The Wisconsin Department of Natural Resources (WDNR) recently released their updated Wolf Management Plan (WMP), which will guide all management and efforts related to wolves in the state. As wildlife advocates and scientists that have been engaged in the process for years, scrutinizing both the use of scientific evidence in the plan and the WMP’s update process, we feel the responsibility to publicly denounce that the process has not been “transparent, deliberative, [or] inclusive”, as stated on the WDNR’s WMP website. What has transpired instead is an undemocratic, unscientific, unethical, and institutionally racist process that has prioritized the desires of individuals that want to kill wolves for entertainment or revenge. As a result, if federal Endangered Species Act (ESA) protections are removed for wolves, they will once again have a target on their backs in our state, to the detriment of not only their wellbeing, but that of Wisconsin ecosystems, domesticated animals, their guardians, and most Tribes in Wisconsin, who are left without recourse against having their relatives killed for the mere entertainment of a few trophy hunters. 

Failures of science and ethics in the WMP

A draft of the updated WMP was released for public comment last November until late February. During that time, the WDNR received over 3000 comments from Tribes, advocacy organizations, and private individuals. We have reviewed those comments, of which the overwhelming majority, even from folks residing in wolf country, were in favor of core habitat wolf protections, no population cap, prioritizing non-lethal methods to mitigate conflicts, and adamantly opposed recreational wolf hunting and trapping, (especially of the methods the WMP decided to allow in its final plan). Those comments were overwhelmingly more numerous than others, and suggest most Wisconsinites feel that hunting wolves is unnecessary or culturally offensive to Tribes, and their opposition to both a population cap and specific methods of killing like hounds or traps. By omitting all this feedback from the final plan, the plan not only runs contrary to public values towards wolves, but also neglects informing the public about the comments received and the evidence supporting those requested changes. Such a conflict between managers and the public should not only be acknowledged, but foregrounded and carefully considered in policy, rather than swept under the rug without any evidence of its serious consideration. 

Moreover, the comments from our organizations identified several and egregious scientific gaps in the plan, and provided an extensive list of scientific studies covering many relevant topics that were omitted from it. Notably, the missing scientific literature supports the majority of public comments mentioned above. Those comments, and the large body of omitted scientific literature they point to, suggest the plan is largely unscientific to the extent that it only incorporates science that supports the agency’s predetermined ‘management’ practices, while dismissing any studies that challenge them. The scientific bias intrinsic to the plan is not only a scientific failure, but also an ethical one, because it gives the false impression of being scientifically comprehensive and therefore misinforms the public about (1) the relevant science and (2) the real and most effective alternatives available when it comes to coexisting peacefully with wolves. Such decisions to omit literature or downplay evidence (e.g., such as majority opposition to killing wolves and their reasons) are contrary to principles of scientific integrity (e.g., transparently present all relevant scientific evidence to the public) as well as ethics (e.g., disguising ethical decisions, such as allowing recreational wolf killing and the allowed methods, as supported by science).

The scientific and unethical failure of the agency when it comes to educating the public and ‘managing’ wolves and most other wildlife in Wisconsin is due to the agency’s perspective of wild animals as ‘natural resources’ that humans can do whatever they wish to as long as it is done in a sustainable manner. This view of wild animals as resources rather than living beings deserving of care and respect is actually an ethical position (not a scientific one) that goes unstated, but that pervades the entire plan, including the science deemed relevant. This institutional perspective instrumentalizes all wildlife, dismisses their wellbeing, and promotes their killing rather than their ethical consideration.

A few examples will help illustrate the point, but we refer the public to our organizations’ detailed comments for many more scientific and ethical issues. Despite the ample available scientific literature on the topic, the WMP provides no scientific evidence relevant to wolves’ sentience, cognition and family lives. All of those capabilities and conditions should be relevant to any policy – as they are, to an extent, for our canid companions. Yet, by dismissing those important aspects of who wolves are, the suggestion is that such aspects are irrelevant for policy, that these animals are merely biological machines (which scientific consensus denies), and that there are no ethical issues to consider beyond the sustainability of their killing. It is also noteworthy that the resiliency of wolf populations to widespread killing is repeated several times throughout the plan, while dismissing the scientific concerns over the serious and negative biological, conservation, ethical, and eco-evolutionary implications of such killing. 

The WMP also omits a large body of scientific literature pointing to a lack of effectiveness of killing wolves to mitigate conflicts (i.e., predation on domesticated animals). Although it is true that “…lethal control options (e.g., damage tags) may empower local residents and provide a sense of security.” (WMP, p. 28), the scientific evidence against the functional effectiveness of lethal methods suggests this is a false sense of security due to the ineffectiveness and even counterproductive effects (i.e., increased conflicts) of lethal interventions in response to conflicts. Over a dozen recent scientific studies document such negative impacts of killing wolves and the higher reliability and effectiveness of non-lethal methods for conflict mitigation, but are nowhere to be found in the final plan, even after our organizations noted their omission and the agency had months to incorporate that science. To make matters worse, the plan suggests allowing the killing of wolves will improve attitudes towards them, despite ample evidence to the contrary, from Wisconsin and other wolf populations, that instead note that liberalizing the killing of wolves may promote their illegal killing and its concealment from authorities.

It is also incredibly concerning that conflicting agency objectives such as “maximiz[ing] hunter/trapper opportunity and satisfaction” (WMP, p.133) and conflict mitigation are not only not acknowledged, but even framed as harmonious, against the body of scientific evidence. That culminates in the prioritization of consumptive values and policies; e.g., according to the body of scientific literature, use of lethal methods, and especially public hunts, are contrary to most objectives relevant to wolves (e.g., conflict mitigation). Despite Act 169, which mandates a wolf hunting season, the department can still restrict the implementation of lethal methods by setting minimal quotas, restricting timing and methods, but decided not to and provided no explanation for it. 

The WDNR’s decision to not only sanction, but promote the killing and trapping of wolves conveys an inappropriate understanding and dismissal of tribal worldviews about wolves. Tribal worldviews of wolves are misconstrued as ‘cultural benefits’ Tribes receive from the existence of a wolf population, when in fact tribal worldviews consider each individual wolf as a person and relative. This means that Tribes are not just content with having a sustainable population of wolves they can ‘enjoy’. Although the plan includes various statements from Tribes explaining their kinship with wolves, none of them seem to be integrated into policy. On the contrary, the Tribes’ relationship to wolves is misinterpreted by the WDNR, which suggests that Tribes can enjoy such ‘benefits’ while the agency codifies and promotes the killing of their relatives for the entertainment of trophy hunters by multiple cruel methods. Cultural respect and sensitivity towards such views, shared by many non-tribal members (as seen in the public comments), demand the strict mitigation of lethal measures and recreational killing, and especially the use of methods like trapping, baiting, snaring, hounding, destroying wolf dens, and night-hunting. Such ignorance, thoughtlessness, prejudice, and lack of respect for the worldviews of co-sovereign Tribes, alongside the goal of maximizing the killing of their relatives for entertainment via cruel methods by a minority, is the definition of institutional racism and should be condemned.

Procedural failures  

For a policy process to be considered transparent, democratic, deliberative and inclusive, there needs to be at least some evidence that input was not only allowed, but effectively and adequately considered. Unfortunately, we have no evidence that the comments of the majority on the WMP, i.e., the science, public values, and the Tribes’ worldviews, were given serious consideration by the WDNR. Besides providing opportunity to comment, we cannot point to the revised WMP as evidence of consideration because it lacks the integration of any of the science or values presented above, nor has the agency provided any responses or rebuttals to the challenges to the plan posed by the public. On the contrary, the ‘revised’ plan provides evidence for dismissal of such challenges given all the science that is still missing and no explanation for why it was not incorporated into the final draft. Public comments may as well be a box the agency checks to protect itself from procedural litigation, while still being allowed to ignore any and all comments that challenge their preferred ‘management’ alternative. That could not be more evident, as Natural Resources Board (NRB) Chairman Bill Smith and NRB member Sandra Dee Naas proclaimed that they would choose whatever was a defensible management plan against litigation. 

However, we suspect that some constituents’ comments were actually integrated into the revised version of the WMP, to the detriment of democratic deliberation, ethics and scientific rigor. After the comment period for the draft WMP closed in February, The Wisconsin Wildlife Federation, in cooperation with the Wisconsin Sporting Dogs Association, Wisconsin Bear Hunters Association, Wisconsin Wolf Facts, Farm Bureau, Farmer’s Union, and the Cattlemen’s Association, submitted comments and held listening sessions attended by Natural Resources Board (NRB) members and the WDNR Secretary, Adam Payne. We suspect those comments and sessions did result in unexplained changes to the plan the public opposed, even after the comment period had closed. For example, one of the few revisions to the plan, and the biggest, was the introduction of a cap on the wolf population of around 1,200 wolves when there was initially no cap and when the majority of the public commented against such a cap. No rationale was provided for that change.

The Natural Resources Board violated the Wisconsin Open Meetings Law by hosting private, invitation-only public meetings for hunting and trapping groups to provide priority comment on the WDNR’s Draft WMP. These private meetings resulted in substantive changes to the draft plan and occurred after the formal comment period ended. Any changes resulting from these illegal meetings should be struck from the draft plan, or the plan violates the Wisconsin Open Meetings Law and Wisconsin Administrative Procedures Act.

What’s worse, much of the testimony at these listening sessions didn’t happen or was not backed by data or evidence of reports to federal or state public agencies. Individual experiences shared during these sessions were either made up or lacked evidence, including:

• A pet owner’s experiences with dogs killed by wolves that had broken into their kennel. The pet owner was later stalked by a wolf as she searched for one of her missing dogs.
• A grandmother’s experience encircled by wolves over her deer harvest after returning to the carcass on an ATV with her 3-year old granddaughter.
• A taxidermist has experienced a transition from large numbers of local deer being brought to him to deer coming to him from other states, suggesting Wisconsin hunters are leaving the state to hunt. 
• A Douglas County farmer shared how they lose 15 to 25 calves annually to wolf depredation and only receive a small percentage of their value.
• Due to recent encounters with wolves, a horseback rider never before afraid in the field has purchased her first firearm to protect herself, her horse, and her dog as she trail rides. 

Reactionary politicians and trophy hunting organizations capitalize on such unfounded feelings of persecution, rather than assuaging fears by educating folks on why wolves are some of the least dangerous species for humans. It is predictable that some individuals will feel compelled to exact revenge on the animals and/or people whom wolf hating institutions have identified as their oppressors. However, we do not think the WDNR should appease them by offering up wolves for their revenge and bloodlust. It is disappointing that the state of WI is suing to have wolves delisted in Wisconsin. Then again, it’s these fear based, competitive, morally decayed hunter groups that the Wisconsin DNR apparently works for. 

In addition, we understand that the Natural Resources Board intends to adopt an emergency rule to regulate wolf hunting and trapping, though no emergency exists. Please be on notice that we are prepared to file suit if the Board improperly uses the emergency rules making procedures to thwart the democratic procedural requirements for notice and comment rulemaking under the Wisconsin Administrative Procedures Act. No emergency could possibly justify the need to adopt urgent rules for the hunting and trapping of wolves while the wolf is protected from hunting and trapping under the Federal Endangered Species Act.

The above failures are clear examples of how both the agency and the NRB have shown time and time again that they cave to politicking, narrow special interests and still believe in killing as a main ‘management’ strategy, at the cost of transparency, scientific evidence, public values and democratic accountability. Even when the values and demographics relevant to wildlife are moving towards non-consumptive uses and care for wild animals, Wisconsin’s DNR continues to respond to sport hunting and fishing interests over all other constituents. That has made wolf ‘management’ in Wisconsin synonymous with extreme killing of wolves by cruel methods and illegal back door dealing. The voices of non-consumptive users have been ignored, forcing groups to take action in the form of litigation. It is the only choice we have when the agency and its supporters are prejudiced against different worldviews, and cheat, lie and ignore proper procedure.

It should be clear from the above that we have no confidence in the WDNR’s scientific expertise or ability to conduct a democratic and ethical policy process, including the virtual public listening session on September 12, 2023 related to permanent rule WM-03-21 on gray wolf ‘harvest’ regulations. Our organizations submitted comments opposing the hunting and trapping of wolves during the official WMP comment period that were dismissed without explanation. We have neither trust in the WDNR nor reason to believe this upcoming hearing will be any different.

Changing this sad state of affairs begins with taking accountability. We must all take responsibility for ensuring a democratic process behind good policy making, grounded on sound ethics and science. For the agency, that should begin through establishing processes that rebuild trust, such as providing evidence that it has considered public comments, which ones, and how, when the agency asks for public input. There is also an urgent need to democratize wildlife policy through the equitable consideration of currently underrepresented worldviews in policy, including those of Tribes as co-sovereigns, and their integration into policy. Simultaneously, the agency should create official spaces to debate the science and ethics behind policy decisions when there is conflicting evidence or values, rather than arbitrarily choosing which to prioritize and providing no rationale for it. No policy will ever absolutely satisfy everyone, but policy guided by science, ethics, and collaborative decision-making will most assuredly point us in the direction of what’s in the best interest of the public and wild lives. 

Francisco J. Santiago-Ávila, PhD | Science & Conservation Manager

Project Coyote | 608.285.2738 | fran@projectcoyote.org

www.projectcoyote.org 

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Melissa Smith |Executive Director| Friends of the Wisconsin Wolf & Wildlife 

Great Lakes Wildlife Alliance | Wildlife Policy & Government Affairs

 Phone: 608.234.8860 |PO Box 259891 Madison, WI 53715

www.wiwolvesandwildlife.org