Wolf-Livestock Related: Deaths: Confirmed 104 Probable 13 Possible 21

1. Catron County Investigation Results of Wolf-Animal and Wolf-Human InteractionsApril, 2006 to present Wolf-Livestock Related: Deaths: Confirmed 104 Probable 13 Possible 21 Injuries: Confirmed 19 Probable 2 Possible 6 Missing: Probable 3 Possible 3 Livestock Total 174

2. Wolf-Pet Interactions: Deaths: Confirmed 5 Injuries: Confirmed 3 Pets Total 8 Wolf-Animal Interactions on private property: 81 Wolf-Animal Interactions on non-private property: 107

9. Wolf-human Interactions Total Wolf-human interactions 154 Wolf incidents on Private Property 110 Wolf Incidents on non-private property 44

12. Wolf-Animal/Wolf-Human Interactions Combined Wolf-Animal/Wolf-Human incidents 347 Wolf incidents on private property 189 Wolf incidents on non-private property 158 The wolf incidents on private property illustrate a high degree of wolf habituation. A habituated wolf seeks out humans and human use areas and lacks the characteristic avoidance response of a wild wolf.

13. Psychological Trauma Bold/fearless wolves coming to homes Wolves killing/attacking pets at homes with children watching ( 8 confirmed incidents) Bold/fearless wolves approaching children

20. Translocation of Problem Wolves (11) Wolves, with no evidence suggesting that they are part of the MWEPA, that fail to respond to aversive conditioning (i.e., continue to display the same nuisance or depredation behavior over a period of six months despite aversive conditioning efforts) can be translocated within the management zone or to other management zones, Mexico or the BRWRA, with coordination and input by the Service and appropriate jurisdictional agencies, or Mexico, with approval from the Mexican government, where the behavior is less likely to continue. Mexican wolves dispersing out of the Blue Range Wolf Recovery Area, un-identified Mexican wolves become “Wild Wolves” Canis Lupus, Full endangered status. Mexican wolves becomes one and the same as Canadian wolf – Canis Lupus Occidentalis

21. Excerpt 1.3, Southwestern Gray Wolf Management Plan  Gray wolves from the Northern Rocky Mountain population have been documented in Colorado, <200 miles north of the New Mexico border (74 FR 15128, April 2, 2009). Dispersal into, and natural re-colonization of, areas of suitable habitat in northern Arizona and New Mexico (north of Interstate Highway 40) where gray wolves are listed as an endangered species may occur from the Northern Rocky Mountain Distinct Population Segment (NRM DPS) of wolves. Unmarked, unidentifiable wolves from the BRWRA population of Mexican wolves could also contribute to naturally re-colonizing populations of wolves in these areas of Arizona, New Mexico and western Texas that are outside the MWEPA.

22. Translocation of Problem Wolves (11) Wolves, with no evidence suggesting that they are part of the MWEPA, that fail to respond to aversive conditioning (i.e., continue to display the same nuisance or depredation behavior over a period of six months despite aversive conditioning efforts) can be translocated within the management zone or to other management zones, Mexico or the BRWRA, with coordination and input by the Service and appropriate jurisdictional agencies, or Mexico, with approval from the Mexican government, where the behavior is less likely to continue. Canadian wolves (Canis Lupus Occidentalis) dispersing into Arizona, and New Mexico from the North. These wolves will mate and bring genetic rescue into the Mexican Wolves (Canis Lupus Baileyi). “Translocation” is the key for genetic rescue and the artificial advancement to disperse wolves to all zones, Mexico and the BRWRA.

23. Translocation of Problem Wolves (11) Wolves, with no evidence suggesting that they are part of the MWEPA, that fail to respond to aversive conditioning (i.e., continue to display the same nuisance or depredation behavior over a period of six months despite aversive conditioning efforts) can be translocated within the management zone or to other management zones, Mexico or the BRWRA, with coordination and input by the Service and appropriate jurisdictional agencies, or Mexico, with approval from the Mexican government, where the behavior is less likely to continue. The Canadian Wolf = Canis Lupus Occidentalis, and the Mexican Wolf = Canis Lupus Baileyi both become Canis Lupus in Zone 1. As a problem wolf, they can be translocated anywhere in Zone 1, Zone 2, Zone 3, Mexico and the Blue Range Wolf Recovery Area.

24. “Major Problems” in the Southwestern Gray Wolf Management Plan HUMAN HEALTH/PUBLIC SAFETY 4.4.1 Potential Environmental Impacts and Proposed Mitigation Measures No studies have been conducted, and there are no data available for an evaluation, as to whether the reintroduction of wolves into the BRWRA has, or has not, had a positive, neutral, or negative psychological effect on children living in the rural counties proximate to the recovery area. Psychological trauma, PTSD has been documented in our children due to wolf interactions at homes. Positive protective measures need implemented to protect children. DNA Testing All wolves located in the management zones 1, 2, and 3 need to be DNA tested and held in captivity to identify Canis Lupus Baileyi status. Once determined the wolf is identified as Canis Lupus Baileyi it will be returned to the Mexican Wolf Recovery Area. Non-lethal Techniques  Non-lethal Techniques do not work, or only work a very short time ( one to one and a half weeks). Scare devices like fladry, boom boxes, taste aversion, hazing, and the like have not worked in the past 14 years of Mexican Wolf Management. There is no positive action that can be used to stop wolves from killing livestock, pets or habituated wolf behavior other than “removal”. The use of non-lethal techniques keeps the problem wolves on the ground where they continue to be problem. The USFWS knows this, but continue to use these schemes. Taste aversion was used on coyotes and was found not to stop coyotes from depredating sheep. No Canadian Wolf translocations  No Canadian Wolves (Canis Lupus Occidentalis) can be translocated in Zones 1, 2, 3, Mexico or the Blue Range Wolf Recovery Area.

25. Wolf Caused “Chronic Stress” in livestock • Negative effects beyond wolf-caused mortality • (Not Addressed in Plan, No Compensation) • The negative effects to livestock producers caused by Mexican Wolves are a wide spectrum not addressed and/or ignored by the US Fish and Wildlife Service. Prior negative data and documentation of wolf recovery from other states were not utilized to mitigate the same negative effects of Mexican wolf recovery in New Mexico and Arizona. Wolves continually killing, prey testing in a herd produces chronic wolf stress in cattle. • Chronic wolf-caused stress in cattle leads to: • Loss of body condition • Cows birthing weak calves • Pre-mature birth of calves • Abortion of calves • Immune suppression • Decreased pregnancy rates-open cows • Increased susceptibly to disease • Weight loss, and wolf attacks • Alters the demeanor of cows from docile to aggressive. • True livestock losses are not reflected in confirmed and probable investigative findings; • Few livestock depredations are actually compensated; • Cumulative effects of wolf predation makes livestock production untenable; • Impact on individual family ranchers is devastating, even though the impact to the entire livestock industry of the state may be small; • Wolf depredation disrupts grazing management plans; • Increased uncompensated hours tending injured calves; • Increased uncompensated hours checking livestock; • Increased uncompensated hours mending fences when wolves attack/run livestock through them; • Increased uncompensated hours gathering livestock and returning to proper pasture; • Loss of market value for maimed and disfigured calves; • Loss of replacement heifers/production; • Loss of revenue while new herd takes several years to acclimate; • Loss of revenue while replacement heifers take three years to acclimate into an existing herd.

26. Livestock Carcass Removal (d) Intentional feeding of wolves must not have occurred. Accepted livestock and carcass management practices would not be considered intentional feeding. However, livestock carcasses not properly disposed of in an area where depredations have occurred may be considered attractants by the Service (see Appendix I). On Federal lands, removal or resolution of such attractants may accompany any control action, if deemed necessary by the Service. The Service may choose to not implement control actions or designate the wolves as Problem Wolves if livestock are not removed at the request of the Service. Comment: Mexican wolves in the Blue Range Wolf Recovery Area are supplementally (diversionary feeding) fed with horse meat by the US Fish and Wildlife Service wolf recovery team which leads to habituation and has contributed to scavenging behavior. Environmental Justice Minority and low-income populations in those portions of Arizona, New Mexico or Texas within the action area would not be directly affected or disproportionately burdened by the Proposed Action. Comment: This is a False Statement, small family ranchers have gone out of business, having to sell their ranches. Catron County Recommends: No Action Alternative: We (USFWS) would not implement the Southwestern Gray Wolf (Canislupus) Management Plan for Portions of Arizona, New Mexico and Texas