The U.S. Fish and Wildlife Service proposal to remove the gray wolf from Endangered Species Act protection raises questions about the trade-offs between science-based decision making and political pressure. A group of 16 leading wolf research scientists has raised serious questions about the scientific basis of the proposal to 'de-list' the wolf. This in turn raises the question of whether the Obama administration is once again setting science aside when its message is politically inconvenient.
On June 7 the U.S. Fish and Wildlife Service, an agency of the Department of the Interior, proposed to remove the gray wolf (Canis lupus) from the list of threatened and endangered species. The FWS proposes to maintain protection and recovery efforts for the endangered Mexican wolf in the Southwest. The gray wolf has been protected under the Endangered Species Act since 1973, after being exterminated from the lower 48 states by the mid-20th century.
The FWS de-listed the gray wolf from the ESA, declaring the population to be recovered and no longer threatened, in the Western Great Lakes region (Minnesota, Wisconsin, and Michigan) in 2011 and in the Northern Rocky Mountains region (Montana, Idaho, Wyoming, and eastern portions of Washington and Oregon) in 2012. Under the new proposal, states would be responsible for managing and protecting the wolves under wolf management plans where they are currently present, and in areas into which they might migrate (such as Washington, Oregon, North Dakota, Utah, and Colorado).
“Wolves are recovered and they are now in good hands,” according to FWS director Dan Ashe. “States are the most competent people to make the decisions in the future about how many wolves” there should be and “where wolves can add value to the landscape in the years ahead.”
However, on May 21, 16 leading wolf scientists, "collectively representing many of the scientists responsible for the research referenced in the draft rule," wrote to Interior Secretary Sally Jewell and Dan Ashe calling into question the scientific legitimacy of the FWS proposal. (Read the full letter and list of signers here.) The letter, written after an advance view of the draft rule, says in part:
Based on a careful review of the rule, we do not believe that the rule reflects the conclusions of our work or the best available science concerning the recovery of wolves, or is in accordance with the fundamental purpose of the Endangered Species Act to conserve endangered species and the ecosystems upon which they depend. ...
The letter raises four issues bearing on the science-policy relationship including:
1) Removal of the gray wolf from the List of Threatened and Endangered Wildlife
The gray wolf has barely begun to recover or is absent from significant portions of its former range where substantial suitable habitat remains. The Service’s draft rule fails to consider science identifying extensive suitable habitat in the Pacific Northwest, California, the southern Rocky Mountains and the Northeast. It also fails to consider the importance of these areas to the long-term survival and recovery of wolves, or the importance of wolves to the ecosystems of these regions.
2) Maintain endangered status for the Mexican wolf by listing it as a subspecies
Although the taxonomic distinctness of the Mexican wolf is well-supported, and we thus support subspecific listing as appropriate, the draft rule fails to delineate the geographic extent of the area in which wolves would receive protection, specifying only that Mexican wolves would be protected “where found”. Genetic analysis of historic Mexican wolves showed that the range of the Mexican wolf likely extended beyond the historic range initially inferred from limited record data. At the same time, the Service has inexplicably delayed completion of the recovery plan for the Mexican wolf, the draft of which had concluded that habitat to the north of the current recovery area may be essential for recovery of the subspecies. The lack of specificity in the rule, coupled with past actions by the Service, encourages continued efforts by stakeholders to block recovery actions essential to recover a subspecies that is among the most endangered mammals in North America.
The letter concludes:
The extirpation of wolves and large carnivores from large portions of the landscape is a global phenomenon with broad ecological consequences. There is a growing body of scientific literature demonstrating that top predators play critical roles in maintaining a diversity of other wildlife species and as such the composition and function of ecosystems. Research in Yellowstone National Park, for example, found that reintroduction of wolves caused changes in elk numbers and behavior which then facilitated recovery of streamside vegetation, benefitting beavers, fish and songbirds. In this and other ways, wolves shape North American landscapes.
Given the importance of wolves and the fact that they have only just begun to recover in some regions and not at all in others, we hope you will reconsider the Service’s proposal to remove protections across most of the United States.
Western politicians and livestock ranchers do not find this message congenial. For them, it is too pro-wolf, too in favor of increasing wolf populations and geographic ranges.
During the comment period the Interior Department can expect to hear from those who support the views expressed by the scientists, and by environmental and conservation groups. Our friends at the Center for Biological Diversity issued this statement on June 7 (excerpt):
Obama Administration Strips Wolf Protections
Across Most of Lower 48 States
WASHINGTON— In a move questioned by some of the world’s leading wolf researchers, the Obama administration announced plans today to prematurely strip Endangered Species Act protections from gray wolves across most of the lower 48 states, abruptly ending one of America’s most important species recovery programs. ...
“This is like kicking a patient out of the hospital when they’re still attached to life support,” said Noah Greenwald, endangered species director with the Center for Biological Diversity. “Wolves cling to a sliver of their historic habitat in the lower 48, and now the Obama administration wants to arbitrarily declare victory and move on. They need to finish the job that Americans expect, not walk away the first chance they get. This proposal is a national disgrace. Our wildlife deserve better.”
Wolves today occupy just 5 percent of their historic habitat in the continental United States. Today’s proposal means that wolves will never fully reoccupy prime wolf habitat in the southern Rocky Mountains, California and Northeast, and will hinder ongoing recovery in the Pacific Northwest.
The proposal will hand wolf management over to state wildlife agencies across most of the country – a step that has meant widespread killing in recent years. Following removal of protections for wolves in the northern Rocky Mountains and western Great Lakes in 2011, states in those regions quickly enacted aggressive hunting and trapping seasons designed to drastically reduce wolf populations. In the northern Rocky Mountains more than 1,100 wolves have been killed since protections were removed; this year populations declined by 7 percent.
“By locking wolves out of prime habitat across most this country, this proposal perpetuates the global phenomena of eliminating predators that play hugely important roles in ecosystems,” said Greenwald. “Wolves are well documented to benefit a host of other wildlife from beavers and fish, to songbirds and pronghorn.”
“The centuries-old war against wolves continues to rage, particularly in states where the species has lost federal protection in recent years, as management of wolf populations was turned over to the states. ...”
Wolf management in [the] states is often driven by politics, and wolves are being killed at alarming rates in the name of sport in all but Michigan.
For instance, most of the nearly 1,700 wolves surviving in the West lived in Montana, Idaho and Wyoming at the end of 2012. Those states now have recreational hunting and trapping seasons, and in the past two years, nearly 1,200 wolves have been killed. Nearly 400 more were killed for attacking livestock. ...
Last year, wolves killed 645 of the estimated 7 million cattle and sheep in Idaho, Montana and Wyoming [i.e., about one in 11,000]. Those wolves can be killed legally; a federal fund also compensates farmers and ranchers for their losses. But these predators are critical components of the ecosystem, a so-called keystone species. Their presence can keep populations of browsing animals in check and on the move, allowing vegetation to regenerate. They are true ecological assets, but not if they are reduced to ecologically irrelevant numbers.
The problem is that wolf management continues to be hijacked by hunting and livestock interests. ...
In Idaho, hunters and trappers killed 698 wolves in the last two seasons — more than the estimated population of 683 wolves in the state at the end of 2012. In more than 80 percent of Wyoming, anyone can kill as many wolves as they wish, without a license. Hunters and trappers in Montana will each be allowed to kill up to three wolves this winter. (In Idaho, the number is 10.) Beginning this fall, hunters in Wisconsin can use dogs to track and chase wolves — a scenario that all but amounts to state-sanctioned animal fighting.
Where management has been transferred to the states, America’s wolves have fallen under an assault of legislation, bullets and traps. A conservation victory is quickly turning into a conservation tragedy. Now the Obama administration is proposing to remove virtually all remaining protections. Have we brought wolves back for the sole purpose of hunting them down?
Our friends at Public Employees for Environmental Responsibility (PEER) have filed a federal lawsuit to obtain all the internal government documents relating to the decision to de-list the gray wolf. In particular, PEER says, a 'National Wolf Strategy' was developed starting in 2010 in a series of closed-door federal-state meetings called 'Structured Decision Making', or SDM. PEER is seeking to obtain all the SDM documents. PEER said in a May 22 statement (excerpt):
SUIT TO UNCOVER POLITICAL DEALS BEHIND GRAY WOLF DE-LISTING
Closed-Door Meetings Honed Plan to Strip Gray Wolf Endangered Species Status
... “By law, Endangered Species Act decisions are supposed to be governed by the best available science, not the best available deal,” stated PEER Executive Director Jeff Ruch, pointing to a letter from the nation’s leading wolf researchers challenging the scientific basis for the de-listing plan. “The politics surrounding this predator’s legal status have been as fearsome as the reputation of the gray wolf itself.”
The SDM meetings included most states involved with gray wolf conservation. PEER charges that the resulting National Wolf Strategy used political and economic factors to predetermine the answer to scientific questions, such as the biological recovery requirements for wolves and ruling out areas in states within the species’ historical range which lack sufficient suitable habitat.
Other documents earlier uncovered by PEER show eligible habitat for Mexican wolves was severely limited by a related series of political federal-state deals. ...
“This closed-door process lacked not only transparency but also integrity. It involved no independent scientists, let alone peer reviewed findings,” Ruch added. ...
Some people doubtless would prefer to see the gray wolf population driven to the lowest level possible consistent with keeping the animal de-listed from federal protection. But to what extent should such 'stakeholder' perspectives be given essentially a free pass by federal policy, as it turns the problem over to state governments -- which are notoriously driven by parochial stakeholder interests in many areas of policy? Is there a national interest, a general social interest, to be protected here? People around the country whose preference is to give the wolves a high level of protection might wish to have a say in this.
How about this? If states must have federally approved wolf management plans in order to be given the management authority, then let the federal government set criteria that constrain human predation on wolf populations. Can scientific research -- can this include social and economic research? -- assess the potential risk to the gray wolf from the destabilizing and population-weakening influences of human predators? Can the federal government require, as a condition of approval of state wolf management plans, that the plans demonstrate how the risk from humans will be characterized and managed so as to allow wolf populations to thrive -- and to migrate into the Pacific Northwest, California, Colorado, Utah, and the Northeast -- without being decimated by the actions of human predators? Is the federal government intending to wash its hand of the problem and allow those states to decide whether to allow viable wolf populations to move there?
Short of ensuring real protection, will the Obama administration be making itself complicit with "the centuries-old war against wolves"? Will they have, in effect, "brought wolves back for the sole purpose of hunting them down?"
The FWS will open a 90-day comment period when the proposals are published in the Federal Register (scheduled the week of June 10). ... This is an opportunity to make a statement to the federal government, not only about wolf management but about human predator management.
Some talking points for your letter are below - remember that it will be most effective written in your own words, from your own experience. Your letter will be most effective if you focus on a few key points, so don’t try to use all of these. If you need additional help or want someone to review your letter before you send it, email it to firstname.lastname@example.org.
Talk about your personal connection to wolves and why the issue is important to you. If you’re a grandmother wanting your grandchildren to have the opportunity to hear wolves in the wild, or a hunter who recognizes that wolves make game herds healthier, or a businessperson who knows that wolves have brought millions in ecotourism dollars to Yellowstone, say so.
Point out that the scientists whose research is referenced in the draft rule to remove the gray wolves' protections have stated in a recent letter that the science does not support the delisting.
Express your support for relisting Mexican wolves as an endangered subspecies and point out that delisting gray wolves throughout the U.S. is counter to protecting Mexican wolves. Fewer than 80 Mexican gray wolves exist in the wild. New populations of these wolves are desperately needed for them to thrive. But the draft plan would leave gray wolves unprotected in places where this endangered subspecies could and should live. This will make protection of Mexican gray wolves much more difficult should they expand into Utah or Colorado and make it unlikely that any wolves will be able to naturally reestablish a presence in the Southern Rockies, a region with excellent suitable habitat where wolves were once found.
Describe the ecological benefits of wolves to entire ecosystems and all wildlife. Wildlife biologists believe that Mexican wolves will improve the overall health of the Southwest and its rivers and streams – just as the return of gray wolves to Yellowstone has helped restore balance to its lands and waters. Science has repeatedly demonstrated that wolves are keystone carnivores who help to keep wildlife like elk and deer healthy and bring balance to the lands they inhabit.
Thank you for taking action today for wolves!