Submitted via http://www.regulations.gov June 14, 2020
Document No. FWS-R2-ES-2020-0007
RE: FWS-R2-ES-2020-0007, Revision to the Nonessential Experimental
Dear Sirs and Madams,
These comments are being submitted by the New Mexico Council of Outfitters and Guides {NMCOG} along with support from timber, farming, livestock, mining, small business, sportsmen and outfitter industries. The New Mexico Outfitting industry supports 240 full time outfitters plus hundreds of guides, cooks and packer wranglers and is the second largest economic driver in Catron County New Mexico in the heart of the Mexican Gray Wolf Recovery area.
The NMCOG along with Safari Club International participated in the 2015 rule making EIS process. We made comments pointing to the failure of the U.S. Fish and Wildlife Service to properly consider the negative impacts to the social, cultural, economic and all wildlife populations for our members who live and or make their living from the recovery area and will potentially spread to other parts of the state.
The scope of analysis should include:
- Analysis of the economic, physical and mental impacts on the livestock ranchers, outfitters, guides and small business owners.
- Analysis of the economic impacts on the hunting and guiding and other recreational activities.
- Analysis of the impact on the game populations in the areas of wolf release and dispersal.
Other scoping issues include:
An estimated 90% of the historic range of the Mexican wolves is in Mexico. The future success depends on how the wolves survive and propagate in Mexico and the US portion should not be saddled with the full brunt of the wolf proliferation in the States of New Mexico and Arizona.
The 2015 rule should continue for takes resulting in impacts to a wild ungulate herd. The NMCOG is concerned that eliminating this provision could have serious impacts on the ecosystems and species dependent on those ecosystems.
Since humans and their survival activities are now occupying these habitats, bringing in Mexican wolves to a settled environment is extremely hard on the residents here.
If you continue the current trends of increased wild ungulate depredations, wolves will increase pressure on livestock and the continuing downward spiral of ranching operations.
With decreased grazing on allotments there will be a decrease in construction and maintenance of livestock water developments.
The decrease in water availability will compound the impacts on the wild ungulate population.
Analysis must include an examination of these ecosystem impacts. Analysis also needs to include impacts on game department revenues from hunting licenses, state and local government tax revenue loss from reduced hunting and outfitter/guide activities.
The following information on big game hunting data, including the number of license holders and applicants, days spent hunting and average hunter financial expenditures and total number of hunters, harvest and success ratio for elk and deer, will be detailed below.
Note that this information is a year old and wolf numbers in the affected areas have significantly increased the past year.
Also note that three years ago it was estimated that the Gila region was at capacity on the then 65 estimated wolves in the greater Gila SW Region, with a prey base of an estimated elk population of 20,000+ elk.
This means a wolf population of 65 and their estimated diet, the elk herd would have to be maintained at the 20.000 plus level, with wolf depredation and leaving elk hunting license numbers as they presently are.
Any more than this then the New Mexico Department of Game and Fish will have to start cutting hunting licenses to allow for a healthy balance of elk.
Deer numbers are affected to a lesser degree as deer populations are already at their lowest levels in thirty years due to drought and depredation from other predators such as lions, coyotes, and bears.
Elk hunter information in GMU’s encompassing the Gila (10, 12, 13, 15, 16A, 16B/22, 16C, 16D, 16E, 17, 21A, 21B, 23, 24)
2019 Total draw elk applicants: 22,472
- ($645,384 in non-refundable fee income to NMDGF)
2019 Total elk hunters:
- 11,265 (public land hunts 8,892
- Private land hunts 2,372)
- 2019 Total days spent elk hunting 101,124 (Resident hunters 89,469, non-resident hunters 4,756, outfitted hunters 6,898)
- 2019 public draw elk hunters license revenue to NMDGF $3,230,540 (Resident $1,605,448 / Non-resident $660,424 / Outfitted Hunts $964,692
- 2019 Private land hunters license revenue to NMDGF $768,474 (Resident $76,632 Non-resident $691,842)
- 2019 Est. outfitter total revenue $13,078,500 (private land $8,479,500 public land $4,599,000
- Based on an average cost of an outfitted public draw hunt at $3,000, an outfitted private land hunt at $7,500, and an outfitted cow elk hunt at $2,500.
- 2019 Est. NM Gross Receipts Taxes paid by outfitters $915,495
- 2019 Est. total indirect resident and non-resident hunter expenditures spent in wolf country $2,205,300 (gas, food, hotel, etc…)
- Greater Gila Herd population estimate: 21,000-23,000, 1340-1730 bulls, cows 1530-1870
- Lesser Gila Herd population estimate: 1300-3600, sustainable harvest 140-190 bulls, 160-210 cows.
- San Mateo Herd population estimate: 2,000-2600, sustainable harvest: 150-180 bulls, 170-200 cows.SW
- Region totals sustainable harvest: 1870 bulls, 2140-2650 cows.
The SW Region has averaged a little over 9500 licensed elk hunters the last three year period of 2017, 2018 and 2019.
The success rate for these three years has gone from 38% down to 32% in 2019.
The average days hunted has been 4.7 days.
The average hunter satisfaction ratio has fallen from 3.73 to 3.58 from 2017 to 2019.
The above statistics were taken from the New Mexico Department of Fish and Game harvest reports from 2017-2019. To garner a more complete analysis of the statistics there needs to be a compilation of the NMDGF records from the start of the Mexican Gray Wolf program for the previous 20 years prior to 2017.
Also note the figures on the estimated daily pounds of elk meat needed and consumed by these wolves has not been done in the Gila, although they have proven elk make up the biggest percentage of their diets. Any presently used calculations are from studies done in the northern states.
Thank you,
Tom Klumker
SW Director for the New Mexico Council of Outfitters and Guides
Outfitter Director for the AZ/NM Coalition of Counties
sfroutfitters@gmail.com
13 Pearl Drive
Glenwood, NM 88039
