Wyoming Game and Fish Puts Politics Above Science By Delaying Migration Corridor Designation

By Mountain Pursuit

Wyoming Game & Fish Department leadership has delayed identifying migration corridors for the Sublette Pronghorn and Wyoming Range Mule Deer herds in response to last-minute concerns raised by industry groups representing ranching, mining and oil and gas.

Mountain Pursuit strongly disagrees with the delay, and urges Department leadership to proceed with identifying and designating these corridors

“The Department’s decision to delay is disturbing,” explained Mountain Pursuit Board President Rob Shaul.

“The Sublette Pronghorn and Wyoming Range Mule Deer Herd migration corridors weren’t created out of thin air,” he continued, “but rather were identified after years of tracking collared animals, thousands of GPS data points, and detailed statistical analysis. The agency announced public meetings and asked for public comment starting in early February. These industry groups were given plenty of notice and time to share their perspectives when the rest of us did.”

“By delaying designation over these last minute concerns from industry, Game & Fish Department leadership has loudly pushed aside hard biological science because of political controversy.”

The Department alone has the authority to designate migration corridors, which is simply mapping and identifying them, under a “Ungulate Migration Corridor Strategy” approved by the Game and Fish Commission in early 2016. Industry and agricultural groups, as well as conservation and hunting organizations, were heavily involved in the drafting of that strategy.

“There is nothing new about the Department following a three-year old strategy to identify where big game herds move between their ranges,” Shaul pointed out.   

The Wyoming Game & Fish Department, United States Geologic Survey, and University of Wyoming have spent hundreds of thousands of dollars funding ungulate migration corridor research throughout Wyoming, and the state’s efforts are pioneering the field throughout the West. The Department has already designated three mule deer migration corridors in the state.

Importantly, both herd populations which use the migration routes in question are far below population objective.

According to the latest statistics available on the Wyoming Game & Fish website, the Sublette Pronghorn Herd is 25% below it’s population objective of 48,000 animals, and the Wyoming Range Mule Deer Herd is 23.8% below it’s population objective of 40,000 animals. 

“Migration route designation and subsequent protection are key to bringing these herd populations back,” continued Shaul. “Department leadership undercut its own field biologists and other researchers with its decision to delay designation.”

“The Wyoming Game & Fish Department has always prided itself on basing management decisions on science,” he concluded. “This delay jeopardizes the Department’s credibility and sets a disturbing precedent that should worry all of Wyoming’s hunters.”

Below is the comment letter sent to the Wyoming Governor Mark Gordon concerning his Draft Migration Corridor Executive Order:

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January 14, 2020

To: Mark Gordon, Governor of Wyoming
Fm: Rob Shaul, Mountain Pursuit Board President
Subj: Comments to the Draft Migration Corridor Executive Order

Governor Gordon, 

Mountain Pursuit is a new, non-profit (501 (c)(3)) hunting advocacy organization headquartered in Jackson. Mountain Pursuit was founded by multi-generation Wyoming natives.

We are significantly disappointed with your Draft Migration Corridor Executive Order. 

Specifically we disagree that future Migration Corridor designation would be subject to corridor protection/mitigation agreement, not scientific fact. 

This makes a biological fact (migration corridors) determined by scientific, field-based observations subject to political negotiations and consideration. Doing so undercuts the biologists and other wildlife professionals at the Wyoming Department of Game and Fish and University of Wyoming, guts the entire Migration Corridor designation process and puts at risk big game herds in Western Wyoming already far below population objective.

To be clear, big game migration corridors are not political constructs. Rather, they are the result of hard edged scientific method, and identified though years of GPS collaring, sophisticated mapping and pioneering data analysis. Wyoming has lead the United States in big game migration corridor identification methodology. 

Mountain Pursuit is not ignorant to the political considerations and compromises of migration corridor protection and mitigation, but these should come after the designation, not before. 

Under your draft executive order, if the different interests could not agree on corridor protections, the corridors would not be designated. This guts the entire process and intent and makes us wonder whether you believe in scientific method. 

Further, the mitigation steps outlined in your draft order are weak. While your draft order seems to prohibit surface disturbance inside the corridor bottleneck and stopover areas, we feel the order should go further, and also establish 1/2 to 1-mile no surface development buffer zones bordering these and the high traffic critical areas. 

Finally, we are significantly disappointed with your decision to insert yourself in the designation process. We believe your actions have unnecessarily and directly threatened the designation of the Sublette Pronghorn and Wyoming Range Mule Deer Herd migration corridors. 

Don't you know that according the Game & Fish, in 2018 the Sublette Pronghorn Herd was 21.9% below population objective, and the Wyoming Range Mule Deer Herd was 24.5% below population objective?

These big game herds are Wyoming treasures, in dire need of our attention and protection. 

We ask that you reconsider your executive order, put science ahead of politics, and work with  Mountain Pursuit and others to protect our the health and future of our big game herds.

Respectfully,
Rob Shaul
President, Mountain Pursuit