We need to BAN  Grazing Allotments in Known Wolf Den Areas to prevent what happened Last year to The Profanity Peak Pack. Cattle Ranchers need to be prevented from Grazing Known Wolf Den Areas, especially Ranchers like McIrvrin, that knowingly place Salt Blocks in Den Areas to keep cattle close.

Colville National Forest Plan Shortcomings

As They Relate to Wildlife Conflicts

The 1988 Colville National Forest Plan is based on outdated science and it has inadequately addressed public and tribal concerns about the impacts of grazing. Grazing has been managed only in the best interests of the rancher and the logging industry and, as such, inadequately protects non-developed recreation (for example Hikers have to walk up cow pie laden trails) from the impacts of grazing on our environment. Protect The Wolves® contends that it also does not address cultural resource concerns of the Indigenous peoples of North America as they pertain to our wildlife. Thereby, placing the USFS, WDFW, and Washington State elected officials in direct conflict and perhaps violation of not only the Indian Trust, but the Public Trust Doctrine.

  Protect The Wolves® viewpoint holds that the Indian Trust establishes the core principles central to the Model; the notion that wildlife is, in fact, a public resource which is managed for the common good of the beneficiaries. Next to the Indian Trust, is the Public Trust Doctrine, which is held in custodianship by a cadre of so-called, oftentimes self-proclaimed professionals who serve as trustees and are to be held accountable by the beneficiaries, the Indigenous peoples, as well as the general public.

  Furthermore, it is essential for USFD, WDFW, and Washington State to remain100% transparent in their relationship in regard to managing tribal and public resources as mandated by both Trusts.

  In situations where certain wildlife management responsibilities have been fully or partially legislatively reassigned. The resulting management may not be in the best interest of the beneficiaries, or may advantage a particular segment such as cattle ranchers (which WDFW has done and USFS has allowed to happen) to the detriment of the greater Indian Trust, as well as the Public Trust. An example being that the USFS is charged with ensuring the protection of wildlife, yet WDFW is tasked with the management and enforcement of this process. Consequently, despite a relationship that was established for the protection of our wildlife and natural resources, there has been total disregard for either the Indian Trust, or the Public Trust Doctrine.

  The mission and purpose of the trustees depends on government branches serving the interest of the beneficiaries. The mission and purpose of the different public agencies must serve the interests of all of the beneficiaries. The manner in which the USFS, WDFW, and Washington State elected officials have managed wolves in Washington State is in direct conflict with this mission. According to the mandates placed upon them as trustees, they cannot manage trust assets in an inequitable manner, nor can they gift trust assets. For example, if a public asset such as predators were assigned to a state or provincial agency as trustee, and the agency’s role is described as managing predator populations in a self-sustaining manner for the benefit of future generations, the purpose of the Indian Trust and Public Trust Doctrine would be served. However, the manner in which WDFW has managed our wildlife resources is contrary to the purposes of both the Indian Trust and Public Trust Doctrine. The Trusts would not be served if the purpose of the agency is described solely as preventing economic impact to agricultural producers such as the affected ranchers, which seems to be the path that WDFW has chosen.

  The Trusts establish a clear delegation of management responsibility to the trustees for the beneficiaries. It is the mandated responsibility of the trustees to manage said fish and wildlife in the best interests of all beneficiaries. It is the refusal of the USFS and WDFW, as well as Washington State elected officials to follow either of these Trusts which now leads us to request that a mandated depredation deterrent policy be added to the current protocol. For example, Deterrents need a list of requirements first, second, third, etc, as well as proven successful combinations. This will assist the USFS as well as WDFW, and perhaps Washington State elected officials to comply with the intentions and mandates of the Trusts. For instance, simply delaying livestock turnout for a week is not only insufficient, it is not even a deterrent, nor is it in the best interests of the wildlife, being wolves in this case; it is in the best interests of the livestock ranchers. The trustee agencies are mandated to protect wildlife assets for the beneficiaries, both the Indigenous peoples as well as the general public. The clear disregard for Trust mandates by trustee agencies demonstrates disrespect for both the Indian Trust and the Public Trust Doctrine.

  Protect The Wolves® was founded on not only traditional Indigenous values, but religious values as they pertain to not only our environment, but include all of the Creator’s resources  pertaining to all things sacred which are necessary for establishing a healthy environment.

  Protect The Wolves® places emphasis on cultural identity as it relates to our religious beliefs including what we, as Indigenous peoples, hold as sacred. Those beliefs include all wildlife as a necessary part of the circle of life, which to all Indigenous peoples is sacred all on its own. Indigenous sacred items include all things living, grizzlies, wolves, wild horses, and all species of wildlife, as well as locations which include mountains, trees, and water.

  Protect The Wolves®, on behalf of their 53,000 followers with the same beliefs that we were founded on, is petitioning the Colville National Forest and their representative, Range Manager Travis Fletcher, to rescind or move any and all grazing allotments that interfere with the protection of our environment as well as our trust resources or sacred species. As such, any grazing allotments in direct conflict with known or newly discovered wolf den sites, should either be rescinded, or the allotments should be moved away from direct conflict with wolf den sites. Clearly, USFS as well as WDFW are managing the public's resources for the sole benefit of Ranchers, and not the Beneficiaries, thus placing them in conflict and perhaps violating both the Indian Trust as well as The Public Trust Doctrine. Wolves like Grizzlies, Wild Horses, all wildlife are Trust resources that fall under both Indigenous and Public trusts. We request that the USFS, WDFW, and Washington State elected officials honor the mandates of these Trusts.

Thank you for your consideration.

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