The Rewilding Institute Comments on Gray Wolf Delisting and Peer Review

TRI Comments on Gray Wolf Delisting and Peer Review

Originally published March 25, 2014 - The Rewildlige Institute

Attn: FWS–HQ–ES–2013–0073

Division of Policy and Directives Management
U. S. Fish and Wildlife Service
4401 N. Fairfax Drive MS 2042-PDM
Arlington, VA 22203

The Rewilding Institute (TRI) appreciates the opportunity to comment on: Endangered and Threatened Wildlife and Plants; Removing the Gray Wolf (Canis lupus) From the List of Endangered and Threatened Wildlife and Maintaining Protections for the Mexican Wolf (Canis lupus baileyi) by Listing It as Endangered and the peer review of that document.

ACTION: Proposed rule; notice of availability and reopening of comment period.

These comments have been prepared by TRI’s Carnivore Conservation Biologist, David R. Parsons. Mr. Parsons served as the U.S. Fish and Wildlife Service’s (FWS) first Mexican Wolf Recovery Coordinator from 1990-1999 and was the primary author of the original rule that established a Nonessential Experimental Population of the Mexican Gray Wolf in Arizona and New Mexico. Mr. Parsons has continued to follow the progress of the Mexican wolf recovery program from his retirement from FWS in 1999 to the present day. Mr. Parsons holds B.S. and M.S. degrees in Wildlife Biology, served as a career wildlife biologist for FWS for 24 years, and has lectured nationally and internationally on wolf biology, ecology, and conservation.

We remain concerned about ongoing and potential further delays by the FWS in advancing the conservation and recovery of the critically endangered Mexican gray wolf (Canis lupus baileyi).  The FWS has acknowledged that at even the currently authorized population objective of 100 wolves in the Blue Range Wolf Recovery Area (BRWRA), Mexican wolves will remain in danger of extinction.  At a most recent population estimate of only 83 wolves with deleterious levels of inbreeding, Mexican wolves need aggressive recovery actions immediately.

Currently, the proposal to list Canis lupus baileyi as an endangered subspecies is an integral part of the proposal to remove all other presently listed gray wolves (Canis lupus) within the United States from the list of endangered species, and thusly end their protection under the Endangered Species Act (ESA).

A FWS-initiated peer review has concluded that the science that the FWS relied upon to support their proposal to delist gray wolves is not the best available science.  This makes the proposed delisting of gray wolves in violation of the ESA mandate that decisions made pursuant to the ESA be based on the best available science.

Given that FWS has reissued for a second public review the exact same proposal found by the peer reviewers to be scientifically deficient, it is not clear if FWS plans to make any substantive changes to the proposed delisting rule before issuing the final rule.  We are assuming here that FWS will either (1) issue the final delisting rule without substantively addressing the scientific deficiencies found by the peer reviewers, or (2) further delay the release of a final rule to allow FWS biologists time to address the scientific deficiencies found by the peer reviewers.  Either scenario will have adverse consequences for the critically endangered Mexican gray wolf as we explain below.

We note, however, that the peer reviewers and the FWS are in agreement that Canis lupus baileyi is a unique and taxonomically distinct subspecies of Canis lupus deserving of separate protection and recovery actions under the ESA.  And in fact, FWS has proposed the separate listing of the Mexican wolf within this proposed rule.  The only disagreement between the peer reviewers and the FWS is over the probable historic range of the Mexican wolf.  This disagreement is essentially rendered moot by language in the proposed list rule declaring Mexican wolves to be endangered “where found.”

Disagreement over the extent of the Mexican wolf’s historic range is best addressed by the Mexican Wolf Recovery Team using the best available science and settled in a final Mexican Wolf Recovery Plan, not in this proposed rule.  The work of the Mexican Wolf Recovery Team, suspended since November 2011, needs to be resumed immediately.  While not procedurally necessary, it appears that FWS is waiting for the promulgation of the final rule placing Mexican wolves on the endangered species list before resuming work of the recovery team.

History has shown that proposals by the FWS to remove gray wolves from the endangered species list have always been litigated, often delaying or even reversing actions proposed by the FWS.  And history has shown that the FWS tends to suspend legitimate recovery actions for Mexican wolves in the face of litigation over proposals related to other gray wolves.

Furthermore, there is no scientific disagreement over the FWS’s proposal to list Canis lupus baileyi as an endangered subspecies of the gray wolf.  And Mexican wolves are in critical need of recovery actions that are hampered by current regulations and the lack of a current recovery plan based on the best available science (see comments submitted by TRI on the draft proposed rule for Mexican wolves dated 10/24/2013 and incorporated in their entirety here as Appendix A of these comments).

Therefore, to enhance the likelihood of survival and recovery of Mexican wolves, it follows that FWS must decouple the proposal to list Canis lupus baileyi from the proposal to delist gray wolves elsewhere.  No legitimate purpose is served by continuing link these two distinct actions into one combined process that is destined to be litigated solely over the gray wolf delisting part of the proposal.

As for the proposal to delist Canis lupus, TRI recommends that the FWS honor the independent peer review process and base its final decision on the best available science.

As for the proposal to list Canis lupus baileyi TRI recommends that FWS issue an expedited final rule completing this action separate from the gray wolf delisting proposal.  And we further recommend that the existing Mexican Wolf Recovery Team be reactivated immediately with a goal of completing a science-based recovery plan as soon as possible.

As always, The Rewilding Institute appreciates this opportunity to comment on these proposals.

Sincerely,

David R. Parsons
Carnivore Conservation Biologist

PLEASE CLICK HERE TO READ THE ENTIRE DOCUMENT, INCLUDING APPENDIX A

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Wolves and the Ecology of Fear

Video Story by Michael James Werner for QUEST Northwest on Mar 06, 2014

Does “the big bad wolf” play an important role in the modern-day food web? In this video we journey to Washington State’s Cascade Mountains, where the return of wolves could have a profound impact on a vast wilderness area. We meet up with biologist Aaron Wirsing to explore why wolves and other top predators are needed for diverse ecosystems to flourish. Using a simple video camera (a “deer-cam”) Wirsing is gaining a unique perspective on predator/prey relationships and changing the way we think about wolves.

Wolves in the Crosshairs:  Q&A with conservationist, Fred Koontz

Dr. Fred Koontz

Gray wolves are in the crosshairs of a heated conservation debate, with the federal government trying to strip all protections for them in the continental U.S. Dr. Fred Koontz, vice president of field conservation at Woodland Park Zoo, Seattle, has worked in conservation for three decades and has studied the wolf issue. We talked with Dr. Koontz about the future of wolves in the U.S. and the role they play in maintaining healthy ecosystems.

Wolves may be the most polarizing animal in North America, more so than other large carnivores like cougars or grizzly bears. Why?The gray wolf is one of the world's most adaptable and widely distributed mammals, ranging over much of Asia, Europe, and North America. Wolves, the size of a German shepherd, are pack-hunting predators that sometimes kill livestock. Combined with wolves’ nocturnal behavior and haunting howling, this has resulted in a long history of conflict with people, especially as human numbers have increased exponentially in recent centuries and agricultural lands expanded into wolf habitat. There are, however, very few documented cases of wolves attacking people, but the rare times it’s happened it’s been sensationalized and blown out of proportion.

How have your perceptions or understanding of wolves changed over the years?At an early age, my mother read with much theatrical expression “Little Red Riding Hood,” which, like many children, left me fearing the “big bad wolf.” This negative image was reinforced with similar wolf-themed horror movies that I ashamedly spent far too much time watching in my youth. Only when I studied ecology and animal behavior in college and as a wildlife professional did I see a different image of the wolf. Wolves are important regulators of prey numbers and behavior, and as such, influence a web of ecological interactions that enrich biological diversity. I learned also that among many adaptive traits enabling their evolutionary success, wolves have a rich social life and extraordinary set of communication behaviors. The more I learned, the more fascinated I became in understanding how wolves and people might live together for their mutual benefit.

Gray wolves have been taken off the federal endangered species list in some states, such as Idaho, Wyoming, and Montana. And a recent federal proposal would strip all gray wolves in the continental U.S. of their federal protection. How did this come to be? What kind of politics are at play?

Gray wolves can come in an assortment of colors, such as these all-white wolves. Photo courtesy of Ryan Hawk, Woodland Park Zoo, Seattle.

Under the Endangered Species Act, the U.S. Fish and Wildlife Service (USFWS) in 1974 first listed gray wolves as endangered in the lower 48 states. Now they propose to remove them from the ESA list. This idea follows from three decades of actions undertaken by federal, state, and local partners that resulted in population recovery and delisting in 2011 of wolves living in the western Great Lakes states and northern Rockies. With about 6,000 wolves residing in these two recovery areas, USFWS believes that the gray wolf population in general is well established and stable enough to warrant delisting. Many state wildlife officials welcome the move as they are eager to take back the management authority for animals within their political borders.

However, many conservation scientists and wolf advocates believe that more time on the endangered species list — and [under] federal protection — would allow wolves a greater opportunity to reclaim more of their former territory and grow the number of their populations. This is important because, despite wolf recovery success in the Great Lakes states and Rocky Mountains, there is still a lot of their former range not yet occupied. Expanded range and more populations, in turn, will provide greater species resiliency to unexpected environmental disruptions like climate change and emerging diseases and also improve long-term wolf survival in the U.S.

An independent review panel recently found that the federal government used uncertain science when it proposed removing the gray wolf from the endangered species list across the lower 48 states. What could that mean for the future of wolves?
This is important because under Endangered Species Act law the U.S. Fish and Wildlife Service is obligated to use the best available science. The Service claimed that new genetic research indicated that wolves living in the eastern U.S. were actually a different species, and thus should not be considered as part of the original listing or part of the historic range. The expert panel said the genetic research was uncertain and based largely on one paper. The panel’s report has reopened the debate about delisting gray wolves, and I suspect it will extend the time wolves remain listed. The final decision on delisting is yet to be determined — public comment is encouraged. [Note: deadline is March 27, 2014]

In the long run, the debate about delisting wolves invites larger questions like, what constitutes full recovery of any endangered species, and does the legal framework of the ESA reflect current conservation science and principles of sustainable living? Most importantly, there needs to be agreement at the onset about the ultimate purpose of recovery — is it simply species survival or restoring ecological function? There are no easy answers.

Mule Deer photo courtesy of Lauren Sobkoviak.

Is it possible for wolves and humans to coexist? What needs to change for that to happen?
I think that wolves and humans ultimately will coexist by sharing land in two key places — protected areas and rural areas managed for the benefit of people and wildlife, for example, park buffer lands, multiple-use public lands, and designated wildlife corridors. For the reconciliation between wolves and humans to prove fully successful, we will first need a broader understanding of the role that apex predators play in creating healthy ecosystems and why healthy ecosystems are needed by people. In other words, there must be a broader understanding of why saving wolves is essential to sustainable living. Greater public will to save wolves will result in increased public spending needed to conduct science and carry out sound management actions. For example, we need more research on improving ranching practices to minimize wolf predation of livestock, and insurance programs that compensate ranchers for unavoidable losses. There is already good evidence from pilot efforts that such research and management programs are possible — and that they work!

Why should people care about the fate of wolves?
The fate of wolves is tied directly to the greatest challenge facing humankind this century —  sustainable living! With more than seven billion people consuming resources at an accelerating pace, this generation of world citizens must transform our societies to sustainable ones. We must, among other things, protect a wide variety of animal and plant species — scientists call this “biodiversity.” Many conservation scientists believe that apex predators (animals at the top of the food chain), like wolves, are necessary to maintain habitats rich in life. In turn, high levels of biodiversity bring many direct benefits to people — everything from providing food and fiber to protecting water supplies and enriching recreation.

Biologist Aaron Wirsing for the University of Washington (right) and graduate student Justin Dellinger (left) radio collar deer with video cameras in order to better understand predator-prey dynamics. Photo courtesy of Greg Davis.

Understanding the links between apex predators and biodiversity is a growing area of research for scientists like Aaron Wirsing of the University of Washington. Since 2008, wolves have been returning to Washington and have reestablished populations in the U.S. northern Rockies. This has provided a unique research opportunity for Wirsing and other scientists. For example, deer populations in Washington have likely over-browsed plants for decades in the absence of gray wolves. One consequence of deer eating trees along streambeds is less habitat for birds, and streams that are more likely to harbor fewer cold-water fish like trout because they are filled with sediments from soil erosion and overheated because of lack of shade. With wolves back in the state, Wirsing is leading a study to document how wolves are changing mule and white-tail deer populations, which in turn affects forest landscapes.

Why do you care about wolves?
I care about wolves because as apex predators they contribute significantly to enriching biodiversity needed by people for sustainable living. I also care about wolves because I admire them! Wolves are amazing for many reasons, but I am especially fascinated by their complex social behavior and adaptable lifestyles, two traits that they share with humans. Also, one of the most important reasons I care is that wild wolves in the U.S. are a symbolic way of keeping our American heritage of wilderness alive.

EXPOSED - USDA's Secret War on Wildlife

By Darryl Fears, Published: December 15
Washington Post

They say U.S. critter assassins work in secret, quietly laying traps, lacing food with poison, sniping at targets from helicopters. Few people know exactly how the hits go down; the methods are largely hidden.


What’s certain is that the U.S. Department of Agriculture’s little-known Wildlife Services program kills up to 3 million animals a year, mostly those deemed a nuisance but also some that agents kill by mistake, including endangered species.


Now, in a turnabout, the hunter is the target. A petition seeks to reduce the power of Wildlife Services and shine a light on its practices, claiming its agents have “gone rogue,” overstepping the mission to protect the public by killing indiscriminately.


There’s no dispute that Wildlife Services plays a valuable role by eliminating invasive animals such as nutria and starlings that are a menace. But critics have questions: How many is too many? Does the agency euthanize wildlife too often on behalf of farmers and ranchers without regard to ecosystems?


The petition filed in December of 2013 by the Center for Biological Diversity isn’t the first time that animal rights activists have squared off against Wildlife Services, but this time their coalition includes politicians who agree that the agency is too secret and too deadly. Even some federal workers frown on it; staff members at the U.S. Fish and Wildlife Service quietly dismiss Wildlife Services agents as “gopher chokers.”


“Wildlife Services is one of the most opaque and obstinate departments I’ve dealt with,” said Rep. Peter A. DeFazio (D-Ore.). “We’re really not sure what they’re doing. I’ve asked the agency to give me breakdowns on what lethal methods they’re using. They can’t or won’t do that. We’ve asked them to tell us what goes into their poisons. They won’t say.”


DeFazio and several colleagues requested a congressional hearing on the agency’s practices without success, so they pushed the USDA inspector general to conduct an audit, which was announced this month.


“The WS program is inefficient, inhumane and in need of a review,” the lawmakers wrote in a September letter to Inspector General Phyllis Fong. They said that the frequent killings of top predators, such as wolves, bears and coyotes, benefit “a small proportion of the nation’s private agriculture” and other interests.

Wildlife Services said in response that it has nothing to hide. Answering questions by e-mail, a spokeswoman said that the bulk of its work is to protect humans.

“For example, we work with the aviation community to protect the public by reducing wildlife hazards at more than 800 airports around the country,” spokeswoman Lyndsay Cole said. “Wildlife Services’ efforts to protect threatened and endangered species are conducted in more than 34 states. Wildlife Services also operates the National Rabies Management Program, which distributes oral vaccines in 16 states.”


Read more . . . 

Hunters are conservationists? Maybe many years ago . . . not today.

By Georger Wuerthner - The Wildlife News - March 5, 2014

Many hunter organizations like to promote the idea that hunters were the first and most important conservation advocates. They rest on their laurels of early hunter/wildlife activist like Teddy Roosevelt, and George Bird Grinnell who, among other things, were founding members of the Boone and Crocket Club. But in addition to being hunter advocates, these men were also staunch proponents of national parks and other areas off limits to hunting. Teddy Roosevelt help to establish the first wildlife refuges to protect birds from feather hunters, and he was instrumental in the creation of numerous national parks including the Grand Canyon.  Grinnell was equally active in promoting the creation of national parks like Glacier as well as a staunch advocate for protection of wildlife in places like Yellowstone. Other later hunter/wildlands advocates like Aldo Leopold and Olaus Murie helped to promote wilderness designation and a land ethic as well as a more enlightened attitude about predators.

Unfortunately, though there are definitely still hunters and anglers who put conservation and wildlands protection ahead of their own recreational pursuits, far more of the hunter/angler community is increasingly hostile to wildlife protection and wildlands advocacy.  Perhaps the majority of hunters were always this way, but at least the philosophical leaders in the past were well known advocates of wildlands and wildlife.

Read more . . . 

Should the Wolf continue to be protected?

From: VIRGINIA MORELL, SCIENCE
Published February 9, 2014 08:03 AM

The ongoing battle over a proposal to lift U.S. government protections for the gray wolf (Canis lupus) across the lower 48 states isn’t likely to end quickly. An independent, peer-review panel yesterday gave a thumbs-down to the U.S. Fish and Wildlife Service's (USFWS's) plan to de-list the wolf. Although not required to reach a consensus, the four researchers on the panel were unanimous in their opinion that the proposal "does not currently represent the 'best available science'"

"It's stunning to see a pronouncement like this--that the proposal is not scientifically sound," says Michael Nelson, an ecologist at Oregon State University in Corvallis, who was not one of the reviewers. Many commentators regard it as a major set-back for the U.S. Fish and Wildlife Service (FWS), which stumbled last year in a previous attempt to get the science behind its proposal reviewed.

The USFWS first released its plan for removing the gray wolf from the endangered species list in June 2013. The plan also called for adding the Mexican gray wolf, a subspecies that inhabits the southwest, to the protected list. At the time, there were approximately 6,000 wolves in some Western and upper Midwestern States; federal protections were removed from the gray wolf in six of those states in 2011. More than one million people have commented on the plan. But regulations also require that the agency invite researchers outside of the agency to assess the proposal's scientific merit.

At its core, the USFWS proposal relies on a monograph written by its own scientists. They asserted that a different (and controversial) species, the eastern wolf (Canis lupus lycaon) and not the gray wolf, had inhabited the Midwest and Northeast. If correct, then the agency would not need to restore the gray wolf population in 22 eastern states, where gray wolves are no longer found.

But the four reviewers, which included specialists on wolf genetics, disagreed with the USFWS's idea of a separate eastern wolf, stating that the notion "was not universally accepted and that the issue was 'not settled'"—an opinion shared by other researchers.  "The designation of an 'eastern wolf' is not well-supported," says Carlos Carroll, a conservation biologist at the Klamath Center for Conservation Research in Orleans, California, who was not a member of the review panel.

Idaho damages its public image as well as its rural economy

Idaho Statesman - Guest Opinion

BY DORI BROGLINO AND PETER SPATZ

January 15, 2014 

Read more here: http://www.idahostatesman.com/2014/01/15/2973739/idaho-damages-its-public-image.html#storylink=cpy

On a crisp December morning at the edge of the Lamar Valley in Yellowstone National Park, a steady stream of cars flowed to a pullout that was filled with hopeful visitors braving frigid temperatures in the predawn light to catch a glimpse of a pair of wolves that had been feeding on a road-killed bison. We were among the fortunate ones who got a parking spot that morning and were rewarded with a view of the wolves trotting along the creek bank in the early morning light, making for a magical, wild sight.

We returned to our car and soon heard a short news report on the wolf and coyote derby to be held in Salmon. A few days later while reading The New York Times, an editorial titled "wolf haters" negatively portrayed Idaho as it described the upcoming wolf derby, as well as Idaho Fish and Game's recent hiring of a professional wolf killer in the Frank Church-River of No Return Wilderness. The wolf derby not only infuriates the conservation community, but also many hunters interested in promoting ethical, fair and respectful hunting. The conservation community is questioning the legality of the hired hunter as a possible violation of the Wilderness Act. These recent events resulted in worldwide negative publicity for Idaho and have likely alienated potential visitors. Instead, Idaho could capitalize on tourism dollars by promoting the lucrative wolf-watching industry.

Look at Gardiner, Mont., as an example of a rural community benefiting from the presence of wolves. Just outside the north entrance to Yellowstone, we observed a bustling winter economy, largely driven by wolf watchers staying in hotels, patronizing restaurants and hiring wildlife watching outfitters. Couldn't and shouldn't Idaho foster this sustainable form of tourism in its rural communities instead of creating opportunities for the media to depict a state paralyzed by irrational fear and loathing of a predator that is a natural and important part of the state's ecosystems?

Some folks will cite the damage caused by wolves to Idaho's elk herds and livestock, as well as some who espouse the dangers to life and limb of just having predators in our midst, but consider some information that provides a more balanced view of the role of wolves and other wildlife here in Idaho:

• The amount of compensation paid to ranchers and farmers by Idaho Fish and Game related to wolves has been less than the amount of claims paid out for crop losses due to elk.

• Though wolves are vilified for preying on elk, black bears and mountain lions, whose populations far outnumber wolves, are major predators of elk.

• There are no documented cases of a wolf in Idaho injuring or killing a person. However, the Idaho Department of Transportation reports that since 1997, more than 27 human deaths resulted from vehicle collisions, mostly involving deer and elk.

• Other states have greater densities of both people and predators. Minnesota, Wisconsin and Michigan have approximately 2,000, 800 and 700 wolves, respectively. Densely populated New Jersey now has approximately 3,500 black bears. Idaho, on the other hand, appears to be fearfully preoccupied with fewer than 700 wolves.

There is a complex picture of how the wolf fits into Idaho. It's unfortunate that recent publicity has depicted our state as intolerant, disrespectful and ignorant with regard to dealing with this animal.

We need to repair this image, investigate additional ways to coexist, determine whether there are opportunities to embrace the wolf-watching economy in rural Idaho, and ensure that a more balanced picture of the wolf is presented to the country and the world.

Broglino is an environmental professional. Spatz is a scientist with the Department of Interior. They live and work in Boise.

Read more here: http://www.idahostatesman.com/2014/01/15/2973739/idaho-damages-its-public-image.html#storylink=cpy

Plan to delist gray wolf endangers other threatened species, researchers find

The federal government's proposal to discontinue protection for the gray wolf across the United States could have the unintended consequence of endangering other species, researchers say.

As written, scientists assert, the proposed rule would set a precedent allowing the U.S. Fish and Wildlife species.

Service (FWS) to declare habitat unsuitable for an endangered animal because a threat exists on the land – the exact opposite of the service's mandate to impose regulations that reduce threats against imperiled 

The FWS has "conflated threats with habitat suitability" by stating that U.S. land currently unoccupied by wolves – most of the country that historically served as wolf habitat – is now unsuitable because humans living in those regions won't tolerate the animals, the lead scientist said. This claim runs counter to existing research, which the service did not cite in its explanation of the rule.

"The Fish and Wildlife Service is supposed to detail what the threats are and if they're substantial enough, they're supposed to list a species and put in place policies to mitigate the threats," said Jeremy Bruskotter, associate professor in The Ohio State University's School of Environment and Natural Resources and lead author of the paper.

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