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Why is trapping mortality an acceptable exception noted in this 4(d) Rule?

• The 4(d) rule to blanket exemption from take for trapping will undermine (not further) the conservation of wolverine in the lower 48 states. 
  • The best available science reveals the 4(d) rule’s broad exemptions from Section 9’s prohibition on take for trapping and logging projects fall short and fail to further the conservation of wolverine. The best available science also reveals wolverines in the lower 48 States qualify for “endangered” status, thus alleviating the need for the rule itself.
  • In support of this trapping exemption, the Service maintains the incidental take of wolverine in the lower 48 States from trapping “is minimal” and will not “significantly impact” the population. As explained by the agency: “If we assume there are approximately 300 wolverines in the contiguous United States and assume two wolverine mortalities per year for incidental trapping,” that would “be 0.67 percent of the population per year,” which will not “inhibit the conservation” of Wolverine. This finding, however, conflicts with the best available science. In short, losing individual wolverines – even a few- from trapping is a stressor and can undermine the species’ conservation in the lower 48 states.
  • When wolverines are caught and killed in traps in Montana and throughout the lower 48 States, it is almost always “accidental” or “incidental” to otherwise legal trapping in areas occupied by wolverines.
  • The loss of a single individual wolverine – especially a dispersing female – can be significant for population recruitment, connectivity, and functioning meta-population dynamics. According to the best science, if the metapopulation dynamics break down, either due to changes within the subpopulation or due to the loss of connectivity (from climate change, trapping, or development), then “the entire metapopulation may be jeopardized due to subpopulations becoming unable to persist in the face of inbreeding or demographic and environmental stochasticity.” 78 Fed. Reg. at 7867.
  • Wolverines are particularly vulnerable when they leave protected areas, like Yellowstone and Grand Teton National Parks (where trapping is prohibited) or remote wilderness areas (where trapping is more difficult and less likely). As explained in The Wolverine Way, the mortality data from dispersing wolverines show they run a “fairly high risk of being killed by people outside strictly protected lands such as national parks.”
• The wolverine population in the lower 48 States lacks sufficient genetic diversity and is too small (both census and effective size) to exempt incidental take from trapping.
  • Therefore, the Service’s decision to exempt wolverine take from trapping in the interim 4(d) rule must be viewed in the context of an extremely small total population that is likely already experiencing generic drift. Unnecessarily losing two wolverines a year to recreational trapping in areas occupied by wolverine in the lower 48 States – even assuming that figure is correct – is not “minimal.” Such a loss is two too many when one considers the low genetic diversity and low effective and total population numbers in the lower 48 States and how that may affect meta-population dynamics.
• Allowing an exemption from take for trapping in the 4(d) rule cannot be viewed in a vacuum but must be considered in combination with other cumulative stressors to wolverine in the lower 48 states.
  • The Service carefully evaluates, analyzes, and considers these combined threats. Nowhere does the Service apply the best available science and evaluate how its decision to exempt trapping from take and the anticipated loss of two wolverines a year, in conjunction with existing threats from climate change, small population size, low genetic diversity, and other secondary threats may cumulatively threaten wolverine. This is a major oversight and one that, if corrected, warrants a new 4(d) rule without exemptions for take from trapping.
• No steps can be taken to “minimize” the potential incidental take of wolverines from traps and snares. 
  • The trapping exemption in the Service’s 4(d) rule exempts trapping for other species in areas occupied by wolverines, provided that trapping is done in accordance with state law and regulations and conducted “in a manner that uses best practices to minimize the potential for capture and mortality of wolverines.” But no details about what those best practices” may be, nor how they will be determined, are provided. Nor, as explained above, is there any scientific support for the notion that baited traps and snares used to catch bobcats, wolves, and other species can be modified in such a way to limit or minimize incidental take of wolverine – a fierce scavenger.