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Response to Montana 2023 Wolf Plan

Objective: In December, FWP staff will hold virtual and in person public meeting to answer questions about the plan and EIS. The draft 2023 Montana Gray Wolf Conservation and Management Plan incorporates updates in wolf-related research, more than 20 years of management experience, evolution in conflict management, new laws, social perspectives and public input. For more information about the draft 2023 Wolf Plan and draft EIS, please go online here.

Wild Livelihoods Business Coalition members, devoted to sustainable populations of wildlife for all, will be attending this meeting to present a detailed position statement (see below) with respect to FWP's one page "economic argument" for their 2023 Wolf Plan. We welcome civil discussions, pros and cons (regardless of your perspective), on our argument.

The Region 3 meeting will take place in Bozeman on December 5th from 6-8 pm in the FWP Office at 1400 South 19th Avenue, Bozeman MT. A virtual meeting option is available on December 12th; register here.

FWP's "Economic Discussion" from pp. 33-34 of the draft 2023 Wolf Plan

The following text in italics is quoted verbatim from Montana FWP's draft 2023 Wolf Management Plan. Items highlighted in bold are specifically addressed in Wild Livelihoods Business Coalition response.

Wildlife in Montana has contributed to increased tourist interest and visitation to the state. Visitors rated mountains, Glacier and Yellowstone national parks, rivers, open space, and wildlife as the top six attractions to the state, respectively (Parrish et al. 1997, Dillion and Nickerson 2000). In 2017, nonresident visitors to Montana spent $3.36 billion, supported 53,380 jobs and contributed to 58% of all dollars in the state. Montana ranks second of western US states in visitor spending per capita, with the travel industry focused in the western half of the state and 40% of vacationers participating in wildlife viewing (Nickerson et al. 2019). Since the reintroduction of wolves, the visitation to YNP has increased an estimated 3.7% due to wolf presence, specifically. Wolf centric ecotourism has brought an estimated $35.5 million (confidence interval of $22.4 to $48.6 million) additional tourism dollars into the local economies in the GYA (Duffield et al. 2006). Wildlife-viewing is associated with an influx of cash and sales amounts during the third quarter of the year in western Montana, with spending predominately in retail and grocery (41%) and tourism (e.g., restaurants and lodging, 34%; Montana Dept. of Commerce 2021). However, these quantifications are not wolf-specific. The 2010 mean per capita income for Montana cities in the GYA ranged from $17,810– $31,618 (Gardiner, West Yellowstone, Red Lodge, and Cooke City; 2010 Demographic Profile Data, US Census Bureau 2010). Although ecotourism is touted as a viable, sustainable way of generating economic activity through “low-impact” use of natural resources, ecotourism has potentially negative consequences. Risks to resources include increased infrastructure development, habitat degradation, wildlife disturbance, and an erroneous perception that ecotourism leads to long-term protection of environmental assets (Isaacs 2000). Positive economic benefits are expected for businesses related to tourism, outdoor recreation, and national park visitation.


In contrast to the benefits wolves provide for the ecotourism industry, other segments of the economy can be negatively affected by wolves. Livestock producers may experience significant direct and or indirect economic impacts due to wolf presence or depredation. In the most recent published report, the percentage of calf deaths attributed to predators increased steadily from 3.5% in 1995 to 11.1% in 2015. In Montana, total cattle and calf losses cost about $55,135,000, with injuries due to predators costing an additional $223,000. However, only 2.0% of cattle deaths and 9.8% of calf deaths were due to predators, with 10.2% and 12.8%, respectively, of those depredations attributed to wolves (USDA 2015). Losses due to predators amounted to 5% of the 2020 sheep and lamb supply and 47.2% of all sheep and lamb deaths, costing about $3.57 million in losses, though coyotes are the primary culprit of sheep depredations (Sommer 2021). From 1987–2003, livestock producers in the NRM that experienced wolf-livestock depredations averaged $11,076.49 per year in losses (Muhly and Musiani 2009). Specific wolf-livestock depredation compensation can be found in Part IV of this document. Producers could have other losses beyond what is confirmed and documented, and it is difficult to estimate economic losses due to unconfirmed or undocumented livestock losses or the indirect economic costs associated with wolf presence. Indirect financial expenses of wolf presence may include non-lethal predator control, increased human resources to prevent predator conflicts, and stress-induced declines in livestock health and weight gain as a result of harassment by wolves. However, Ramler et al. (2014), found no evidence that wolves had any detrimental effects on calf weights and other non-wolf factors (e.g., climate, husbandry practices) better explained variation in calf weight. For hunting-related businesses such as outfitting, economic losses may be associated with decreased hunter opportunity (i.e., reduced tags) or fewer recreational days afield (i.e., shorter seasons), which ultimately may reduce hunter expenditures or participation rates. Declines in predicted annual big game hunter spending associated with ungulate declines and restrictive harvest opportunities, was estimated to be $187,000 to $464,000, with Wyoming estimating a reduced hunter spending of about $2.9 million (Duffield et al. 2006). Hunter opportunity may fluctuate based on prey densities and distributions as they relate to population objectives. As a result, the license dollars and revenue that funds wildlife and habitat management efforts, may be negatively impacted (see Part V).

Response from Wild Livelihoods Business Coalition

Wild Livelihoods 200+ business owners are providing the following response to FWP's 2023 draft Wolf Management Plan.


While FWP leadership in Helena acknowledges the economic value of wolves and other wildlife to the general tourism industry, the bulk of their comments are devoted to the "costs" of wolves. Their financial analysis is out-of-date, not based on standard financial metrics that actual businesses and economists use, and, at best, nebulous in its case. A standard economic analysis - just the data - would have been a better approach, rather than bleeding in to "values" over wolves.

As such, their analysis reveals biases that:

  • They refuse to use the most recent economic data.

  • Ecotourism cannot be a force for "habitat" improvement.

  • It is not clear why FWP included our local "mean" income. How is it relevant? Our business owners would be happy to share their personal incomes and show that we are middle class families making a good living from wildlife and are paying our taxes and feeding our families and sending our kids to college.

  • Livestock predation costs cannot be weighed relatively against tourism revenues.

  • Hunting opportunities, albeit a minority within the context of our local tourism GDP, should be factored in to wolf management. No one in our membership is opposed to hunting, since many of our members actually hunt for food. We do, however, champion un-biased, accurate economic analysis to the standard of professional CFO’s.

If FWP-Helena wants to talk about "values", then regions should be allowed to vote as to their "values" with respect to wolves in their region. Wild Livelihoods business members have always maintained the position that they are not going to impose their values on other regions of Montana. But we do not appreciate other regions, especially Helena bureaucrats, imposing their pedagogy on our local community.

Our response to their "economic analysis" is:

  • Let’s take advantage of the most recent, scientific economic data in the 2023 wolf plan, in terms of revenues and costs, and lay that out in a format that would be familiar to any CFO or CPA or even the average Montanan who knows how to balance their checkbook. As it stands, the economic section is a set of statistics with little comparative value when getting at the elephant in the room: stakeholder values.

  • Discussions of economics should involve Montana's Department of Commerce (one of the few representative agencies of the $5B+ tourism industries in Montana), and the pro-business Governor’s office, who has been very engaged in supporting the small tourism business operators in Park County after the flood. We believe that continual dialog between the Department and Commerce and FWP, in the same way FWP refers to its collaboration with Department of Livestock, will result in the best economic data being used when considering FWP decision making in the context of the public trust. This sort of clear economic reporting will become more necessary as the debate over cougars, grizzly bears and wolves continue.

  • NON-RESIDENT SPENDING: Use the best current economic science from Department of Commerce’s own 2022 data (you can find it here or via ITRR and various links at the Department of Commerce site). 2022 data shows that $5.82 Billion was spent by 12.5 million visitors. And of course, they can break that down even further by regional districts, including our own here in the Yellowstone Country Tourism district, which makes up $1.5B in that spend. Park County alone (the gateway to the north entrance of Yellowstone) generated $337,272,00 in non-resident spending. And, hopefully someday, DoC will resume publishing the resident spend, which will only drive this number higher. Our point is that FWP is quoting all hunter economic data, and DoC is only quoting non-resident spend (of which, of course, hunting is a small sub-group of that spend).

  • WOLF CENTRIC TOURISM: Please use the most current scientific economic data on wolf tourism, as completed by individuals at ITRR and RCC (you can download it here). By extrapolating the increased visitation to Yellowstone, as you have done in your comments below, a more accurate conservative estimate of wolf tourism is $82 million annually for gateway communities; and since Park County is associated with the northern range of Yellowstone where wolf watching is the easiest, we would expect that a large portion of this $82M falls within that county's economy.

  • NEGATIVE SIDE EFFECTS TO TOURISM: There is no need for you to use the term “ecotourism” and its “environmentally friendly” connotation. Economic data should simply be about categories and revenues and costs. We know that “tourism” isn’t non-consumptive or always “low-impact”. It is what it is, and our members work diligently to protect wildlife for everyone (including hunters) and the economics should be reported as is. If you ARE going to leave these comments in about the negative impacts of tourism, then for the sake of integrity include a discussion of the negative impacts of ranching and fencing on both private and public lands. And the negative impacts of private land sub-development. And the negative impacts of “poaching”. The biases of your author(s) are showing through in your report. Just give the economic facts. And then maybe talk about positive ways that locals like us are working with ranchers and tourism operators (including the small subsection of outfitters) to ensure sustainable wildlife populations for future generations.

  • LIVESTOCK LOSSES: Improve this section with clearer language about the total dollar estimate in losses due to wolf predation, not lumping it together with all predators. And provide an ANNUAL number so that like in any P&L (profit and loss statement) the timeframes are consistent across economic categories. For example, you aren’t honestly claiming that predators killed $55M in cattle and calves. Montana’s Livestock losses website reports payments of $241,000. And, using your cited statistics of wolf depredation rates, the annual cost of cattle losses due to wolves would have been less than $10,000. We support fair compensation of ranchers impacted by predation. But don't make us do the math on wolf-predation and make assumptions. Provide the actual estimated annual dollar cost of wolves predating on livestock. Once you do that, weigh those losses as an operating expense against the revenue of tourism to come to a true operating income number (do a P&L analysis of the issue). And if you’re going to do an apple’s to apple’s comparison with tourism revenues generated in gateway communities (since you mention YNP and Glacier several times), at the very least, call out that in Park county in 2022 we had 2 predation events…and compare that to the out weighted tourism revenues in a year where the Park was closed to tourists. Furthermore, any competent CEO would counter that even in “wolf country” the year over year increase in predation events doesn’t apply…why…because the year over year increase you site from 1995 to 2015 is due to dispersal of wolves. Once wolves are dispersed across Montana (and let’s say for the sake of argument that they are now), then you start comparing year over year increases…not prior to complete dispersal. Any CEO or CFO would see that that statistic is not very valuable when comparing the economic costs to the economic revenues. Finally, if you’re going to talk about “soft” costs of livestock depredation, then talk about the “soft” costs of tourism depredation when bad press covers the 2022 quota increase next to Yellowstone. Be consistent when covering nuanced, "soft costs" economic data; or, just stick to the data that is not disputed.

  • HUNTING OPPORTUNITY LOSSES: If you are going to claim that there is an opportunity cost to hunting revenues due to predations, then provide an estimate of that cost based on wolf predation of ungulates. Is your data saying that wolves caused the loss of $187k to $464k of lost big game spending? Or did wolves cause a subset of that overall loss? If you’re going to do opportunity costs for hunters, then do the same for property sub-development, or human population growth, industrial development, or anything that reduces habitat and causes a loss in hunter revenues. In addition, provide opportunity cost estimates if wolves are eliminated from the equation. At the very least discuss the potential tourism opportunity costs IF wolf quotas are increased surrounding national park boundaries. Be consistent on nuanced discussions of “opportunity costs” across all revenue categories. Or, don’t discuss them at all and reveal bias. The point of an economic discussion should be to show everyone clearly where the revenues are coming from and what the costs of the revenues include.

  • FINAL COMMENT: Site your economic data based on annual $ amounts so that people can easily see the annual revenue and annual costs under discussion. All modern CFO's require a year-over-year, and quarter-over-quarter comparison of revenues and costs. Don’t provide “totals over vast distances of time” and confuse the issue. Use a standard P&L format with consistent timelines for each category.

Economic Risk

As visitors to southwestern Montana start to voice their opinion regarding how Montana wants to manage wildlife (including carnivores), they are making it clear as to if they want to spend their money here. ​Here are a few economic highlights with respect to recreational tourism in our area (for more data, see here) and the impact that wild places have on it.

  • One and only year-round driving entrance to Yellowstone National Park.

  • 22% of all labor income fueled by travel, tourism and recreation.

  • Park County alone generates roughly $500,000,000 in tourism revenue annually. To put that in perspective, all of Park County's annual agricultural revenue in the last census ran $34,000,000 ($24m in livestock and $10m in crops). Based on the 2021 estimated predation losses (of all kinds), less than .075 percent of that revenue was lost to predation.

  • Lodging/accommodation wages and revenue are the largest economic category in our region. Lodging tax revenue for Park County, driven in large part to Yellowstone National Park visitation, in 2021 generated almost $3,400,000 for Montana's general fund, various heritage programs and recreational use programs, including FWP. 

  • Small business proprietors (or self-employment) represents a significant portion of all employment in Park County, accounting for 39% of all jobs in 2014.  This has grown over the last decade from about one-third of all jobs before 2000 and this growth has been entirely among non-farm proprietors.  Statewide in Montana proprietors accounted for 27% of all jobs in 2014, up only slightly from 26% in 2000. 

  • A 2017 survey of non-resident tourists visiting Montana shows the time spent on various activities ranked as:

    • 56% Scenic driving

    • 36% Day hiking

    • 34% Wildlife watching

    • 29% Nature photography

    • 26% Camping

    • 24% Recreational shopping

    • 19% Visiting other historical sites

    • 17% Visiting local brewery

    • 12% Visiting museums

    • 12% Visiting Lewis & Clark sites

    • 9% Fishing / Fly Fishing

  • As the rate of tourism goes up or down, which business/retail categories categories are impacted the most (ranked in descending order according to the State Department of Commerce expenditure categories):

    • Gasoline Outlets (e.g. Town Pump)

    • Restaurant & Bars

    • Hotel & Motel

    • Outfitter & Guides

    • Retail Sales

    • Grocery Stores

    • Auto Rentals

    • Rental Lodging

    • Campground & RV Parks

    • Vehicle Repairs

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