List on an Emergency Basis Alexander Archipelago Wolves

Dear Mr. Zinke and Mr. Siekaniec,

Recently, the Ninth Circuit Court ruled in favor of the U.S. Forest Service in a lawsuit over the Big Thorne timber project on Prince of Wales Island. The project will log almost entirely remnant old-growth stands that are vital to the fate of deer and wolf populations in the area as well as many other species.

Prince of Wales Island is the most heavily logged part of southeast Alaska, with the Forest Service disregarding and circumventing its road density standard and guidelines, creating a high road density which goes hand in hand with uncontrollable wolf poaching. Big Thorne’s 46 miles of new roads will add to 580 miles in that project area already with another 37 miles which will be reopened or reconstructed putting the wolf at even greater risk.

Clear-cutting over 6,000 acres of rainforest will destroy coastal old-growth forest habitat which supports rare and unique species of fish and wildlife. Destroying critical habitat that the Alexander Archipelago wolves and their prey, Sitka black-tailed deer, depend on will compromise their ability to survive.

In 1994, the state estimated there were over 260 wolves living on Prince of Wales; today there are far less than 100.

As you already know, the Prince of Wales wolf population declined 60% in just one year from 221 individuals in 2013 to 89 wolves in 2014 with another 29 wolves killed during the 2014-2015 hunting and trapping season, leaving as few as possibly 60 individuals. Please remember these numbers indicate reported kills only.

Steve Brockmann, a federal employee from USFWS, indicated that there is evidence which suggests that the continuing decline of wolves on the island has to do with over-harvesting.

Jump ahead to the 2016-2017 season, and again, 28 wolves were killed from this already tiny population! The quota was set at 11. Again, this total indicated just the reported kills; the total loss to the population is more than likely much higher.

It is obvious that logging and road construction will trench on the habitat of the Alexander Archipelago wolf. This rare wolf preys on a species of deer that thrives in the old-growth rainforest, which provides suitable shelter and forage during periods of heavy snow. A smaller forest will support fewer deer, which, in turn, will support fewer wolves. The new roads will compound that effect by letting wolf and deer hunters range
deeper into the forest. Even before Big Thorne was approved, the project area had insufficient habitat capability to support the guidelines of 18 deer per square mile. The road densities were also above the recommended maximum guidelines.

Clearly, The NFMA’s regulations (at the time of the Forest Plan) which required that National Forests "be managed to maintain viable populations of existing native and desired non-native vertebrate species" have been disregarded. This regulation defined a viable population as one with "enough reproductive individuals to insure its continued existence is well-distributed in the planning area".

The Forest Service Plan does not, by any means, safeguard the continued and well-distributed existence of the wolf on Prince of Wales Island. Presently, the wolf population on POW is neither sustainable nor viable; the situation will be further exacerbated by the Big Thorne project.

Judge Gould, of the Ninth Circuit Court of Appeals, dissented* from the majority in the case against Big Thorne:

"The agency’s assessment of the plight of the wolves in the Tongass National Forest is in my view inadequate. In the mid 1990s, 250–350 wolves were thought to inhabit the Alexander Archipelago. The Big Thorne project area, located on the Prince of Wales Island, had sufficient habitat to support 45–50 wolves, making up three separate packs and a portion of a fourth pack. A project, funded primarily by the Forest Service, estimated that by fall 2012, only about 29 wolves and only two packs remained in the Big Thorne project area. By spring of 2013, researchers could only account for a mere six to seven wolves left in the project area. Another researcher observed that “numbers seem to indicate that the population of wolves
in the central portion of Prince of Wales Island is approaching zero.”

The Alexander Archipelago wolf and the Sitka black-tailed deer, as the Forest Service explained, are closely interrelated. Survival of the wolves depends on survival of the deer on which the wolves feed, which in turn depends on maintenance of the old growth forest habitat on which the
deer depends. Deer populations depend on a sufficient quantity, distribution, and quality of winter old-growth habitat. It is inescapable that logging reduces this habitat. The Forest Service, aware that wolves depend on deer for their survival, and that those deer to survive depend on old growth forest habitat, has stressed that maintaining sufficient deer habitat capability, and thus greater number of deer, was “the most important factor” in sustaining wolf viability in the
Tongass National Forest. In fact, the destruction of deer habitat capability is, as the agency has explained, “the most
important factor limiting wolf viability.” Yet the Forest Plan does not support deer habitat capability numbers, and nothing
in the record supports the Forest Service’s contention that viable wolf populations will remain relying on the other two
prongs of habitat reserves and wolf mortality management."

This drastic decline in numbers must be arrested and a recovery plan should be immediately established. Without ESA protection the Alexander Archipelago wolves fate will be sealed; extirpation will be imminent. Further evidence of a dire situation was proven in 2015, when ADF&G during their field season in the spring, visited approximately a dozen known den sites and found just one active den, with only one pup, indicating either entire wolf packs had been wiped out or had been decimated to a point leading to their fragmentation.

Threats to this unique subspecies are amplified because the wolf represents a distinct and isolated gene pool and now very few individuals remain. The Alexander Archipelago wolves are isolated and genetically distinct from other North American wolves because of tidewater barriers and coastal mountains that limit migration to the rest of the continent. The GMU-2 population is further isolated and may be genetically distinct from other Alexander Archipelago wolves. Scientific evidence determines that coastal wolves endemic to temperate rainforests are diverged from neighbouring, interior continental wolves; a finding that demands new strategies must be taken managing this species if they are to survive.

On September 28, 2015, the Service indicated that they would continue to evaluate the status of the Alexander Archipelago wolf as part of a settlement agreement and that "if at any point we determined that emergency listing was warranted, an emergency rule may be promptly developed". In light of a steep decline, and loss of another 28 wolves on POW last season, we feel emergency measures are warranted.

Enough is enough, we the undersigned believe it is far past time to give the Alexander Archipelago wolves (Canis Lupus Ligoni) the protection they need under the ESA. We urge you to take emergency action on behalf of the few remaining wolves on Prince of Wales Island.

*Judge Goulds' full statement can be read here (See pages 21-27): bit.ly/Big_Thorne