New Mexico Federal Lands Council
Gila Livestock Growers Association
P.O. Box 111
Winston NM 87943
President: Laura Schneberger
Vice President Matt Schneberger
Secretary Treasurer: Stephanie Bason
Director At Large: Kit Laney Catron
Director At Large: Tom Klumker Glenwood
Director Black Range: Jack Diamond
Director: Silver City: Alex Thal
Director Luna District: Alvin Laney
Director Glenwood District: Joe Nelson
Director Reserve District: Charlie McCarty
US Fish and Wildlife Service
New Mexico Ecological Services Field Office
2105 Osuna Road, NE
Albuquerque NM 87113
Attention:† Mexican wolf Project:
Re: 5 year review recommendations comments
April 12, 2006
Dear Interested Party,
Please incorporate these comments into your analysis of the 5 year review recommendations our members believe that they are essential to preserving the civil rights of our members who live and run livestock in the Mexican Wolf, BRWRA and will become essential to protecting those who do not yet have to deal with wolves.
We recommend extending the comment period for the 5 year review recommendations time frame by 30 days.† The seasonal workload on the local people and businesses most affected by the Mexican wolf, has not allowed most locals a chance to become familiar with the recommendations and the methods for participating.
Our recommendations are as follows.† Replace the AMOC with people who are willing to include local concerns and issues and plan mitigation of civil rights and takings violations occurring in the current program.††††
We also recommend the service include local interests in a new AMOC, the current AMOC is made up of only large government interests and rigidly resists mitigating problems within the current program.† Both of these requests are based on EO Executive Order Facilitation of Cooperative Conservation, signed by President Bush in New Mexico in August of 2004.† Any planning currently in progress, including 5 year review recommendations, that does not recognize this EO is clearly a violation of congressional and presidential intent as it relates to the equal treatment of local interests in conservation practices.
Re: Number 4 in the recommendations document. Refusal to recognize White Sands Missile Range as a viable alternative for any kind of wolf management is limiting the services alternatives in implementing wolf management.† WSMR may very well be an ideal spot to fence in animals that may not be ideally suited for release or re-release into the wild population where there is the potential to keep problem animals away from human and livestock encounters.† The service should never write into a document limitations on management tools.
RE: Number 5 in the recommendations document.† Making determinations solely on ecological and biological grounds will result in a plan that is biased against local needs and should not be recommended.† Any decision on whether the MWEPA is expanded and where should consider fully a broad range of issues not just ecological and biological.† This kind of limited thinking is exactly why the current rule has become impossible to follow.† It is impossible to create a workable plan based on narrow determinations.† Social and economic values and implications both to local residents and communities as well as the Mexican wolf program, should be given equal weight in making determinations as to whether and how to recommend re-definition of the MWEPA and or BRWRA.
Part b of number 5 should be removed, there are already far to many teams and groups associated with this program so many in fact that it has become impossible to get a straight answer from anyone associated with the program.† We recommend a new AMOC giving equal interests participatory status and simply allowing that group to make recommendations.
We believe the entire Number 5 recommendation is written to exclude equal representation by local interests and that the service is obligated to include the local communities in any and all decision-making processes to mitigate the disproportionate burden these communities are bearing from the current practices and recommendations of the IFT, AMWAG and AMOC.
RE: Number 6 the words (at least) should be removed.† Goals should be clearly stated and adhered to without surprising changes along the way.† It could and has in the past become all too easy for the service to simply decide to expand their goals if they see fit. The general public deserves to know ahead of time what the goal is and how it will be reached.†
In addressing a rule change, clearly defined delisting and recovery numbers need to be determined and stated in any proposed rule change.
RE: Number 7 there is nothing at all in this recommendation that addressed determining the number of wolves already In the BRWRA and beyond it. This should be addressed and noted.† The statement (other appropriate contiguous areas of suitable wolf habitat) should insert wording to exclude any and all private land unless the landowner is amenable to having his property defined as appropriate habitat.† We also disagree with the SOPís that allow the release of livestock depredators at all, and disagree with allowing a three strikes policy that was made with no public input,† as well as releasing wolves with depredation history at all much less after being held in captivity for one year.† These policies need to be addressed and changed to mitigate ongoing problems in the program.† It is our stand that the service is manipulating the rule through arbitrary and capricious policymaking behind closed doors and those policies are significant contributors to the civil and takings violations occurring in the BRWRA.
RE: Number 8 & 9.† These recommendations appear to be deliberately confusing and as they have very little information defining the proposed BRWRZ or the MWEPA or anything remotely explaining the thought processes behind new translocation areas,† that will be clear to the public, it should re-written with appropriate and clear information or be stricken entirely.† No livestock depredating wolves should be available for translocation no matter where the boundaries are.† This policy creates disproportionate hardship and civil violations for local citizens.†
It is our opinion that this policy has been created out of whole cloth and implemented without adequate public review and has proven harmful to stakeholders.† This is not the first or last time we have commented on this policy and we believe the service has deliberately ignored the consequences that have arisen from their three strikes and translocations policies.†
RE: number 10:† This recommendation redundant.† The permit to control depredating wolves issue has already been addressed and approved in the current final rule and has proven impossible to implement.† Even when the over burdensome criteria were met, permits were not forthcoming and ranchers continued to suffer depredation contributing to a significant violation of the private rights. Even then, current rule requirements appear to be much more flexible, as they clearly state that private landowners may kill a wolf in the act of attacking livestock on private land.† This recommendation appears to undermine that portion of the current rule.†
The service is going backwards.† It needs to lower the current rule standards relating to lethal take permits and apply them to federally administered grazing allotments where legally run privately held livestock are grazed and legal private interests are held, as well as to private landowners.† With the stipulation the other species of privately owned animals may also be protected from attacking wolves.
Simply burdening private landowners further and spreading the misery to them is not mitigation for the growing livestock depredation problem by Mexican wolves.††
RE: Recommendation 11
The service cannot and/or will not count wolves currently on the ground in the BRWRA, nor do they adequately investigate sightings beyond the BRWRA.† Raising the initial number of wolves to be documented in an arbitrary and undefined experimental population area is hardly consistent.† This recommendation will require a Rule change that specifically defines the scope of these actions as well as the criteria for what can be determined locally unacceptable livestock depredations.††††
RE: Recommendation 12† (AMOC may convene, if necessary, a technical advisory group,) should be stricken and in itís place wording should be placed that any such action determining the necessary information for an incentives program will be made by a technical advisory group with appropriate expertise.† AMOC should not determine the makeup of such a group to do so would be a conflict of interest.
Total removal of grazing fees will not begin to cover the costs the program has had on individual ranchers.† Adjustment is not an adequate mitigation proposal and will not begin to cover the costs associated with the discussion items listed.† This recommendation appears to open the doors for service personnel to include discussion of private business practices and economic concerns in public documents forthcoming for public comment and this recommendation should be re-written with protection of the privacy rights of individual ranchers.†† These issues should never be discussed with an AMOC approved technical advisory committee.† Ranchers are already overburdened with federal requirements relating to this and other federal programs.† These issues should be handled legislatively with a compensation package.† Compensation should relate to losses reported and compared to pre-wolf data with no strings attached.
RE: 12 a. AMOC currently has no members that have any expertise in the economic impacts of wolf recovery.† They have no business heading any group much less choosing
RE: 12 b. This is total overkill, None of the current Mexican wolf personnel should be involved with this issue.† AMOC has no business defining mechanisms to address private business practices.† Compensation for take of private property is also not an AMOC issue.† If the services personnel or AMOC are to be involved to this extent, then funding needs to come directly from the service.† It is a conflict of interest for AMOC or the service to become involved in compensation or anything relating to costs associated with the recovery.†
The AMOCís only job is to admit to the problem and recommend congress and the states determine a solution.
RE: number 18.† Enhancing genetic diversity is simply not an option within this population unless hybridism or breeding with northern wolf population is condoned.† Further releases citing the need for genetic diversity are not necessary and amount to misinforming the public about the minimal genetic material in the Mexican wolf population.
RE number 24, There is no date specifying when this educational program will be implemented, without a date it will likely not be implemented and education of the masses as usual will continue as is. Also, there appears to be no planning for coordination with appropriate experts involved in both the social impact issues and both positive and negative aspects of the reintroduction and wolves on the landscape.† This indicates that any program developed will be biased and un-objective.
RE: number 28, Due to a severe lack of adequate communication over the course of the past 8 years the program has been in place we recommend this communications training recommendation be undertaken immediately.
RE: number 34, Our recommendation is to advise AMOC to give special consideration to those interests who struggle day to day under this program and suffer a disproportionate Impacts from the effects of this program.†
Those entities, namely private property and livestock owners, should be given reasonable status in planning opportunities.†††††
RE Number 37, It is our recommendation that funding of this program be withheld until some major changes and mitigation of chronic problems are corrected and the IFT and AMC can demonstrate that the Rule whether current or future, can be implemented without being consistently broken.† More money will not solve management problems. Nor will it help biased and unbalanced planning that do more harm that good.
†It is our recommendation that the Mexican wolf program be terminated until such a time as the above cited practices are changed and realistic mitigation efforts are made to solve the current ongoing livestock depredation issues, and civil rights violations against the local residents of the BRWRA.†† It is our opinion the most of the 5 year review recommendations are simply ways to relieve the service of their responsibilities to the local residents and this attitude within the program personnel should not prevail.
President Gila Livestock Growers Association