ACT NOW! Submit Comments on the Mexican Wolf Draft Recovery Plan
Electronically: Go to www.regulations.gov and enter FWS–R2–ES–2017–0036
Public Comments Processing
U.S. Fish and Wildlife Service, MS: BPHC
5275 Leesburg Pike
Falls Church, VA 22041-3803
- This draft recovery plan gives state agencies veto power over critical releases and translocations that are necessary for the genetic rescue of the wild Mexican wolf population. This is an abdication of federal responsibility, and shows that the current administration is intentionally weakening federal oversight and giving far too much power to the states. The U.S. Fish and Wildlife Service cannot decide it does not want to recover the Mexican gray wolf on behalf of the American people --that is its job. The state agencies it wishes to transfer power to are the very same agencies that have blocked wolf releases and recovery in general. How can we expect them to suddenly begin working to save the species? This is a serious dereliction of duty.
- This plan, as written, relies on state cooperation over a course of at minimum twenty years. It is extremely unlikely that the state agencies tasked with releasing wolves can be expected to cooperate for this long or even at all, given that they have yet to cooperate. The plan does not begin to explain how enforcement of the release plan will occur, if at all, and the Service is relying on the states to be truly interested in recovery and delisting, contrary to the abundant evidence to the contrary that both Arizona and New Mexico have moved to limit critical wolf releases in recent years. There is no failsafe plan if the states refuse to cooperate; the entire recovery plan could be botched on this basis.
- There is also no mechanism for compensatory releases in response to illegal killing of wolves. There should be a replacement policy that discourages poaching and encourages states to contribute to law enforcement within the recovery area.
- The U.S. Fish and Wildlife Service is required under the Endangered Species Act to incorporate the best available science into its Mexican gray wolf recovery plan. Unfortunately, it has scrapped its duty in order to attain the best political deal the agency could find, a political deal that would send the Mexican gray wolf to extinction. The Service has chosen to make hostile players happy rather than uphold its duty to consider the best available science. It is not clear that the current models consider all the factors contributing to improvements in breeding success.
- The state agencies that played a central role in drafting this plan have published articles that are being used to show that recent science supports this plan, but the authors have serious potential conflicts of interest that cast a doubt on their findings.
- What happens if the targets outlined in the plan are not met? The plan should account for this scenario by including a mechanism whereby state involvement is constrained in the event the targets are not met.
- This draft recovery plan’s downlisting and delisting criteria, which effectively lessen protections, are seriously flawed. The U.S. Fish and Wildlife Service wants to reduce wolf protections after 22 wolves released from captivity have reached breeding age, but with no requirements that they actually be breeding pairs or that they produce any pups. Why not wait till they have actually had pups? The Service claims this plan will solve the dire genetic situation the Mexican gray wolf is in, yet it’s very possible none of the 22 released wolves would contribute to strengthening the gene pool. The criteria should be based on what actually happens rather than what could happen. The criteria should also specify a benchmark of genetic diversity in addition to target number of individuals. Simply ensuring they reach breeding age is not the same thing as actual breeding. Additionally, the low population increase predicted in the next few years is worrisome. An increase of just seven wolves before 2022 is a lackluster effort at a critical time. This should be increased to reflect the current estimated population and a growth rate of at least 10 percent from that.
- This plan calls for delisting the Mexican gray wolf when the population in the U.S. is only half the size recommended by scientists on the U.S. Fish and Wildlife Service’s previous planning team. These experts found 750 wolves in three U.S. locations including the Grand Canyon region are required for the population to be viable. Sadly, the U.S. Fish and Wildlife Service is ignoring the recommendations of credible scientists who worked on recovery planning in 2011. Instead, the agency has caved to the demands of state agencies that want to keep the wolf population unsustainably small and do not want to see wolves north of I-40. There is no scientific rationale for limiting their expansion northward and this is a clear political compromise that undermines the science.
- We support and applaud the efforts underway to recover the Mexican gray wolf in Mexico. However, this plan relies substantially on Mexico for the recovery program, and rests heavily on the historic range of the species to justify this move. It does not consider the realities on the ground now and in the future. Mexico does not have enough public land to support a sustainable population of Mexican gray wolves, and the area the Service is proposing they use has a higher density of livestock than the more suitable areas identified in the U.S. We also don’t know if there is suitable social tolerance for the species in Mexico, yet polling shows strong support for Mexican gray wolves in the U.S. And Mexico does not have nearly as much law enforcement to minimize poaching. Additionally, the funding for the Mexican wolf recovery program in Mexico is uncertain. The Service is asking another nation to do our work to recover the species to appease some politicians, not because it’s the best thing for the species. Moreover, as climate change continues to cause species to shift territory within the suitable habitat, the Recovery Plan should focus on suitable habitat to the north such as the Grand Canyon and Southern Rockies.
- This plan rightly identifies connectivity between wolf populations as critical to success of the species, yet it does not adequately address or ensure connectivity between the proposed population in Mexico and the population in the U.S. Currently there is a barrier across parts of the international border, plans for a wall along the entire border, and a record of removing wolves who try to move between the two populations. The plan rests on translocations to initially improve genetics in the wild populations for a limited duration, then assumes translocations will not be needed after the species is recovered. This essentially proposes two separate, disconnected populations, which is far from what scientists have recommended.
- The recovery plan should also provide funding for compensated voluntary permit retirement of public lands grazing allotments in an effort to reduce livestock conflicts and improve natural prey base. Habitat management is a critical component of recovering any species, but this seems to be overlooked in the current proposal.
- This entire recovery planning process is a sham. The previous efforts to draft a plan rested upon the best available science. The current draft plan rests on science drafted by agency staff with conflicts of interest, and was planned behind closed doors. It places critical decision-making powers in the hands of political actors--state agencies that have impeded Mexican wolf recovery at every turn. The result is a plan for extinction, not for recovery.