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Managing Sustainable Wolf Populations along Yellowstone's Northern Border 

ObjectiveA growing list of over 150+ businesses seek to protect the significant local economy of guides, lodging, restaurants and retail along the northern edge of Yellowstone Park, by returning to a scientific approach for wolf quotas along the northern border wherein Montana and Yellowstone National Park work together. Based on new hunting regulations introduced in August 2021 by MTFWP commissioners, up to 82 wolves could be harvested in region 3, potentially by only five individuals, with no limit in WMUs 313 and 316. In acknowledgement of social-economic feedback from local Park County businesses and individuals, in August of 2022, the FWP Commissioners voted to combine WMU's 313 and 316 in to one unit, 313, and set a quota of six wolves. We welcome all comments and feedback and desire for a civil discussion on this topic. Current wolf harvest counts. For the latest data on impacts of human-caused mortality to wolf pack dynamics see this publication.

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2023 Survey of Montanan's Tolerance of Wolves

As a result of new laws in the state legislature, Montana's Fish Wildlife and Parks Commissioners implemented new wolf harvest regulations in autumn of 2021. Although not required by this legislation, FWP commissioners voted 3-2 for replacing the limited quotas of two wolves in wolf management units adjacent to Yellowstone National Park and dramatically increasing it to a potential of 82. 

WMU's 313 and 316 are a tiny fraction of the entire state's land mass and yet represent 10% of the entire state's harvest numbers. The reason for this disproportionate harvest is obvious: these wolves primarily reside in Yellowstone Park (90%+ of the time) and den/litter therein. They are used to seeing people. And, when they travel outside of the Park to chase prey in the winter, they are sitting ducks especially in WMU 313 (surrounding Gardiner) where they can be easily seen, and are not afraid of people. It is not uncommon for a handful of hunters to sit in their vehicle, windows down and listen for wolf howls. Once heard, it is easy to reposition via dirt roads and target the wolves.

What are the implications? Yellowstone Park has been averaging about 100 wolves park-wide; conservatively, 50% of the population might be expected to move in and out of WMUs 313 and 316. Based on the 2020 Wolf Project numbers (123 wolves), 20% were killed in this hunting season. Depending on the 2021 published wolf population, that percentage could go up.


WMU's 313 and 316 (highlighted in map) represent .5% of Montana's land area but have resulted in more than 10% of the state's wolf kill/harvest quota.

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Wolf 1233 in January 2022 on YNP Blacktail Plateau before being shot weeks later in WMU 313 after the FWP Jan 28 meeting that did not close the season per our request. Photo Credit Nick Zimmer

On Jan 28th 2022, apparently responding to widespread complaints that an over-sized portion of the Region 3 harvests were coming from the sliver of land on WMU 313, the Commission held a special meeting to address the issue.  The supposed answer to the problem, at least the one they voted on, the FWP Commissioners voted to close Region 3 when the 82 wolf harvest is met, but did not vote to close WMU's 313 and 316 even though their was a motion to do, but due to a strange turn of events was dropped.


In August 2022, FWP Commissioners voted to combine 313/316 in to one unit and set a quota of six wolves. We are now working to promote civil discussion and scientific debate about how many wolves actually reside in 313, and therefore how a quota can be chosen based on actual data from the field tied to a definition of what it means to "count" the population of a species, whether it be humans or wolves or elk. Reasonable people can be united in wanting to accurately know how many elk, people, cattle, wolves, grizzlies actually occupy a landscape so that management decisions can be based on reality, not best guesses. 

As the actual collar data shows, the amount of time Yellowstone wolf packs spend outside of the park is fractional, and yet the impact of human-caused mortality is evident in pack dynamics the following years. For those of us in the tourism industry dependent upon quality experiences for our customers, the burden of proof lies with MT FWP to provide accurate population estimates in 313 (that don't double count, aka double tax, individual residency) and the impact of quotas on non-resident populations.

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Montana's Wolf Population Estimates

How We Got Here

The 2021 MWFP commissioners quota changes to WMU's 313 and 316 have set up the possibility that just a handful of actors could impact the viability of the "Yellowstone" wolf population and irreparably impact the local economy. In economic parlance, the customers travelling to Montana and spending their money here are "externalities". They bring their money to Montana, thereby contributing a higher profit margin than local economic sectors that export goods. Equally important to understand, it was totally unnecessary for the commission, many of whom are not from our area, to impose their region's high quota on our local economy. As you can see from this map, Region 3 wolf management unit is a vast section of southwest Montana. WMU's 313 and 316 represent less than 4% of that region and mostly consist of national forest, not private land, that must support multiple use. To drill down further, as of January 23, 2022, 17 wolves were taken in WMU 313. That is roughly 10% of the statewide harvest. But WMU 313 is only 0.17% of the state's total area. One wolf is 0.20% of the targeted population reduction of 450 wolves statewide. So, using basic math, if the state's objective of wolf reduction were to be met proportionately to the state's area, then only one wolf would be allowed in WMU 313. But this isn't just about basic math. Nor, is it about our business coalition. While we would welcome a seat at the policy table, we believe that scientific professionals at both the state and federal levels should be the ones telling us what it takes to manage for sustainable wildlife populations. If it had a negative impact to our businesses, then so be it. But we ask that our business voices be listened to within the broader stakeholder groups.


The prior limited quotas in Montana's northern boundary to Yellowstone Park protected wolves with summer territories within the park's boundaries but who leave each winter following prey (e.g. elk and bison). Enabling so many wolves to be killed adjacent to Yellowstone is a direct threat to the primary economy of our area. Whether you like them or not, wolves are a local economic mainstay. They are the stated primary interest of the majority of our recreational visitors to the North and Northeast entrances of Yellowstone. As many of our business owners know, trout and wolves are critical components of our supply chain. But it's not about two species. It's about protecting a dynamic, diverse, healthy ecosystem...which takes hard work and willingness to sacrifice, compromise and engage. The results can be a place full of wildlife, interacting and surviving in ways that only others can wish for. After all, we doubt that a National Park full of just grazing bison would be chosen by visitors over a dynamic, sustainable, ever-changing National Park populated by diverse wildlife and plants.

In 2021, there were 1,251,912 visitors to the northern entrances. The citizens and businesses of Livingston, Paradise Valley, Gardiner and Cooke City are service those visitors and generate tens of millions of dollars to their local economy (see multiple research reports by economists below). Although there are many reasons to visit Yellowstone, the top-ranked reason that visitors come to the northern gateways of Yellowstone is to see wildlife in the Northern Range of Yellowstone. These visitors indicate that they are here primarily to see wolves and they have spent approximately $80 million in the first 10 months of 2021 (based on calculation of wolf-dependent spending by visitors in 2005 by Duffield et. al, 2008, adjusted for inflation and the percent increase in visitors). Everything from retail to guiding services are dependent upon these consumers. For more information, see this report and here. Conversely, wolf hunting licenses cost between $10 and $50 per wolf.


Hunting, Agriculture and Tourism

Tourism, hunting and agriculture had a mostly equal standing in our area in the 1870's when Yellowstone was established. Even back then, many locals were involved in all three economies and are still today. 


There is often a misnomer in the press and social media purporting that ranchers and hunters oppose wolves, and tourists and liberal Californians moving here are for wolves. It is much more complicated than that. A simple example is that local ranchers in most of Park County have learned to live with higher wolf quotas where they operate, but allow for low quotas next to Yellowstone. Now, because of the FWP, they face federal re-listing of wolves which will result in wolf expansion in to their area. That said, livestock losses due to predators are quantified in Montana and can be studied to inform the debate. In 2019, Montana Livestock Loss Board reimbursed $82,450 for confirmed and suspected livestock depredation by wolves statewide. In Park County where WMU's 313 and 316 are only a small fraction of, $18,000 in livestock losses occurred in 2021 across the entire county. We fully support compensation for wolf predation. We acknowledge that there are costs and challenges to living with wolves here. We support ongoing solutions to address the fact that the price of local agricultural goods do not reflect the additional costs they must bear in order to operate here. We support discussions around higher compensation for predation events that cover the costs beyond the value of the materials. Many of our business members are also agricultural producers. Nonetheless, the actual commerce data shows that the economic value of co-existing with wolves in our local region of Montana is significantly greater than the agricultural economy (roughly 8:1 in terms of revenue produced just when comparing lodging receipts to agricultural receipts). Both types of businesses -- recreational tourism in all of its forms (including hunting and fishing) and agricultural -- deserve policy recognition in the context of wolves.

Our business coalition contains members from the hunting and fishing industry, not to mention many members who hunt for subsistence. We are not anti-hunting. We support equitable fair chase and subsistence hunting. Public hunting will certainly be a key tool used to manage wolves, with the North American model of wildlife conservation serving as the guiding philosophy for achieving scientifically based population objectives. We acknowledge that co-existence with wolves in human-dominated landscapes is difficult, given the economic concerns related to livestock depredation and ungulate population levels for sport hunting which is also a source of revenue. That said, the commerce data suggests that hunting revenue in southern Park County is a small subset of non-consumptive recreational revenue (e.g. wildlife viewing) in the same area (note: we support further efforts to better quantify consumptive and non-consumptive recreational tourism revenue in our area). Both types of recreational tourism businesses deserve policy recognition in the context of wolves. 


We want to be very clear: our effort is separate from campaigns by others that are focused on wolves at a state or federal level. We are only focused on wolf management within WMU's 313 and 316. As such, we call on our local state legislators, the governor's administration, and most importantly the Montana FWP Commission to acknowledge that one size doesn't fit all, that local needs and interests must be addressed in regulatory and management efforts, that state and federal professional scientists - not politics - should lead the way, and that our local job-creating, tax-paying, economically-diverse Yellowstone Gateway businesses be given a voice within both consumptive and non-consumptive stakeholder groups. To be specific, our ask is to return the quota to two wolves in WMU's 313 and 316 or to put forward a scientific study agreed to by state and federal professionals that would ensure the long-term viability of the wolves that primarily reside in Yellowstone.

Lower harvests in the transition zone around Yellowstone would conserve wolves for public viewing, support the local economy and maintain natural wolf behavior and social structure inside the Park.​ In sum, managing wolves with a conservative harvest close to the boundary of Yellowstone but using less conservative harvests farther away from Yellowstone Park within Park County (if that is what those locals so choose) could lessen much of the controversy. And, theoretically, elk populations and hunting would continue with the above target numbers that they have today.


Records from people who emigrated to the area prior to the 1870's when wolf eradication (via poisons) started to pick up  show people describing massive herds of elk (descriptions of 5,000 at a time) and other ungulates all throughout Paradise Valley north of the Park (Mammals of Yellowstone, Whittlesey et al). And...wolves. Clearly, wolves and ungulates in abundance were existing throughout the Greater Yellowstone. Then, after wolves were mostly exterminated, elk population counts started to be taken and numbers continue to decline from the 1930's onward for various reasons including commercial hunting (see graphs for information on elk populations in the northern range in and around WMU 313, taken from Yellowstone Wolves, University of Chicago Press, Smith et al, 2021). As policy changed (in part due to the hunting community) towards more of natural management state to increase elk numbers, population climbed from the late 1960's onwards to a point where forage concerns started to raise issues in the livestock industry. Montana responded with more hunting tags, but even with a record harvest in 1991, numbers continued to climb but immediately dropped prior to wolves being released in 1995. Ranchers and tourists would agree that 20,000 elk in the northern range was a one-sided benefit. After re-introduction, wolves were then one of many reasons elk numbers dropped until what looks to be an equilibrium of wolf populations and elk populations, and human harvests of elk...but other impacts like drought and fires and other predators (cougars and grizzlies) have impact on their populations as well. "There is little doubt that wolves have contributed to the recent decline of the northern elk herd. What is in doubt is the size and timing of that contribution." (p. 187, Yellowstone Wolves). Current data suggests that 10% of the adult northern herd is killed by wolves has rarely exceeded 20% when all ages are considered. In addition, elk population north of Park have climbed since 2011, to the point today, where ranchers in Paradise Valley have worked with FWP to increase elk harvest and seasons due to disease transfer issues (elk carry brucellosis and other diseases) and forage loss in their pastures. The question is whether all three stakeholder groups can work together, where wolves create balance in the elk populations, hunters still harvest good numbers of elk, and the tourist economy can be driven by wolf watchers. In fact, it seems like hunters have the slight fact, they benefit from the fact that bull to cow ratios are much better in the Park than outside of the Park; in other words, Yellowstone is providing safe haven that spills outside of the Park to the hunter's benefit. In fact, as one outfitter put it: "The problem in Paradise Valley isn't that there aren't enough elk to hunt, it's that there aren't enough bulls." You can't have your cake and eat it too: supported by management style of Yellowstone, but angry about wolves in WMU 313. Furthermore, if wolves are re-listed, then WMU 390 where most of the ranching takes place here will have to go back to a day of many more wolves in the area. We believe the compromise is obvious. Return to a conservative quota in WMU 313 and 316, and maintain the current quota elsewhere.

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Economic Risk

As visitors to southwestern Montana start to voice their opinion regarding Montana FWP's decision to disproportionally harvest wolves from WMU's 313 and 316, 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 runs at about $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. The annual "value" of a Yellowstone wolf is $500,000 to the local economy. Accordingly, in 2022, the recreational tourism economy lost $10,000,000 in "wolves", accounting for at least 33% of overall revenue.

  • 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

Our Recommendation

The below are just some of the suggestive topics we hope will inform a healthy dialog about wolf management policy in the Greater Yellowstone area.

  • All stakeholders should have a seat at the table: tourism, agriculture and hunting industries along with the general public. A 2005 detailed study showed that tourists spend conservatively $35 million annually on gateway businesses in order to see wolves. Our 2022 study shows that the economic contribution is now $82 million annually. In addition we have provided economic data that is already known about the general tourism industry in our area, and the importance of diverse types of wildlife to it.

  • Management practices should focus on a sustainable, natural wolf population for Yellowstone, rather than personal values and the survival of individual animals that capture the public's imagination. Wolf populations can be impacted by food availability (primarily elk in the northern range), other wolves (roughly 40% of annual deaths), and disease, to name just a few variables. Breeding fluctuates annually and can be impacted, for example, pack size as well as social structure (e.g. death of an alpha). Consequently, sophisticated management of harvest quotas would want to factor in not just how many wolves harvested, but which wolves harvest would impact the population base. Some ideas include:

    • No more than 5-7% of pre-hunt wolf numbers living primarily in Yellowstone should be harvested each year.

    • No more than 20% of the wolves in any given pack living in Yellowstone should be harvested. 

    • No more than 15% of the radio-collared wolves living in Yellowstone should be harvested.

    • A 24 hour closure technique is used for some ungulate species, and should be used to make sure wolf populations can be sustainable as well.

  • Shifting from rhetoric over a "Yellowstone" versus "Montana" wolf, and working as federal and state neighbors to find common ground. In the past, Montana and Yellowstone biologists agreed that a pack is considered a park pack if they spend more than 50% of their time in the park and den in the park. As one researcher working in Yellowstone Park describes how they count the Yellowstone wolf population: "We are lucky that hardly any packs along MT are even close to that divided. They are usually more like 90-95+% in YNP and 5-10% in MT, or less. The Phantom Lake pack didn't have any collars this year but we suspect they were more like 70/30 in and out of YNP. But combining all northern range packs, we still get to the ~90-95% range altogether. For lone wolves we look at their movements the previous few months and determine if they were still using YNP almost exclusively or if they had left the park study area before being harvested. Basically we try to look at the day of the harvest and ask, if today was Dec 31 would this wolf count as part of the official census. And to some people asking how we can tell. We put lots of time into getting full pack compositions with color, age and sex of every wolf. Once we know where a wolf is harvested that usually narrows it down to 1-3 packs and then we just see which one(s) are around based on collars, and match up the individuals. A double check is done that the same wolf is missing by finding them from the ground or flights." Montana FWP, in light of the large economic stakes in Park County, need to have the same sort of rigor when discussing a "Montana Wolf" that temporarily resides in WMU's 313 and 316. 

  • We acknowledge that elk population management for the sake of human harvest must be part of the dialog. Scientific approaches to the carrying capacity of elk should drive the debate. With current technology it is not possible to know the historical natural carrying capacity of elk in Paradise Valley, for example, prior to European migration here and before commercial hunting and tourism began in the mid 1800's. (Note: historical written documents show that in the 1860's prior to concerted extermination efforts of wolves, immigrants to the area were reporting elk populations of 5,000 near Emigrant Gulch with multiple wolves in the area as well.) But government elk counts from the 1930's til today show that elk numbers hit the same lows in the 70's (prior to wolf reintroduction) that they are running at today. Efforts to increase hunting in the 80's, due to loss of agricultural forage due to the elk population, did not manage to bring down elk numbers. Few who look at the data would deny that wolves impact elk population numbers. And that impact does and did impact hunting outfitters. At the same time, agricultural producers are looking to decrease elk numbers locally. And wolves drive local tourism. Policies cannot be unilaterally biased to the economy of hunting, and should include the broader economy impacted by other species. Humans and wolves benefit from elk. Humans also benefit from wolves. And other industries, like ranching, benefit from wolves harvesting elk (e.g. disease control and forage loss). Elk outfitters in Paradise Valley, for example, note that it isn't the lack of elk outside of the park, it is ratio of bulls to cows. In the Park, the ratio of bulls to cows is higher, and the outfitting industry benefits from overflow of those populations which don't contend with hunting, but do contend with wolves. Let's start the dialog over equitable use of wildlife with this information as context.


FWP's decision to remove the two-wolf limit in WMU's 313 and 316 was counter to the current administration's efforts to strengthen Montana's economy. When it comes to recreational tourism, which includes hunting, we believe that non-consumptive benefits of wolves (even when factoring in wolf impact on elk populations) far outweighs the economic advantage of hunting wolves in WMU's 313 and 316. We encourage the FWP commissioners, who represent an organization that actually receives some revenue from an economic category (i.e. lodging) driven by non-consumptive use of wildlife resources, to acknowledge that their decision to increase wolf quotas in WMU's 313 and 316 risks the politically diverse economy of our area and to return to a wolf quota in WMU 313 and 316 that results in a natural, sustainable wolf population in Yellowstone. We are very thankful to the Commissioners for hearing our civil argument and responding with a compromise that factors in the out-sized role our tourism economy plays in our local community.

Timeline of Goals

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Winter 2021

Spring 2022

Summer 2022

  • Educational Outreach & Collaboration

  • FWP District 3 Agency Meeting

  • FWP Commission Meeting

  • National Forrest Service Meeting

  • State Legislators Meeting

  • Letter to FWP Commission

  • Press Release

  • Communication via the Press

  • Local dialog over coffee, lunch and dinner to gain better understanding of various perspectives

  • Provide public input on the upcoming wolf quotas

  • FWP Commission Wolf Quota Meeting (objective reached)

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