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Leech Lake Band of Ojibwe

Peter D White, Chairman
Arthur "Archie" La Rose, Secretaryareasurer

District I Representative Distnct 11 Representative Thstnct 111 Representative

Burton "Luke" Wilson Lyman L Losh Richard Robinson, Jr

RECENED
Aug. 8, 2003 , Region 3

Ron Refsnider, Endangered Species Coordinator AUG 2 1 2003

US Fish and Wildlife Service U.S. FISH AND WLDLIFE SERME
Whipple Federal Building Ecological Services
1 Federal Drive, Ft. Snelling, MN 55111

Dear Mr. Refsnider,

In a recent letter the Fish and Wildlife Service requested information on the stRuis of the
gray wolf on the Leech Lake Reservation and any concerns and issues the tribe has over
the proposal to deist the wolf. The gray wolf is an animal of cultural importance to
many tribal members who live on the reservation and, due to its limited numbers on the
reservation, one that will take sotne special efforts in preventing its loss. A few years
back when reclassification, delisting,„ and the Minnesota Wolf Roundtable were initiated
err..
the Reservation Tribal Council, in concurrence with the tribal Natural- Resources
Advisory Committee, discussed the wolf issue and passed a Tribal Council Resolution
with the following position statement, which we continue to support

It is the position of the Leech Lake Reservation Tribal Council that the harvest of
gray wolves for sport or recreation b an inappropriate use of an anhnal we share
the Mother Earth with. We do, however, respect -the - individual tribal member's
choice io harvest an animal if it Ls done in a respectful manner and does not
negatively impact the gray wolf population, and if the animal is used for traffitional
or spiritual purposes.

lt appears that once the wolf is delisted the State of Minnesota will push for some type of
sport harvest. Any time you. have cultural differences over the value and utiTization of a
resource between trilal members and the general population you are setting up a situation
in which there will be conflict. This is why the USFWS, as a federal agency with tmst
responsibility to uphold the treaty (property) rights that the tribes never relinquished
under federal treaty, must assure that the state develops management strategies that will
accommodate the interests of the tribe for resources within our boundaries. To this end
we would lace to see the Leech Lae Reservation become a separate management area
where the wolf population would be co-managed with the state. We currently do this for
deer and some fish species, and would Ile to do it for more species.

6530 U S 2 NW • Cass Lake, Minnesota 56633

(218) 335-8200 • Fax (218) 335-8309
Email 11pr@paulbunyan net
 The Reservation's Conservation Code currently forbids the taking of "timber wolves", so
a major revision of the code would be needed for any take by tribal members. We have
been attempting to get needed code revisions implemented for the past 4-5 years, but it is
a fairly arduous process involving the USFWS, Bureau of Indian Affairs, Minnesota
Department of Natural Resources, and the TrilsaI Council. Until this revision is
undertaken we do not know what, if any, harvest would be allowed, what nurnbers it
would consist ot or how it would be implemented. Due to the limited nurnber of wolves
on the reservation a sustainable harvest may only be 10-20 animals per year, which
would probably have to be divided between tribal and state harvest Currently all the
wildlife species on the reservation are either available to all members or to none.
Establishing a harvest in which only a limited number of members would be able to
participate will take some time to establish. If some type of harvest for cultural purposes
is established for tribal members, the reporting of harvest would be conducted in much
the same way as it is currently done for other furbearer species.

In your letter you bad also inquired about how wolves involved in livestock or pet
depredation would be handled. This has really never been an issue on the reservation as
there is virtually no livestock production nor are we aware of any pet losses. I talked
with USDA Wildlife Services about a year ago and as of that time they could not recall
ever taking any depredation wolves from within the reservation boundaries.

An estimate of the gray wolf population on the reservation was also requested in your
letter. There are no current surveys for gray wolves on the reservation so our estimates of
population are based on the two scent post routes we run each year, along with our
observations and those of tribal members. Gray wolf populations on the reservation
plummeted after the deer die-off that occurred during the very cold winters of 1995 and
1996. Although deer numbers are up again, the wolf numbers are still down, based on
our observations. Prior to 1995 we would pick up gray wolves in both of our scent post
survey routes almost every year, but in recently years we only pick them up sporadically.
Our staff have not observed rnany wolves in recent years and we haven't received many
reports of wolves.

Another indicator is that in recent years we haven't fielded many questions about wolf
population effects on deer numbers. A variety of explanations has been put forth as to
why wolf nurnbers have not increased even though deer numbers are back up. Warm
winters have enabled deer to be in better condition and less vulnerable to predation by
wolves. The lack of deep snow during the same period put the wolves at a disadvantage
in their ability to catch deer. Human induced mortality from vehicle collisions, accidental
trapping, and shooting by deer hunters are also factors that are difficult to account for.
The factor that is currently thought to be the most lady cause of slow wolf population
increase, however, is the outbreak of mange that has been seen in many wolves, at least
locally. Of the 3-4 wolves that were trapped or illegally killed locally, all but one had
fairly heavy cases of mange.

Locally at least, we question the figures put forth as to the number of wolves found in the
state, and feel we that it is imperative, as part of the delisting process that another
comprehensive survey of Minnesota's wolf population be conducted. Only by doing so
can you get an accurate number to be used as a baseline for future population monitoring.

As to the number of wolves and wolf packs on the reservation, we can only base our
estimates on the amount of potential habitat and monitoring work conducted by various
researchers. The reservation, excluding large water bodies, potentially has about 600
square miles of gray wolf habitat., but many areas would not be considered prime habitat
due to development and other factors. Studies have found that wolf packs in Minnesota
will occupy and defend territory of anywhere from 36 to100 square miles, so if we use a
figure of 50 square miles we could potentially have about 12 packs. In reality probably
over half of the potential packs will have territories that extend outside the boundaries of
the reservation Using an average pack size of 5.4 wolves per pack, the reservation could
potentially be home to about 65 (plus or minus 30) wolves. Due to the mange outbreak
the validity of this figure is questionable, which reemphasizes the need for an updated
population count.

Another factor we think the USFWS should evaluate is the value of gray wolves as a
means of providing some control of white-tailed deer numbers. Although this is a
discussion we would not have had even 10-15 years ago, we think it is becoming more
and more pertinent. It is projected, and the survey data seems to be bearing it out, that
the percentage of people who hunt in the US is on the decline. As the baby-boomers get
older and stop hunting and there are fewer young people taking it up, declines will be
even greater. Many states out east and even Michigan, Wisconsin, and parts of
Minnesota already have higher numbers of deer than they know what to do with and it
does not appear that in many locations hunting is going to control them. These deer are
having a profound affect on native vegetation, and other species of wildlife that need
these habitats. Here on the Leeeh Lake Reservation, while many tribal members like to
hunt and eat deer, we have others who are wondering what is happening to all the
traditionally gathered and medicinal plants. Although wolves may not be able to control
deer numbers in many locations, we think you need to explore their potential in areas
where they may be a factor.

We appreciate your interest in our comments and concerns over the gray wolf.

Since1y,

Peter hite, Tribal Council Chairmen

Leech Lake Band of Ojibwe

cc: John Leonard, USPWS Tribal Liaison