockets of surviving wolf populations, pinpoints areas of high human density, and proposes potential wolf recovery areas.

USFWS Wolf Livestock Demonstration Project Grants

posted Apr 26, 2015, 10:31 AM by Scott Slocum   [ updated Jul 17, 2017, 11:32 AM ]

Update: 7/17/2017

To: U.S. Senator Al Franken.
Re: MN Wolf-Livestock Conflict Prevention Pilot Program.

I would thank you for your reply to my 2017 complaint about S. 1514, the so-called "HELP for Wildlife Act"--except that it's just a copy of your uninformative reply to my similar complaint against the weakening of the Endangered Species Act (ESA) two years before.

In 2015, I complained to you about amendments that were being proposed to the ESA that would, as I described them, "weaken the ESA, either by delisting species, delaying listings, or interfering with the due process of environmental protection." 

In your 2015 reply, you expressed your limited support for the protection of the Gray Wolf in Minnesota as long as it could be done "without threatening Minnesotans, their livestock or pets." At the same time, you expressed your full support for 1) the "continued funding for the USFWS Wolf-Livestock Demonstration Project Grant program," and 2) the restoration of funding to "USDA gray wolf management and technical assistance programs, which provide relief for farmers and ranchers suffering livestock losses when preventative measures fail." 

Disappointed by your 2015 reply, I wrote to remind you about a major problem with that USFWS program in Minnesota: the state of Minnesota has participated only in the lethal part of the program, declining to apply for grants to assist with non-lethal depredation control.

So imagine my disappointment when, in 2017, I wrote to you again about protection for the Gray Wolf, and received the same reply from you, without any mention of the Minnesota problem.

I won't try, today, to get into all of the problems with your boilerplate position on the subject of the ESA and the Gray Wolf; but I'd like to focus on one area in which your genuine response and participation would be invaluable.

There's been a positive development in Minnesota: we now have a non-lethal depredation-control program! The Minnesota "Wolf-Livestock Conflict Prevention Pilot Program" was created in Minnesota Session Law, 2017, Chapter 88 to assist livestock producers with non-lethal depredation control. It should qualify for matching federal funds through the [USFWS] Wolf-Livestock Demonstration Project Grant program, but I haven't yet heard whether the Minnesota Dept. of Agriculture has applied for the matching federal funds.

It would be great if you would encourage them to do so.

Re: USFWS Wolf Livestock Demonstration Project Grants.

Thank you for your response to my letter warning against legislative Gray Wolf management. I support scientific Gray Wolf management (including independent peer review, and excluding political and industrial overrides).

Your reply referred me to the USFWS Wolf Livestock Demonstration Project Grant program (FederalGrants 2014), which, as you correctly pointed out, is available "to help farmers and ranchers deploy preventative measures against wolf predation and to compensate them when losses do occur."

You should know that of that two-part federal program, one part has been ignored by the State of Minnesota Department of Agriculture and Department of Natural Resources.

Unfortunately, Minnesota officials have declined to support Minnesota livestock producers through "preventative measures against wolf predation." (Smith 2010, USFWS 2013, USFWS 2014). Whether this is due to the personal beliefs of these officials about the effectiveness of these measures, or to the stress of the political and industrial pressures these officials find themselves under; they have chosen to ignore non-lethal measures, and concentrate instead on lethal measures and compensation funding.

Minnesota livestock producers are not required to take precautions to protect their livestock from depredation. All they need to do is call the federal trappers to remove all of the wolves from the area, and then file for compensation for their losses.

You're right to expect non-lethal precautions to be a precondition for lethal control and a requirement for compensation, but that's not the way things are.

But let's get back to the beginning; I wrote to ask you not to short-circuit the process of Gray Wolf delisting with a legislative workaround.

The proper process of Gray Wolf delisting includes an orderly transfer of management activities to the States, according to their Wolf Management Plans. Minnesota has a decent Plan, but as a federal court has now pointed out, it wasn't complete, it wasn't examined for completeness, and it wasn't followed completely. It skipped Zone B, and it skipped non-lethal depredation control.

We need to follow a proper process of Gray Wolf delisting that can stand up to legal and scientific examination. I hope you will look into the matter further, and support that process.


FederalGrants. 2014. “Wolf-Livestock Demonstration Project Grant Program (WLDPGP).” Federal Grants. 

Smith, Paul. 2010. "Feds Announce New Wolf Depredation Funds to Wisconsin, Other States." Milwaukee Journal Sentinel, April 1. 

USFWS. 2013. FY 2014 Wolf-Livestock Demonstration Project Grants. U. S. Fish & Wildlife Service. Indexed at 

USFWS. 2014. FY 2014 Wolf-Livestock Demonstration Project Grants. U. S. Fish & Wildlife Service. 

USFWS logo

MN wolf-livestock-conflict prevention grants!

posted Apr 17, 2015, 2:20 PM by Scott Slocum   [ updated Nov 21, 2015, 6:50 PM ]

Finally, a proposal to implement livestock Best Management Practices for non-lethal depredation control!

Minnesota Senate, 2015, SF 2082: Lourey, Saxhaug, Sparks. Wolf/livestock conflict-prevention grants

A program like this was called for in the 2001 MN Wolf Management Plan (14 years ago, if you were counting). 

This program would be eligible for matching federal funds (Smith 2010, USFWS 2014).


The Minnesota Department of Agriculture may award grants to Minnesota livestock producers for the cost of practices to prevent wolf-livestock conflicts.

Grants may be awarded for:
  1. Guard animals;
  2. Wolf barriers including fencing, fladry, and pens;
  3. Wolf-deterring lights and alarms;
  4. Calving or lambing shelters;
  5. Etc.
Grant recipients must make the following good-faith efforts: 
  1. Avoid wolf-livestock conflicts;
  2. Care for guard animals;
  3. Document the expenses;
  4. Report annually on the effectiveness of the non-lethal methods; and
  5. Allow follow-up evaluation and monitoring.

Author and co-authors

MN Senator Tony Lourey MN Senator Tom Saxhaug MN Senator Dan Sparks
Minnesota Senators Tony Laurey, Tom Saxhaug, and Dan Sparks.


Smith, Paul. 2010. "Feds Announce New Wolf Depredation Funds to Wisconsin, Other States." Milwaukee Journal Sentinel, April 1. http://www.jsonline.com/blogs/sports/89710142.html.

USFWS. 2014. FY 2014 Wolf-Livestock Demonstration Project Grants. U. S. Fish & Wildlife Service. http://www.fws.gov/endangered/grants/pdf/FY14_Wolf_Livestock_Demonstration_Program_Grants_Chart.pdf.

MN House Agriculture Finance Committee jokes about non-lethal wildlife management, but serious about wolf/elk compensation

posted Feb 28, 2015, 10:30 AM by Scott Slocum   [ updated Mar 1, 2015, 11:28 AM ]

MN House Agriculture Finance Committee meeting, 2/26/2015. Full video recording.

The young people visiting for Future Farmers of America's "FFA Day at the Capitol" learned this week how the Minnesota House Agriculture Finance Committee manages its own "direct line" to the State's General Fund. 

Welcome, Future Farmers of America! Welcome to our Committee! Chairman Rod Hamilton (R-Mountain Lake) gestured with both hands raised. "Wonderful! Wonderful!" Honors were bestowed on retiring MN FFA Secretary Jim Ertl and on Food Farm owners and organic farmers Janaki Fisher-Meritt and Annie Dugan with their baby son Truman. No testimony was heard from organic farmers.

MN Rep. Rod Hamilton: Wonderful! Wonderful!
MN Rep. Rod Hamilton: Wonderful! Wonderful!

Three bills got their first hearings in the Committee's 2/26/2015 meeting. Without any voting necessary the three bills were "laid over for possible inclusion" in the committee's omnibus bill. What does that mean? Apparently that committee leadership will give them all the green light if possible. None of them will be subject to individual scrutiny or vote; voting will only be on the whole collection chosen by the committee leadership (Chairman, Vice Chairperson and Minority Lead). In other words, safe passage for these special bills.

The first bill was HF 888, titled "Mentoring and Farm Business Management Program challenge grant funding provided." It would provide an additional $2.4 million/year to the base funding of about $1 million/year for the program, which is operated by contract instructors on the campuses of Minnesota State Colleges and Universities (MNSCU). 

Committee Members and testifiers praised the higher-education bill for over an hour, interrupted by only one challenging question: why wasn't the bill going through normal channels (the MN House Higher Education Policy and Finance Committee)? The answer: "because that would be harder." The Agriculture Finance Committee is a friendlier audience, with fewer competing priorities--and apparently its own direct line to the State's General Fund.

Interactive Multimedia!

Click on the photos! 
Hear the funny things your policy makers are saying!

The second and third bills (HF 348 and HF 514) had one task to accomplish: to translate one item from the Governor's budget into an appropriations bill. The two bills, introduced independently, overlapped on FY2016-2017 coverage. The latter was more comprehensive, additionally covering payments for elk damage and for FY2015 wolf depredation.

Even though the task might sound straightforward, it was a good thing the Chairman left a half-hour for comments on wolf policy, because many of the lobbyists and Members seemed to want their minute in the spotlight. Again, no comment on the issue from the organic agriculture community, which would be expected (if it were asked) to weigh in with solid support for non-lethal livestock-depredation control. As stated on the Food Farm website "The practice of organic agriculture nurtures the farm as a natural organism. The goal is to establish and maintain an optimal balance of animal, plant and human activity in a self-sustaining system.  Wholesome and delicious food is a product of these practices."

To be fair, these bills did concern wolf policy, so it was natural for people to want to talk about some of the related topics. Too bad they didn't want to talk about other ways (besides the formal topic of compensation payments or the informal topic of the limitations of non-lethal depredation control) they could make things better for Minnesota farmers. For example, funding to develop, publish, and support Best Management Practices (BMP) for livestock-depredation management, as directed in the MN Wolf Management Plan (and organic farming ethics).

There seemed to be a feeling in the room that all that could be done here was to fund the compensation payments; that most wolf-management policy is decided elsewhere--in the Environment & Natural Resources Committees and the Minnesota Department of Natural Resources (MN DNR). The fact remains, however, that two important parts of wolf policy are the responsibility of agriculture (the MN Department of Agriculture (MDA) and the MN Legislature's Ag. Policy and Ag. Finance Committees): 

1) Compensation for livestock losses to wolf depredation. 
2) Best Management Practices (BMP) for livestock-depredation management. 
The complaint of Committee Members seemed to be that they could only carry out the first of these responsibilities; and that they considered the second a joke.

But in fact, rubber-stamping the funding of livestock compensation is not the only wolf-related responsibility of agriculture. According to the MN Wolf Management Plan, the responsibilities of agriculture include the BMPs for livestock-depredation management. Like it or not, those include non-lethal practices; not just the old-men's preference for extermination (i.e. opening a predator-control area to kill all of the wolves within a one-mile radius of the farm).

MN Rep. Dale Lueck
MN Rep. Dale Lueck: "I don't care if you put an elephant out there, [a large pack of wolves] will get him."

Unfortunately, rather than accepting agriculture's responsibility for livestock BMPs, in this hearing, the Committee chose to make fun of non-lethal control, focusing on one aspect of it (that was never meant to stand on its own) while ignoring or attempting to shift responsibility for the other aspects to the MN DNR (or the organic agriculture community, or the LCCMR, or somewhere populated by liberal wolf huggers--certainly not the Farm Business Management Program or the FFA, which were so well represented in the room on this great day). 

MN Rep. Jason Metsa (after telling his story about "one big SOB" wolf found dead on the highway).
MN Rep. Jason Metsa straightens his tie after telling his story about "one big SOB" of a wolf that was found dead on the highway (near a farm with a donkey). Good stand-up comedy!

The subject that was singled-out for ridicule was the use of livestock-guardian animals. Specifically, a few, poor animals that have been left out as examples, on their own, exposed to predators, without proper backup (according to proper livestock BMPs). Committee members were chuckling over their own single-word jokes using the words "llama" and "donkey" in amusing ways in otherwise straight-faced questions and statements. Thom Petersen of the MN Farmers Union, always ready with a good story, recounted the Carlton County extension agent's tale of the two llamas that were killed by wolves on two recent, consecutive nights recently. No one asked about the conditions of their deaths, or why the second llama was left out on the second night, obviously exposed to an overwhelming force, against which it was unable to defend it's farm's livestock, or even itself. Members also found Mr. Petersen's story about the proposal for a "Donkey Cost-Share Program" very amusing. No such proposal appears in the LCCMR catalog for 2014 or 2015. It might be a good one to look for in 2016--with a proper title and integration with livestock BMPs.

Thom Petersen, MN Farmers Union
Thom Petersen, MN Farmers Union: Have you ever noticed how any statement can be made into a joke by adding the word "Donkey" to it?

But let's get back to the topic of scientific livestock production for a moment (just for the purposes of this blog entry, mind you, not twisting any elbows in the Farm Business Management Program or the FFA). Livestock-guardian animals can be effective as one element in an integrated system of livestock BMPs. They can add an alarm and a first level of defense. They can't stand up alone against a pack of wolves, and they shouldn't be put in that position. They need a predator-deterrent fence in front of them, in an area that's kept clean of livestock carcasses, with a second line of defense behind them (e.g. a man with a rifle).

Thom Petersen, in-between his llama and donkey stories, referred Committee Members to "MN DNR help for fencing, and a good spot on their website about things to do." He was apparently referring to the MN DNR "Energized fences" web page about how to keep deer out of gardens, bears out of garbage bins, etc. There is no information on that web page about how to protect livestock from predators. No one challenged his poor reference to this MN DNR information, because everyone wanted to believe it, and nearly everyone would have been happy to "leave it to the DNR" (if that had ever been the DNR's responsibility, and if the DNR had ever done it).

Rep. Paul Anderson (R-Starbuck)
MN Rep. Paul Anderson: Have you ever noticed how any question can be made into a joke by adding the word "Llama" to it?

Then it came time for the public-relations campaign. Let's just title it here "No funding for trappers, no way to defend livestock." Thom Petersen (MN Farmers Union) and Doug Busselman (MN Farm Bureau) carried the campaign in concert. Absent were the USDA Wildlife Services and MN DNR spokesmen who had helped them kick it off on the previous weekend. The principal claim of the campaign is that there is "no funding" for the predator-control trappers that farmers have come to depend upon to remove depredating wolves. 

Doug Busselman, MN Farm Bureau
Doug Busselman, MN Farm Bureau: Woe and Pestilence, sayeth the Commissioner!

The fact is, though, that if there truly were "no funding," it would be a simple matter to restore it. The MN Predator Control Program has been funded in the MN State budget since 2012. It's still in the MN State budget, and the FY2015 funds have not been depleted. The Governor's budget includes continued funding for FY2016-2017. The only thing in the way of the funds is a technicality that could easily be resolved by a clarification in the wording or interpretation of State Statute (see the entry "Here's how to avert a "perfect storm" of funding deadlock for the MN Predator Control Program" in this blog for details on that need for clarification).

Rep. Dan Fabian ended the hearing everyone about his photos of his car thermometer (very cold), a herd of elk near Grygla, MN, and a calf killed by a wolf. He had pointed out throughout the hearing that "farmers don't want to be compensated;" that is, that they don't want to have anything to be compensated for; that they just want to work on raising their crops and their livestock. He illustrated producers' frustration with elk damage and wolf depredation with a story of his wife's feelings about her flower garden. He asked her if it would be okay for someone to come through and tear up her garden, as long as they paid for the damage afterward. "No that's not acceptable to her; she wants to raise her flowers because she likes her flowers." She doesn't want the damage in the first place. 

He was speaking for those who would like to go back to extermination, back to the good old days before the Endangered Species Act and all the talk we hear now about ecosystems, wildlife coexistence, "the farm as a natural organism," a "self-sustaining system," and the like. Back to that wonderful time before cattle were taken by wolves, before fences were broken down by elk, when men could just enjoy their soybeans and their livestock, and women didn't have to file for compensation for the destruction of their flower gardens. 

He was speaking so that the people of Minnesota, and the young people visiting on FFA Day at the Capitol, and on behalf of the Farm Business Management Program should never forget.


MN Rep. Dan Fabian "producers that I know, who live up in NW MN, don't want to be reimbursed; they don't want their cattle killed in the first place." Just like the wife's flower garden, these things should remain inviolate.

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