Final Public Comment

Friends of the Northern Yellowstone Elk Herd, Inc.
P.O. Box 7, Pray MT 59065
Public Comment for Wolf De-Listing
RIN# 1018-AU53

April 6, 2006


Enclosed please find the public comment regarding the de-listing of the Canadian Gray Wolf,
prepared in accordance with the Endangered Species Act of 1973. Issues and comments were prepared by Friends of the Northern Yellowstone Elk Herd, Inc and our membership. Should our petition to de-list the Canadian Gray Wolf in Montana, Idaho and Wyoming be denied, we reserve the right to present these issues to be litigated post 10/26/06.

A complete copy of this file has been forwarded to our attorney.

We hereby demand the immediate removal from any “protections” afforded wolves by the

Federal Government, understanding that such protections are really not “protections” at all, but
are, rather a full scale frontal attack on civil rights, property rights and resource providers in
Montana, Idaho, and Wyoming.

    • The U.S. Congress ordered in 1988 that wolf reintroduction 1) should not hurt hunting, 2)
      should not hurt local economies, 3) should not hurt any other already Endangered Species, and 4) should not hurt the ranching industry. The attached letters dated Aug. 12 1994 and the memo dated Dec.18, 1997, demonstrates a premeditated defiance of not only Congresses’ orders and intent, but a malicious bad faith dealings in direct violation of Title 18 of the U.S. Code, and comparable state law. Friends of the Northern Yellowstone Elk Herd requests of the court to order the U.S. Attorney to commence criminal investigation of those federal, state and non-governmental officials who can be prosecuted.
    • Defenders of Wildlife have established a “compensation trust” acknowledging financial responsibility for losses incurred from wolf introduction. Friends of the Northern Yellowstone Elk Herd, Inc requests of the court to hold Defenders of Wildlife financially responsible for the decimation of the Montana, Idaho, and Wyoming game herds.
    • The Turner Endangered Species fund has played a dominant role in the reintroduction of wolves in extreme densities. Friends of the Northern Yellowstone Elk Herd, Inc, requests the court hold the Turner Endangered Species fund, its employees, officers, and directors
      financially and criminally liable for their role in the destruction of the Montana, Idaho, and Wyoming game herds.
    • Feb. 26, 2000 Dr. L. David Mech, PhD. announced that wolves were biologically recovered in the Yellowstone eco system.
    • Jan. 11, 2000 Wolf Project coordinator, Ed Bangs, announced to an audience of 500 in Billings MT, that wolves would be de-listed within a year.
    • Sept. 25, 2002 Assistant Sec. Of Interior Craig Manson, attended a meeting arranged by Sen. Conrad Burns, with Robert Fanning and MT Representative Dan Fuchs. Judge Manson guaranteed de-listing by Jan. 1, 2004. Judge Manson said this was date certain, even if he had to go to the 10th circuit to get it. To demonstrate his sincerity, Judge . Manson worked directly with Montana Rep. Dan Fuchs to help draft Montana HB283.
    • Clearly the Canadian Gray Wolf has biologically recovered and is eligible for de-listing. The fact that de-listing has not occurred and these extreme high wolf densities, is proof of bad faith dealings and corruption by those entrusted with wolf recovery.
    • Friends of The Northern Yellowstone Elk Herd ( here after refereed to as Friends ) was entitled, based on the administrative law found in the Endangered Species Act of 1973, to a ruling on their petition to de-list the Canadian Gray Wolf by Jan. 5, 2003. Because the administrative law of the endangered species act was violated, Friends petitions the court to set aside the April 1 2003 Distinct Population Segment ruling as null and void, and invalid. Instead Friends request the court therefore rule on our petition to de-list based on; #1 the original terms of de-listing, #2 based on state political boundaries and approved state management plans.
    • Friends believe that Montana, Idaho and Wyoming Fish and Game agencies have a conflict of interest, that arises from the monies routed from the Dept. Of Interior through the so called “Co-operative Endangered Species Fund “ and the “Land and Water Conservation Fund”. These federal monies compromise the allegiance of our Fish and Game agencies from the people of our states, to the federal government, and encourage false agenda driven science to deceive the public as to the damage done to the environment. Friends request that the court order independent scientific peer reviewed studies, to quantify the extent of the damage done to all species other than wolves.
    • The Turner Endangered Species Fund has taken a public stance that wolf recovery was
      implemented to “drive 30,000 ranchers off public lands”. The Endangered Species Act specifically forbids using the act to achieve or force social, political or economic agendas. Friends petitions the court to revoke all “Take Permits” from the Turner Endangered species Fund and bar this organization and their employees from ever participating in wolf management with federal or state authorities.
    • Friends petitions the court to introduce into the public record Canadian, Alaskan, Eurasian, European, and Indian scientists and scientific records, so that we may all thoroughly understand the following;
      • Surplus killing by wolves on both livestock and game herds.
      • Attacks on human beings.
      • Wolves as vectors and carriers of diseases and parasites
      • Specify which diseases and parasites wolves carry, and quantify the damages to
      • our economy and national security should wolves introduce disease and parasites into our environment.


  • Friends petitions the court to identify all Non Governmental Organizations who have used the court systems to delay wolf de-listing. These organizations have caused harm to the citizens and counties of Montana, Idaho and Wyoming. Friends petitions the court to order studies that will quantify these damages, both past and future claims, so that prorata damages can be awarded .
  • Friends petitions the court to quantify the damages incurred because of or as a result of the Federal Fish and Wildlife ignoring the wolf implementation rules of November 18, 1994.
  • Friends petitions the court to quantify the damages done to our economy as a result of the Federal Fish and Wildlife, Department of the Interior and Congress failing to establish a fifth amendment restitution mechanism, before this destructive animal was unleashed on the states of Montana, Idaho and Wyoming, who’s legislatures venemently opposed wolf re-introduction.
  • Friends petitions the court to recognize that wolves are being used as a bio-weapon targeting the civil rights, economy, customs, culture, and heritage of the citizens of Montana, Idaho and Wyoming. Friends petitions the courts to find that all agencies and employees of those agencies, who have breached the public trust, as evidenced by the excessive wolf densities and in defiance of Congress and the Delphi 15. Friends petitions the court to order the surrender of all management authority over wolves to the US Department of Agriculture and seek funding for lethal wolf controls from the Granger-Thy Act and order the US Department of Agriculture to work with the Montana Department of Livestock.
  • Friends petitions the court to order emergency Federal assistance for those Montana communities that bear the disproportionate burden of the impacts of the Federal Wolf Reintroduction Program.
  • Since Congress promised the people of America that hunting would not be hurt within the wolf recovery areas, Friends petitions the court to instruct the Sec. Of the Interior to order lethal wolf control in defense of the game herds, as authorized by Section 11(h) of the Endangered Species Act in Montana, Idaho and Wyoming, abiding by and adhering to the original science authored by the Delphi 15, pre-wolf introduction.
  • Friends petitions the court to hold lethal wolf control in place until the game herds of Montana, Idaho and Wyoming are restored to the numbers promised by the Delphi 15 in Wolves For Yellowstone Volume 1.
  • Friends petitions the court to recognize that these high wolf densities are in direct violation of the original EIS, NEPA, Data Quality Act, ESA and a variety of Montana state laws. We request the court instruct all state and federal agencies to be in full compliance with the aforementioned laws, regardless of how many wolves need to be killed to comply with these laws.
  • Friends requests that the court reserve the right for Friends of the Northern Yellowstone Elk Herd and any or all of its members, and interveners, to enter into criminal and or civil litigation, to recover damages (past and future) as a result of malfeasance, latches, negligence and corruption by those federal and state agencies and administrations and their employees as well as any Non Governmental Organization who has breached the public trust and defied the instruction of Congress.