USFWS: public comment regarding the proposed threatened status for the distinct population
segment of the North American wolverine
To Whom It May Concern:
Thank you for announcing your intent to grant threatened species status to Montana’s wolverine.
As a supporter of Footloose Montana, our state’s lone voice against recreational trapping on
public lands (RTPL), I strongly urge the USFWS to prohibit recreational trapping in critical
wolverine habitat. Trapping has for too long jeopardized the sustainability of Montana’s
wolverine populations, both as a result of the legal quota and as a result of incidental catch.
Results from an analysis of female wolverine trapped in Montana between 1985 and 2005
showed that 49% of the total 83 females trapped during this 20 year period were pregnant at the
time of capture. Among the total 83 female wolverine, thirteen were half-years-old juveniles,
which are sexually immature. If these are excluded from the numbers, the percent of pregnant
mature wolverine trapped was 58.5%. The study extrapolated the average litter size for the
Montana wolverine population given the fecundity results. The average came out to about 2.7
kits. Multiplying this number by the 41 pregnant females killed by traps between 1985 and 2005
shows that roughly 111 unborn wolverine were killed along with their mothers. Each of these
baby wolverine killed in utero could have contributed to future generations of wolverine. The 13
young (6-month old on average) female wolverine killed by traps during this 20 year period
never had an opportunity to reach sexual maturity and bear offspring.
Trapping, unlike hunting, is indiscriminate. Traps are almost always baited, and the bait,
whether pheromones, urine or meat, attracts a variety of species including raptors, pets, and yes,
rare and threatened species. Even the greatest precautions cannot guarantee that a wolverine will
not wander into a trap set for another species. Montana FWP records show several incidental
captures of wolverine in recent years including two from 2012 (one in a Conibear trap and one in
a leghold trap).
Due to its low cost, the most common trap is a snare. Because snares are cheap, trappers can
easily set hundreds, increasing the likelihood of non-target catch and decreasing the likelihood
that each trap will be checked promptly. There is no required trap-check period in Montana, and
the Montana Trappers Association has consistently opposed efforts to institute this requirement.
Both known domestic dog fatalities in Montana this trapping season were a result of snares. In
Idaho, where wolf snaring was allowed, trappers captured 147 non-target animals while catching
123 wolves. Trappers reported that 69 of those non-target animals died as a result. Snares are
lethal and pose a direct threat to wolverine.
Leghold traps are also common in Montana. Although pan tension can minimize the risk of nontarget catch with leghold traps, it is rarely effective, particularly when dealing with a wolverine
which can weigh up to 26 pounds and is larger than many other forest-dwelling furbearers
commonly trapped. Even when properly set, pan tension will fluctuate significantly with
changing temperatures – a common phenomenon in Montana’s mountains. An animal like the
wolverine will easily harm itself struggling in a leghold while a trapper approaches. Releasing a
wolverine from a leghold unharmed is no easy business. There were nearly 60 non-target
captures of domestic dogs in Montana this trapping season, many of them in leghold traps. This
indicates that incidental catch is a common problem. Many of these dogs suffered only minor
injury or were unharmed, but this is because their owners were often present to release them
promptly. Wildlife lingers in traps much longer, and the likelihood of injury thereby increases
dramatically.
Not only do traps catch non-target species, but they also cannot discriminate between males,
females, pregnant females, nursing females, kits, etc. For this reason, when dealing with an
effective population of roughly 40 wolverine in the region, traps can pose an especially
significant threat to population viability.
Futility of Trapping as Wildlife Management Tool
It will no doubt be claimed that eliminating trapping from wolverine habitat is impractical,
because trapping is necessary as a wildlife management tool. Trapping is ineffective in
managing predator and pest populations and disease, especially on public lands, which is where
the prime wolverine habitat is concentrated. By targeting populations with trapping, we are
merely increasing reproductive rates and perpetuating problems.
Predator Control
Despite a 25 year effort to reduce coyote populations through trapping, Maine’s coyote
population has remained the same since 1985. In fact, over the entire continent, coyote
populations are at an all time high despite many generations of trapping. Coyote litters vary
between 1 and 19 pups. Trapped populations increase reproductive rates (frequency of litters
and the number of pups in a litter) drastically to compensate for mortality. Due to this
compensatory breeding, it has been shown that trapping actually leads to higher coyote
populations in the long term. Where coyotes are not trapped (e.g., some National Parks), their
populations densities tend to be lower than in areas where trapping occurs.
In the short term, coyote trapping can cause another problem. If coyotes are removed,
mesopredator populations (smaller predators like raccoon and skunk) often grow overabundant
and lead to management problems (e.g., damage to native ground-nesting bird populations,
conflicts with human use, disease, etc.), which, in turn, are cited by trappers to justify even more
trapping. On public lands, wildlife is better left to self regulate, unless authorities have to
surgically target a local problem due to concerns for public safety or a threatened species.
Wolf management is another example of the futility of trapping. Trapping was recently reinstituted as part of a management regime in Montana. In areas near Yellowstone National Park
most wolf packs had established a firm territory and had an adequate prey base. They were less
likely to depredate on livestock than packs in other areas of Montana, because they had less
reason to disperse or seek new food sources. Instead of focusing their efforts on problem
animals and areas where conflicts are more likely, recreational trappers conveniently targeted the
Yellowstone area and killed many of the alpha individuals and all of the GPS-collared wolves.
As a result, without the older, dominant animals, the subdominant and younger wolves will
likely compete in a struggle for a new hierarchy, will breed more (typically only alpha
individuals breed), and conflicts will push younger, inexperienced animals from their established
territories. These will disperse into areas where human-wolf conflicts will rise. Thus, by
destabilizing pack structures, trapping may do more harm than good. Moreover, without collared
animals, scientists will be less well positioned to predict potential conflicts and mitigate them.
Pest Management
RTPL is similarly impractical in pest management. In Washington State, wildlife authorities
have tried to use private recreational trapping to control nutria, an introduced exotic species, but
nutria pelt prices are so low that trappers do not care to trap them. Instead, they target the native
species whose populations are smaller and whose pelt prices are accordingly higher.
The most commonly trapped “pest” species is the beaver. Beaver populations self regulate.
After colonizing a new area, populations grow quickly, but they subsequently drop to about 25%
of the peak population. Trapped colonies show a higher reproductive rate, so they often end up
being larger than self-regulating colonies in the long run, unless trapping is continuous and
pervasive, which is always costly (both financially and in terms of unintended consequences).
Most importantly, beaver provide vital services in an arid state like Montana. It makes a lot
more sense to employ beaver deceivers (non-lethal devices that prevent beaver from damming
sites like culverts), to relocate beaver, or to find other creative ways to coexist with them,
because they provide valuable services: water quality and availability for fish, for livestock, for
fire suppression, riparian habitat for birds, waterfowl and ungulates, etc.
Disease
Private trappers have no incentive to trap diseased populations (their incentive is pelt prices, and
pelts of diseased animals are rarely worth anything), and even if they did, traps cannot
discriminate between diseased and healthy individuals. Invariably, more healthy animals are
caught. In fact, trapping has occasionally made disease problems worse by increasing dispersal
rates. Brian Giddings, director of the Montana FWP trapping program, has said: “Neither FWP
nor I have made claims that there is scientific information that addresses the relationship between
recreational trapper harvest and disease control.....FWP regulates furbearer trapping seasons for
recreational harvest opportunities. Montana’s harvest seasons are not based on reducing or
controlling diseases.”
Conclusion
RTPL is different from targeted uses of trapping to address management needs or problems.
Recreational trapping is driven by pelt prices, and recreational trappers have no incentive to
target specific problem populations or individuals. Most management needs occur on private
lands where wolverine rarely venture. Agency employees have no private economic incentive in
trapping, so they are best positioned and trained to trap safely and efficiently targeting specific
problems while minimizing the risk to wolverine. Far from being an effective wildlife
management tool, recreational trapping on Montana’s public lands actually does significant harm
to wildlife and creates far more problems than it solves. It exacerbates existing problems and
creates new problems where none previously existed.
Please grant full threatened protection to our regional wolverine population. Furthermore, please
eliminate recreational trapping from important wolverine habitat in Montana. Recreational
trapping is an economic net loss to our state and to our state wildlife agency, and it does not
provide any necessary services on the state’s public lands. Thank you.