Moffat County asks for lethal take, clearly defined compensation rules, more in wolf reintroduction plan
Local leaders have been advocating for Moffat County’s needs in the Colorado Wolf Reintroduction Plan for two years, and county commissioners recently adopted final comments to submit to Colorado Parks and Wildlife.
Jeff Comstock, natural resources director for Moffat County, presented the proposed comments to commissioners on Tuesday, Feb. 14. The now-approved letter includes three general comments and several specific comments Moffat County is asking CPW to consider before adopting the final plan.
Following the Colorado wolf reintroduction bill that was passed by Colorado voters in November 2020, CPW assembled a stakeholders advisory group, which included several ranchers, outfitters and sportsmen from the Western Slope, including Moffat County Commissioner Donald Broom.
Comstock said one of the big questions that comes up hinges on what Western Colorado will get out of all of this, especially since local voters rejected the measure.
But there are some inclusions in the plan, such as allowing the lethal take of wolves, that could benefit farmers, ranchers and outfitters in the region. Comstock said it’s rare to include lethal take for an endangered species at the start of reintroduction efforts, but Moffat County is requesting that lethal take should be an option when wolves are caught harassing or stalking livestock, not just when they are caught in the act of biting.
Broom said when he was first appointed to the stakeholders group, he felt like it might be a waste of time dealing with people on the Eastern Slope. However, Broom’s takeaway from it was that CPW officials actually listened to what the group had to say.
Moffat County Commissioner Tony Bohrer echoed Broom’s assessment, as Bohrer also said he believes the plan turned out better than he originally hoped. Bohrer remains cautious because it’s not a done deal and CPW can still make changes before finalizing the plan.
“This is one of those things that nobody asked for,” Comstock said. “We didn’t want to have to introduce wolves in Colorado. It was not something that we’ve supported, but we’re in that spot now where we have to deal with it.”
In Moffat County’s comments, local leaders advocate strongly for implementing the Endangered Species Act’s 10(j) rule, fair compensation ratios for lost livestock and compensations on all land ownership.
According to the letter, Moffat County leaders have repeatedly testified that wolves should not be released without a 10(j) rule firmly in place. The current plan “anticipates that the resulting 10(j) rule will take effect prior to the reintroduction,” but Moffat County takes the stance that the plan will be highly compromised and likely to fail if wolves are placed on the ground without the 10(j) authorization.
Moffat County is also requesting that compensation ratios for yearling cattle as it is for calves, an idea that the CPW Commission showed support for in a Feb. 7 public hearing in Rifle. The comment further advocates for compensation ratios that extend to all species of livestock where evidence of a wolf attack exists, not just sheep and cattle.
“Limiting compensation ratios to only calves and sheep sets the species or class of livestock as the determining factors for compensation, when actually, evidence of damage or loss should be the determining factor for compensation,” the letter states.
One example provided by the county is that if a wolf attacks a herd of goats and some of the goats’ carcasses are drug off-site or missing, a compensation ratio should still apply. In more specific comments, Moffat County is urging CPW to define livestock consistent with the statute, which includes cattle, horses, mules, burros, sheep, lambs, swine, llamas, alpacas and goats.
The county is also advocating for the use of two GPS collars within each wolf pack, and county officials are requesting that CPW openly shares the location data with livestock producers to give them the maximum opportunity to protect their animals.
While Moffat County believes that it is CPW’s intent to pay compensation for livestock losses across all land ownership, one section that uses the phrase, “private parcel of land,” might imply CPW may not provide compensation for livestock lost on state or federal parcels of land. As a result, Moffat County is requesting that the language be changed to specifically state compensation will occur on all federal, state and private lands where evidence of loss or damage due to wolves occurs.
Moffat County provided 18 additional comments to specific sections or statements within the wolf reintroduction plan. Some show support for the existing language, while others ask for changes or clarification.
While some of the effects of wolf reintroduction are still unknown, Moffat County is urging CPW to address the impact on hunting and outfitting prior to the industry being negatively affected.
The current plan mentions that, “additional regulatory restrictions such as shortened hunting seasons to reduce hunter success rates may need to be considered in some areas where wolves become established.” In their comments, Moffat County leaders argue it should be CPW’s responsibility to resolve these conflicts.
The county’s comments also mention that the plan is void of any discussion about the wolves that already exist in Colorado, and Moffat County is recommending additional discussions to clarify the roles of those wolves and how they will affect wolf reintroductions.
Other comments from the county urge the CPW Commission to allow for more effective population management once the numbers are established. Comstock said a frustrating piece of the plan is that there is no target population numbers for wolves where management tools would set in, as there are for other animal species.
Another large concern for the county hinges on the lack of a permanent funding source to support the ongoing wolf management efforts. The wolf program is currently being funded through the state general fund, and Moffat County is asking for close collaboration with other state programs so that funding for wolf management is not reassigned from other programs critical to Northwest Colorado.
“We also support initiatives that would apply taxes or fees to counties and citizenry that directly voted for and supported the wolf initiatives,” the letter states. “Those who asked for the wolves, should pay for them.”
Moffat County commissioners offered support to any residents who want to provide comments to CPW during the public feedback window. Colorado residents can write a letter to submit feedback on the wolf reintroduction plan. All comments must be received by CPW by Feb. 22. People may review the plan and offer comments at EngageCPW.org/comment-form.
Editor’s note: This story has been updated to clarify details about Moffat County’s comments to the wolf reintroduction plan.

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