2357 Ventura Drive, Suite 106 Saint Paul, MN 55125 Tel: 651-739-9332 Fax: 651-731-1330 mnaudubon@audubon.org mn.audubon.

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Audubon Minnesota represents the 12,000 National Audubon Society members in our state. National Audubon Society is a science based conservation organization with a membership that includes avid hunters and those opposed to hunting, with a majority in between. As the state representative of the National Audubon Society, Audubon Minnesota supports our national policy on hunting of any species: The National Audubon Society historically has not assumed a position either for or against hunting. We do not promote hunting, nor do we oppose hunting so long as it does not adversely affect wildlife populations, and is done legally and in keeping with the principles of good sportsmanship. In Minnesota, the grey wolf is a keystone species of the forest ecosystem. Grey wolves help maintain the health of the ecosystem by culling out weakened prey species including beaver, deer, muskrats, rabbit and other animals. Healthy populations of grey wolves help maintain healthy populations of other species. An effect of a high deer population is their foraging effect on the understory vegetation of forests. Deer eat many plants in the herbaceous layer of the forest floor, which limits recruitment of plants. Without ground cover, ground nesting birds have fewer places to nest. Similarly, without new plant generation, whole vertical habitat components of the forest are missing, which can limit habitat availability for a number of bird species.1.Wolves assist with keeping deer populations in check and by extension help provide a suitable environment for birds and many other species. The Minnesota wolf population has remained stable for the past 10 years2. This is likely due to the significant mortality the wolf experiences, even as an endangered species. For example, at Camp Ripley of 30 wolves monitored from 1996-2006, 16 died. One wolf pup starved, five were shot, one was poisoned, four were hit by cars, two died of unknown causes and three were killed by the US Department of Agriculture3. In this study, 14 of the 16 wolf deaths were caused by humans, including at least 6 illegal deaths. In 1998, the Minnesota DNR convened a Wolf Management Roundtable. Participants in the roundtable included not only Audubon Minnesota, but the Minnesota Deer Hunters Association, the Minnesota Trapping Association, the Minnesota Farm Bureau and Farmers Union and the Minnesota Chapter of the Safari Club International among many others. The roundtables input informed the State Wolf Management Plan4 that includes a five year moratorium on hunting and trapping of wolves after their delisting from the Endangered Species Act.

Cutright, N., Kearns, K., Effects of Deer Herbivory on Birds, WI Bird Conserv Initiative, www.wisconsinbirds.org/deerherbivory.htm, 2010. 2 Minnesota DNR website, Rare Species Guide, Canis lupus, www.dnr.state.mn.us/rsg/profile.html?action=elementDetail&selectedElement=AMAJA01030 last visited March 2, 2012. 3 Axelson, G., MN DNR, The Wolves of Camp Ripley, Minnesota Conservation Volunteer, Jan-Feb 2007, www.dnr.state.mn.us/volunteer/janfeb07/wolvesofripley.html. 4 Minnesota Wolf Management Plan, February, 2001 http://www.fws.gov/midwest/wolf/stateplans/pdf/mn-wolf-plan-01.pdf

The state wolf management plan is insightful and forward thinking, with the long-term goal of maintaining a strong, viable population of gray wolves in Minnesota that would not require the protection of the federal government to thrive in its native Minnesota habitat. The Plan balances the competing needs and desires of our citizens for economic and personal security, and recreation, both consumptive (hunting and trapping) and nonconsumptive (wildlife viewing.) The 2001 legislature passed a law based on the DNR Wolf Management Plan developed as a result of the Roundtable that specified no general public take of wolves (ie hunting or trapping) for a five year period following delisting. In addition, this thorough management plan calls for: population monitoring that includes determination of human-caused mortality, population management that calls for a continued expansion of wolf populations (establishing a minimum population of 1600, but no maximum), a comprehensive wolf damage management program (including state-administered certified predator controllers), strong enforcement of the law with fines (up to $3000) and restitution for illegal killing (up to $2000), information and educational programs, and at least five dedicated DNR wolf program staff: two in program direction and research, and three in enforcement. Audubon members believe that this balanced plan should be implemented in full, for five years, prior to the commencement of a general public take of wolves. The permission granted for an immediate hunting and trapping season by the 2011 legislature in a littlescrutinized section of legislation passed during the chaos of the July 2011 Special Session does not require that such a hunt be conducted immediately. Thoughtful people with many divergent views on wolves developed recommendations which resulted in the present wolf management plan. It is prudent to stick with such a plan, rather than rush to implement a public take which is not necessary to control or manage wolf populations which have remained stable over the past ten years. During the next five years, Audubon Minnesota believes that migration patterns and natural cycles of wolf population growth and retraction and the effects of poaching and other adverse human-wolf interactions should be scrutinized. The wolfs responses to compounding factors such as climate change that may alter habitat structure, and even the spread of disease all need to be known to properly determine the best long-term management of this iconic species. It is only after the data is gathered and Minnesotas wolf ecology is better understood, that a public take should commence in Minnesota. Audubon Minnesota is encouraged by the generally conservative approach the Minnesota DNR has taken thus far towards wolf management, and recognizes important steps that have been taken to begin to implement the State Wolf Management Plan. We urge that the state not deviate from this plan by instituting an immediate public take of wolves. Sincerely,

Don Arnosti Policy Director Audubon Minnesota