Aug. 2, 2016
Public Comments Processing
Attn: FWS-R3-ES-2016-0061
U.S. Fish and Wildlife Service
5275 Leesburg Pike
Falls Church, VA 22041-3083
RE: Petition to List the U.S. Population of Andersoni Moose as a Threatened or Endangered Distinct Population Segment (Docket ID: FWS-R3-ES-2016-0061)
To Whom It May Concern:
The North Dakota Stockmen’s Association is an 87-year-old beef cattle trade organization representing more than 3,000 cattlemen and cattlewomen across the state. We appreciate the opportunity to comment on the Petition to List the U.S. Population of Andersoni Moose as a Threatened or Endangered Distinct Population Segment.
We were surprised to learn that the moose was being considered as a threatened or endangered species in North Dakota, among other states. Our landowner members have anecdotally reported many sightings of the moose in North Dakota, including many outside the animal’s traditional range. This suggests to us that the population is still vibrant. It is also able to support between 100 and 150 moose licenses in North Dakota each year, according to North Dakota Game and Fish Department data. North Dakota is the only state in the proposed listing area currently hunting moose.    
The North Dakota Game and Fish Department is in the midst of a multiple-year research project to estimate annual survival of adult female moose; examine cause-specific mortality of adult female moose; estimate moose reproduction rates; examine annual and seasonal movements and home ranges of moose in northwest North Dakota; evaluate seasonal habitat selection by moose; evaluate the effect of energy development on moose space use; and evaluate moose movements and habitat use with respect to seasonal temperature changes. Certainly, completion of this research will generate valuable data regarding species viability that will help us better understand factors impacting the state’s moose population.
Findings to date point to the unique features of North Dakota’s moose population, including its excellent survival rate (97.5 percent annual survival rate of the cow moose); excellent pregnancy rate (95 percent); and prolific calf production (including a 36 percent twinning rate).  
The agency has also noted that moose in what is considered traditional habitat in North Dakota are subjected to brainworm due to a higher prevalence in white-tailed deer; winter ticks due to habitat; and, potentially, liver flukes. Moose have died from brainworm infection, which is a potential factor for population trends. Even after hunting has been closed in this area since 2006, there are not signs of recovery. In other words, the population has not been impacted by no hunting and, therefore, placing the animals on the threatened or endangered list likely wouldn’t impact the numbers either.
We maintain that North Dakota’s moose population is still vibrant and, thus, it is inappropriate to place the animal on the threatened or endangered species list. Such action would do little to boost numbers, but negatively impact landowners who would be required to adhere to certain management schemes because of the listing and/or subsequent critical habitat designations.
Additionally, the North Dakota Game and Fish Department is still working on a multi-pronged research project that will likely answer many, if not all, questions about the moose population in the state. Until that is done, it is premature to consider any type of listing.
Thank you for the opportunity to comment.
Steve Brooks