• Update May 16:
The comment period has been extended until July 15, 2019 -11:59 pm ET. Please take the time to comment against delisting wolves. Submit your comment here.
• Update March 15:
See the proposed rule in the Federal Register here.
Submit your comment here. #KeepWolvesProtected. Talking points below. The comment period ends on May 14, 2019.
•Update March 14:
Today, the U.S. Fish and Wildlife Service (USFWS) formally announced its plan to remove ESA protections for gray #wolves in the lower 48.
The proposal will be published in the Federal Register on March 15, opening a 60-day public comment period.
Download the gray wolf delisting proposal here.
Federal wildlife officials are proposing to strip endangered species protections from the gray wolf populations in the Lower 48 states, citing significant increases in their numbers across much of the nation.
The decision was announced on Wednesday, March 5th, by David Bernhardt (@DOIDepSec) the acting secretary of the Interior Department. The proposed rule will be published in the Federal Register, with a period of time made available for public comment. When the comment period opens we will provide that link at the top of this page.
When Congress passed the Endangered Species Act (ESA) in 1973, it recognized that our rich natural heritage is of “aesthetic, ecological, educational, recreational, and scientific value to our Nation and its people.” It further expressed concern that many of our nation’s native plants and animals were in danger of becoming extinct, including wolves.
With the exception of the red wolf and mexican gray wolf, the USFWS determined the wolves a recovered species in 2013, proclaiming that “the current listing for gray wolf, developed 35 years ago, erroneously included large geographical areas outside the species’ historical range.”
What would be erroneous would be to proclaim the wolf a recovered species when the estimated population is well under 6,000 in the lower 48, occupies less than 10 percent of their historic range, with a small percent of suitable wolf habitat currently occupied, and when the Endangered Species Act dictates wolves be restored to a “significant portion” of that original range before they are ready for delisting.
“Historic range,” which, broadly stated, refers to the area a species occupied before humans began exterminating them. Yet in an interview with Lance Richardson, the Assistant Director for Endangered Species at the FWS, Gary Frazier said: “Range, is the range at the time at which we’re making a determination of whether a species is threatened or endangered.” In other words, range is where an animal lives at the particular moment the Fish and Wildlife Service decides to list it, not where it used to live before it was widely persecuted. This notion, coupled with delisting because of a taxonomic revision, a revision Fish and Wildlife Service previously rejected as representing “neither a scientific consensus nor the majority opinion of researchers on the taxonomy of wolves” plainly undermines the ESA, but was utilized as a convenient, though erroneous, way for the USFWS to delist the gray wolf.
History has demonstrated that societal values ultimately determine the survival of a species as controversial as the wolf. Wolf management evokes a wide range of public attitudes, polarized views, and prolonged contention. Removing the gray wolf from the ESA is unsettling to most Americans who enjoy seeing the wolf on the landscape and who understand how essential they are for maintaining ecosystems. Removing the gray wolf from the protection of the ESA is unlike lifting protections for any other species. Blatant hostility, as well as the vilification of these essential predators, coupled with the very poor management by individual states during delisting underscores the need for continued protection. Because of this sort of mismanagement, and the ongoing horrific slaughter of wolves allowed by individual states, those who advocate for wolves are driven to keep wolves protected.
The mismanagement of wolves:
In 2014, H.B. 470 was signed into law creating a wolf control board in Idaho with the explicit purpose of killing all but 100 of the state’s remaining 650 wolves. State officials would have preferred total extermination—Gov. C.L. “Butch” Otter said he would support public hunts to kill all but 100 gray wolves in the state once the federal government removes the animal from Endangered Species Act protections.
The governor said he hopes to shoot a wolf himself.
And Brad Corkill—“If every wolf in Idaho disappeared I wouldn’t have a problem with it,” the new Fish and Game commissioner declared at his confirmation hearing.
The fact is that in 2011, when the government began stripping wolves of their protection under the Endangered Species Act, transferring “management” to the states an “all-out” war against the wolf began, and by December 2014 over 3,400 wolves had been slaughtered in just six states, more than 1,956 in Idaho and Montana alone. In December 2014, U.S. District Judge Beryl Howell said the management plans of the three states that allow sport hunting of the wolf (Wisconsin, Michigan and Minnesota) didn’t provide enough protection, and noted that the animal had not repopulated its historic range, reinstating their protections. The judge said that the removal was “arbitrary and capricious” and violated the federal Endangered Species Act.
But in Montana and Idaho the killing continues. In 2011 a policy rider, (the first time legislation has ever removed ESA protections for a species) on a key appropriations bill, stripped Endangered Species Act protections for gray wolves in Montana and Idaho. The rider precluded the possibility of judicial review, making the delisting of wolves in Montana and Idaho virtually permanent. In Montana approximately 225 wolves are “harvested” per year. During the 2017-2018 wolf season, 255 wolves were slaughtered: 65 percent from hunting and 35 percent from trapping. In Idaho there is no “harvest” quota (beginning in 2017) as no quota (limit) had been reached over 7 years.
Wyoming is home to approximately 347 wolves, with the species state managed. (Federal appeals court upheld the U.S. Fish and Wildlife Service’s 2012 decision to remove gray wolves in Wyoming from the endangered species list in March 2017). And so in Wyoming, wolf hunting is legit—365 days a year across 85 percent of the state, where wolves are classified as shoot-on-sight vermin. Guns, snares, explosives, trucks, and snowmobiles—almost any form of violence is allowed to kill these animals. Today anyone in most of Wyoming can kill wolves without a hunting license. The other 15 percent of the state, concentrated around the Jackson Hole area and the Tetons, is the “trophy area” where wolves may be seasonally hunted from October 1 to December 31.
In Wisconsin, the population of wolves was just 800 in 2011, yet in a matter of three years (since delisting, and before court ordered relisting), Wisconsin lost at least 518 wolves to legalized hunting, hounding, trapping and annual unenforced quota overkills. The 518 wolves killed does not include wolves killed at the request of livestock operators for “depredation control” (170) or wolves killed on roadways every year (25). In addition, it is difficult for agency staff to estimate how many wolves are poached, which is estimated, conservatively at 100 a year. Considering annual wolf pup mortality at up to 70 percent, and the human take of wolves in Wisconsin, this was a disaster of catastrophic proportions. Hardly a wolf management plan integrating the “best available science.”
Wisconsin’s Department of Natural Resources (WDNR) has systematically underestimated how many wolves are killed by poachers each year. And without an accurate estimate of the population size and the threats they face, hunting quotas could potentially imperil Wisconsin’s wolf populations again.
This moral bankruptcy and ineptness is not a way to treat a species immediately after removel from the safety net of the ESA.
Until our state governments can evolve, stop catering to whims of the few, listen to the majority of their constituents, and follow good science our wolves need to remain under government protections. Period.
Stand for Wolves—Be Their Voice
By December 2013 the proposal to delist wolves under the Obama administration attracted more than 1 million comments, ranging from passionate personal pleas to analytical legal responses; most of these comments were amassed by conservation groups and delivered just before the closing of the comment period. When the comment period opens this year, please take the time to send your own personalized objection to the removal of gray wolves from ESA protections in the contiguous U.S. (with the exception of the Mexican gray wolf, which remain protected as a subspecies). If federal protections are stripped from nearly all gray wolves across the lower 48, wolves in historically occupied areas like the southern Rockies and Northeast may never be able to establish viable populations despite suitable habitat and availability of prey. Gray wolves are now just beginning to reestablish stable populations needed for genetic sustainability, and although wolves have recovered in some states, the North American population as a whole is nowhere near “recovered.”
With such a small percent of suitable wolf habitat currently occupied and almost constant threats to their survival, these apex predators still urgently need the Act’s protection to survive.
We must learn to respect, rebuild and conserve ecosystems not just by simple fixes, such as reintroducing species, but by finding ways to mitigate the conflicts that originally caused their loss. The exigency for a natural balance in our ecosystems cannot be overemphasized, as well as the need to acknowledge that this balance is not possible without apex predators, such as the wolf.
Wolves are essential.
• regulate ecosystems
• promote biodiversity
• enrich soil nutrients
• feed scavengers
• keep coyotes in check
• suppress disease transmission in deer and elk
• keep down overgrazing
• combat climate change
• generate ecotourism
Adversaries of wolf protective laws and legislation continue their court battles against the wolves, but those on the side of the wolves have an important weapon in their arsenal — the restoration of entire ecosystems (even if such benefits are not immediately obvious). Disruption
of large carnivore populations has led to crop damage, altered stream structures, and changes to the abundance and diversity of birds, mammals, reptiles and invertebrates. Game animal populations have greatly increased without large carnivores, crippling the growth of young trees and reducing biodiversity. This also contributes to deforestation and results in less carbon sequestration, a potential concern with climate change. In order to maintain the resilience
of forest ecosystems, (especially in the face of a rapidly changing climate), the recovery and preservation of large carnivores is essential. Wolves are endangered in most of the nation and need continued protection to survive and completely recover.
Lost in endless bitter arguments over wolf management is any attempt to clarify state agencies’ obligation to their citizens. Scientists and conservationists assert that wolf populations are not yet viable, and that distributions are not sufficient to constitute recovery. More importantly, existing regulations are not adequate enough protection to ensure persistence of population numbers. The Wildlife Trust Doctrine, a branch of the Public Trust Doctrine, defines the obligation of the states responsibility and obligation to its citizens, and dictates that wildlife has no owners at all, and therefore belongs to all citizens equally. As a result, states have a “sovereign trust obligation” to ensure that wildlife resources are protected and managed responsibly, not just for the benefit of current citizens, but also over the long term. The Wildlife Trust Doctrine imposes a duty to ensure proper protection for the gray wolf, as well as any other species no longer (or never) protected by the federal government.
“As they have demonstrated time and again, large carnivores will not stay within human defined safe zones. We need to learn to share the land and its bounty with them, to live with them, or we will lose them—and with them a considerable part of what makes us human.” Mark Derr, Saving The Large Carnivores, Psychology Today
Wolf and ungulate populations and wolf control:
Michigan deer population increases
Yellowstone’s ungulates after wolves
Wolves and the Ecology of Fear: Can Predation Risk Structure Ecosystems?
Feature image by Michael Schönberger
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