Draft BC Wolf Plan

Response to the Draft Management Plan for the Grey Wolf in BC

In thoroughly reviewing this draft plan which has been an ongoing draft for at least 18-24 months, I find the document to be completely unbalanced. Its main purpose is to draft a document that gives the BC Government under the auspices of the Fish & Wildlife Branch to continue to persecute this animal which they have done for decades.

It is mainly preoccupied with the killing of wolves and there are 84 references to the harvesting (killing) or consumptive uses of the wolf compared to 15 references to the conservation or non-consumptive use of the wolf. These references relate to paragraphs, discussions or comments by the author.

I find this bias to killing the wolf very troubling but not surprised that Fish & Wildlife has secured a report which clearly articulates its hatred of the wolf and the need to reduce it any opportunity. The author, Steve Wilson also wrote the report of the Mountain Caribou which he advocated aerial removal of wolves which the citizens of BC widely condemned . A senior manager for Fish & Wildlife had to admit that there was overwhelming opposition to this aerial hunting.

This anti-wolf bias in this draft plan would be akin to President Lincoln asking the KKK to write the Emancipation Proclamation to free the laves during the American Civil War.

In my view this report is incomplete & has missed many important issues regarding wolf management which are included in a more thorough wolf conservation & management  plan from another Canadian jurisdiction. One of the main reasons this report is so unbalanced is because there was no public input sought for the development of this plan. Other jurisdictions such as Alaska, Yukon & Washington State involved the public thru public meetings to make submissions.

When you allow the public to give input from all positions on the topic, you get diversity of thought which allows a frank discussion of the issues & the ability to educate each other or differing points of view. Fish & Wildlife in its fortress mentality did not even want to share this document in its draft form in 2011. Now the responses are only being sent to the Minister & there is no process for groups or citizens to present their cases publically to the Minister. When the process is flawed at the outset you get a flawed result which is this draft report.

Wolf Control due to Livestock Depredation

This is a main point of discussion in this report as it is mentioned on 17 separate occasions. However, there was not one reference to any statistics which shows that wolf depredation on livestock is a major problem. The statistics due not support the public relations campaign by the BC Cattlemen which I feel has overblown this issue.

According to Stats Canada there are 550,000 cattle in BC. The latest figures I could find attributes only 50-75 cattle killed by wolves in a year.  Stephen Hume, reporter for the Vancouver Sun in his August 5,2011 article stated his research which was exhaustive showed only one federal agency that reported in 2008 & 2009, that wolves killed 70 livestock. This very low number of wolf kills on livestock is also supported by USDA (US Dept. of Agriculture) which keeps accurate data.

Data for 2008 showed that sheep ranchers in Wyoming, Montana & Idaho lost 125,000 sheep. The wolf was responsible for 1,300 sheep (1%). The coyote killed 31,600 (or 25%) & weather deaths accounted for 28,200 (or 22%). Dogs killed more than wolves at 1,400. This data can be found in  a table on page 42 of the National Geographic Magazine, March 2010 edition.

Coyotes are much more of a problem than wolves & the Alberta Predator Control Manual is wholly devoted to controlling coyotes than wolves on livestock. Wolves are a top predator while the coyote is a mesopredator (lower ranking) & wolves kill coyotes thereby keeping them in check for ranchers. Wolf kills get mistaken for coyote kills on a regular basis. One rancher called a provincial fish & wildlife agency to complain that a wolf had killed his cow. The cow had drowned in a swamp & when the rancher pulled the cow out with his tractor, there was a dead coyote under the cow. But the rancher stated it was a wolf kill & this mistaken identity story by ranchers is more frequent than we believe.

Ranchers have displayed very irresponsible behavior towards the wolf by poisoning it in past decades, only to do incredible collateral damage to the ecosystem by killing other animals both wild & domestic. Ranchers have this mistaken belief that they can rid the environment from any threats.

In summer 2011, the ranchers in the Chilcotin & Cariboo mounted a considerable campaign to have the wolf extirpated from this area.  They stated there is a significant increase in wolf populations & they were experiencing significant livestock losses even though they could not produce any data.

The BC Gov’t capitulated with Steve Thompson, minister in charge agreeing to regulatory changes to declare open season on the wolf. Hunting was allowed every day throughout the year and there was no bag limits. Not surprising that Thompson was the Executive Director of the BC Agricultural Council before he got into provincial politics. These ranchers were his clients and friends of his organization.

This decision was strictly political and could not be supported by research or science. It was all anecdotal evidence that contributed to this decision. The scientific evidence that was supplied by the senior wildlife biologist for that region showed that radio collared wolves in these areas lived in close proximity to ranches but there was no wolf depredation on livestock.

Another environment minister, Rafe Mair was appointed in 1980  he quickly halted the control of wolves by poison & other means. Mr. Mair represented Kamloops, a major cattle producing area & his constituents bitterly complained but this Environmental Minister showed political leadership by refusing to be intimidate by the Cattlemen. Being a lawyer he looked at the evidence which did not support culling wolves.

Evidence shows clearly that culling wolves in cattle producing areas can result in unintentional consequences that can lead to more livestock depredation. A livestock conflict specialist states that a wolf pack near a ranch that is not depredating on livestock will patrol that territory & keep other predators out such as coyotes which have a higher likelihood  to kill livestock.

Paul Paquet, a wolf biologist for 35-40 years & recognized as one of the pre-eminient wolf biologists in the world, stated that predator control programs that kill wolves indiscriminately usually result in more predation on livestock rather than less due to disruption of wolf pack social dynamics & the breakdown of territories.

To assist ranchers that do lose livestock to wolves, there needs to be a compensation program to assist them with their losses. But the best program is prevention of livestock losses. Ranchers have a major responsibility in this area.

To qualify for the compensation program, ranchers must demonstrate that they are employing non-lethal means to prevent livestock depredation. This means good human surveillance, animal surveillance (guard dogs, donkeys, llamas) & keeping young livestock close to the barn & not on the open range.

Ranchers can’t leave their livestock unattended & rely on being able to kill wolves indiscriminately. Also for the rancher to be eligible for compensation, the kill needs to be verified by a biologist trained in predator control who can distinguish which predator killed the livestock. Conservation Officers are too biased to perform this role & are too friendly with ranchers. So you can see a major part of this plan has been devoted to predator control of wolves when there is no statistical evidence to support the ranchers position.


If Fish & Wildlife is going to take the conservation of wolves seriously, then they have to adopt an attitude consistent with Conservation Ethics. This philosophy accepts the intrinsic value of wolves as a species & as individuals. They are just not an animal you can harvest for 30-40% annually & due to their high reproductive rate they will bounce back. This is not conservation!

This report does not place enough emphasis on the intrinsic value of the wolf. It does not recognize the family value of this animal & how that helps them survive as well as playing a significant, positive role in maintaining & creating healthy ecosystems. The reintroduction of the wolf in Yellowstone & Idaho has shown the important role wolves play. BC has a stable wolf population but that should not give us the right to target the wolf because it has a high reproductive rate.

Aldo Leopold, American conservationist in the 1930’s & 40’s was praising the ecological value of the wolf in maintaining  healthy forests. In fact he was recommending the reintroduction of wolves back into Yellowstone in the early 1940’s. Now some 70 years later wildlife managers are continuing to place little if any value on the wolf in being an integral part of a healthy, functioning ecosystem.

Threats to the Wolf

This draft plan seems to minimize the threats to the wolf. Habitat destruction is harming the wolf thru the destruction of traditional denning sites by logging, oil & gas development & exploration. This can cause wolves to disperse into areas with more contact/conflict with humans.

The report states hunting/trapping is very small on the BC wolf population but I submit this is not true. The very relaxed hunting regs have developed a regulatory environment which has seen a rapid increase of wolves being killed.

Trapping deaths provide more accurate stats because it is compulsory to report. The 2010 fiscal year trapping stats show that 350 wolves were trapped in BC. This si no doubt under reported because not all trapped wolves need to be reported. Non-resident hunters are also required to report wolf kills & that is about 100 wolves annually.

Resident hunters are not required to report wolf kills except for Regions 1, 3&4. However, even in these regions this requirement is not complied with nor enforced. Fish & Wildlife keeps inaccurate resident hunter kill data because they are relying on hunters to complete hunter surveys which are not accurately completed. Self-reporting is inherently inaccurate. Estimates of 500 wolves being killed annually by resident hunters is consistent with this data collection.

About 1,000 wolves are killed annually in BC from a population of 8,500 which I submit is a greater threat than acknowledged in this report.

Unethical hunting practices such as inserting frozen dee or moose legs into frozen lakes to attract wolves & then killing them is a well known practice in northern BC. This certainly violates Fair Chase hunting ethics & Manitoba outlaws this practice. Hunters & trappers intent on killing wolves know how to significantly increase their odds.

Yukon Plan

The Yukon Territory has had a very balanced & detailed plan for the conservation & management of wolves since 1992. This plan was reviewed beginning in 2010 & the final report was approved in 2012. The Yukon Territory involved the public & interested groups in the review of this plan. They called for written submissions but more importantly, the review panel visited 14 communities to get public input. They did because the wolf is important to Yukoners both involved in the conservation of wolves as well as the hunting crowd.

This public consultation has helped to develop this thorough, balanced report which is clearly lacking in the BC report. Why can the Yukon, Alaska & Washington State all involve their citizens in public meetings to develop a wolf conservation & management plan but BC refuses to consult with its citizens directly?

The original Yukon wolf plan developed in 1992, is very detailed and establishes a number of principles to guide the management of the wolf. These principles are set out in Section 3:
3.1 – wolves & their prey will be considered as integral parts of the Yukon ecosystems
3.2 – genetic composition of wolves in the Yukon will be maintained
3.3 – ongoing research & monitoring of wolves, their prey & other elements of the ecosystem will be required
3.6 – effects of habitat loss & fragmentation on wolves & their prey will be considered
3.8 – education & information efforts are a required part of the plan.

The Yukon plan also made recommendations under which wolf control may be used to manage Yukon wolf populations. These recommendations are set out in section 9 in 3 parts.
Section 9.1 – conditions required before wolf reduction programs can be considered
Section 9.2 – seven recommended guidelines which must be followed before a decision can be made to proceed with a reduction program
Section 9.3 – implementation of & follow-up to wolf reduction programs.

None of this process or recommendations are included in the draft BC plan. Not even when considering species at risk (ie. Mtn. Cariboo) & the use of a wolf control plan. Without this process being included in the plan, it is left to the discretion of wildlife managers which is unacceptable & not transparent.

The revised Yukon 2012 Wolf Conservation & Management Plan clearly states that the wolf is of considerable intrinsic value to Yukoners & the Yukon environment. There is a sincere attempt & desire to conserve the wolf in the Yukon. Contrast that to the BC Plan which is very much devoted to the harvesting of wolves.

There are 7 management goals in the 2012 Plan:
1.     conserve wolf populations in recognition of the role of wolves in the ecosystems & the maintenance of biodiversity
2.     Manage the harvest of wolves in recognition of their social, cultural & economic importance to all Yukoners
3.     Manage wolf populations in recognition of the enjoyment & appreciation that Yukoners & visitors have in experiencing wolves in the Yukon wilderness
4.     Use wolf harvest as a management tool to reduce predation rates of moose & caribou in local areas
5.     Promote research, education programs & info sharing to enhance understanding of wolf behavior & ecology & management decisions affecting wolves.

This plan severely criticizes the use of aerial control of wolves. Yukon spent thousands of dollars using helicopters to hunt & kill wolves but it had little effect on managing wolves. This plan recommends & it was adopted that aerial control of wolves is not a tool to manage wolves & it has been abandoned in the Yukon due to strong public opposition, high financial costs & the short-term impacts on wolves & ungulates.

Yukon plan does not allow hunting or trapping beyond March 31 due to the harm & disruption to pup rearing activities. The identification & protection of den sites through input to land use planning & environmental assessment  will help to minimize disturbances to wolves.

Hunting & trapping of wolves is promoted in the Yukon but not at the rate & intensity of BC hunting practices. There are 4,500 – 5,000 wolves in the Yukon & 155 are killed by hunting & 60 trapped annually. This is a significant reduction of the harvesting rate employed by BC. There also is mandatory reporting of wolf kills thru hunting & trapping so they can effectively monitor wolf populations.

The Yukon plan also promotes the ecotourism industry because many visitors come to the Territory to observe, hear & search for wolf sign in its wilderness.

Bob Hayes, senior wildlife biologist responsible for wolf control in the Yukon for 18 years, recently wrote his book, Wolves of the Yukon & he stated killing wolves is biologically wrong. This is an admission of defeat that wide scale wolf control programs do not work.

Through his research, Bob found there was approximately 4,500 wolves in the Yukon about 10,000 years ago. This was based on archaeological evidence & there is now 4,500 wolves in the Yukon. Constantly trying to limit wolf populations by their extensive wolf control programs did not work & he now recommends abandoning these programs for more intensive local initiatives.


This plan needs such extensive work to make it balanced that it would be better to scrap it & start anew. There is no sincere effort to conserve wolves in this Plan, not like in the Yukon Plan. That is because the author & Ministry staff never have had any interest in conserving wolves.

The two zone management strategy does not promote conservation, in fact it promotes the opposite. One zone seeks the extirpation of wolves in cattle producing areas & where there are endangered species. All the regulations allow for the extermination of wolves in these areas.

In the other zone, hunting regulations are set very liberal to ensure wolves are kept at low density. This two zone strategy which encompasses all of BC, is the antipathy of  the conservation of BC wolves.

Here are the recommendations to make the Plan much more balanced:
1.     Hold public meetings to allow all groups to exercise their democratic right to give advice to government.
2.     To curtail hunting & trapping from March 31 – Aug. 31, so wolves can raise their pups without losing their young or pack members. This killing disrupts the pack structure.
3.     No baiting of wolves to assist in hunting. This is not Fair Chase.
4.     Ban leghold traps & snares
5.     Outlaw the use of poison to kill wolves by way of legislation & regulation.
6.     No aerial control (particularly helicopters) of wolves.
7.     Establish an educational component of the Plan to educate the public about wolves in a balanced manner.
8.     Set large areas of BC aside for non-consumptive use of wolves. This would allow the wolves to live in peace & protect the social stability of wolf packs. Also allows for ecotourism of wolves for viewing & research of wolves.
9.     Return to former species licence, quotas, restricted seasons & mandatory reporting of wolf kills.
10. Continue the compensation program to ranchers for livestock predation.

The vast majority of BC residents I speak to at my wolf presentations want to see a greater emphasis placed on wolf conservation. This Plan is a major step backward in achieving this goal.


Gary R. Allan