Response from Wild Livelihoods Business Coalition

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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 Their financial analysis is out-of-date, not based on standard financial metrics that actual businesses and economists use, and, at best, nebulous in its case.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.

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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.

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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.

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Our response to their "economic analysis" is:

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• 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 https://www.wildlivelihoods.com/economic-data 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 https://liv.mt.gov/Attached-Agency-Boards/Livestock-Loss-Board/Livestock-Loss-Statistics-2022 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.

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