May 30, 2014
Public Comments Processing, Attn: FWS-R7-ES-2012-0093
Division of Policy and Directives Management
U.S. Fish and Wildlife Service
4401 N. Fairfax Drive, MS 2042-PDM
Arlington, VA 22203
Via: http://www.regulations.gov
To Whom It May Concern,
The Resource Development Council for Alaska, Inc. (RDC) is writing to comment on the petition to list the Alexander Archipelago (AA) wolf (Canis lupus ligoni) as a threatened or endangered species under the Endangered Species Act (ESA).
RDC is a statewide, non-profit, membership-funded organization founded in 1975. The RDC membership is comprised of individuals and companies from Alaska’s oil and gas, mining, timber, tourism, and fisheries industries, as well as Alaska Native corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to link these diverse interests together to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.
RDC believes the information provided in the petition to list the AA wolf is highly speculative and does not warrant a listing as endangered or threatened under the ESA. Further, we are concerned the petition to list this animal is not out of fear for the future existence of wolves or their habitat in Southeast Alaska, but rather an attempt by environmental non-government organizations to halt what logging still remains in the region.
The petition asserts that “large scale logging on the Tongass National Forest (TNF) and private and state lands poses a primary threat to the AA wolf…”. This misleading statement ignores the fact that only four percent of the entire 17 million acre TNF is available for harvest. In other words, 96 percent of the TNF is closed to logging, and of the available commercial grade forest, 75 percent is protected under the current forest plan, otherwise known as the Tongass Land Management Plan (TLMP). The vast majority of the forested land in the TNF will continue to remain untouched, allowing for ample habitat of the AA wolf.
The current TLMP also adequately addresses concerns raised in the petition regarding habitat of the AA wolf’s primary prey, the Sitka black-tailed deer. The petition suggested that the flora and fauna the deer forage on are shaded out by young growth for up to 160 years, however, only 60 years have passed since the original large-scale harvesting of timber began, and the deer numbers have remained at sustainable levels. Furthermore, the current TLMP has added additional reserves for old-growth, beach fringe buffers, and management guidelines that require additional set-asides in areas that have been previously harvested. Together, the old-growth set-asides comprise 90 percent of the existing high-volume old growth on the Tongass.
The Interagency Wolf Task Report, published May 21, 2014 by Alaska Department of Fish and Game (ADFG) states: “It is particularly important to stress that…regulated harvest of wolves on Prince of Wales Island provides a mechanism to facilitate more-rapid deer recovery after high winter mortality.” The report continues, “…State and Federal partners have worked together to avoid the need to list species many times. It is reasonable to expect that agencies will indeed work to conserve wolves and avoid listing.” RDC echoes these statements and believes ADFG has historically sustainably managed wolf and deer species and can continue to in the future through existing means such as adjusting season or bag limits by the Board of Game.
The petition also suggests that the AA wolf should be considered a subspecies, however, there are no standard criteria for naming subspecies. The subspecies designation is a highly subjective process in which any number of characteristics can be chosen, and then a designation based off of them. In this case, the characteristic being narrowed in on is geography. Even if the geographic range of an animal were a suitable characteristic to define a subspecies, the AA wolf has been tracked following distances down into British Columbia, up to Southcentral Alaska, and even swimming for miles in between islands in Southeast.
Finally, it has been suggested by U.S. Fish and Wildlife Service that there is concern the wolf populations are being negatively impacted by forest roads and the access to hunters and trapper these roads create. Wolf and their primary prey have survived and thrived during periods of time when logging levels were thirty times higher than the logging taking place today. In addition, the U.S. Forest Service has enforced hundreds of miles of road closures since 2010. There are more roads being closed each year than there are new roads being built.
In closing, RDC would like to reiterate that we do not believe there is sound science behind the petition to list the AA wolf and therefore oppose this listing. We encourage you to allow the state and federal agencies to continue working together, as they have in the past, to keep this listing from moving forward.
Thank you for the opportunity to comment.
Sincerely,
Resource Development Council for Alaska, Inc.
