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

- Read more . . .  

The NRDC's Non-Lethal Methods to Prevent Conflicts Between Predators and Livestock

Every year, the U.S. Department of Agriculture's Wildlife Services program kills thousands of predators as a taxpayer-funded subsidy to the livestock industry, using controversial and inhumane methods such as poisons and aerial gunning. Wildlife Services largely ignores the many non-lethal ways to prevent conflicts between predators and livestock. In fact, a small, but growing number of ranchers are turning away from Wildlife Services’ “sledgehammer” approach and emphasizing non-lethal conflict-prevention techniques because they recognize that predators are an integral part of the landscapes where they ranch.

Wildlife Services needs to end the use of inhumane, hazardous, and environmentally harmful poisons—specifically, Compound 1080 and sodium cyanide—to kill predators. Instead, the agency should employ non-lethal conflict prevention methods. Specifically, Wildlife Services, and the private parties it assists, should be required to use, or attempt to use, nonlethal deterrence methods before resorting to lethal control. 

Click here to download more information 

about non-lethal methods from the NRDC.

Support the NRDC

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.

The Reintroduction of Wolves Into Yellowstone

Greater Yellowstone Coalition - WOLVES from GYC on Vimeo.

.

Nearly 1,650 wolves roam the Northern Rockies, in 250 packs with more than 110 breeding pairs. About 500 call Greater Yellowstone home and an estimated 80 wolves live within Yellowstone National Park.

GYC continues to monitor wolf numbers in Greater Yellowstone. Meanwhile, Yellowstone wolves are still playing their ecological role.

A report from Oregon State University plant researchers William J. Ripple and Bob Beschta reinforces the belief that the wolf has been the primary factor in the improved health of aspen, willow, and cottonwood trees in Yellowstone National Park's Northern Range. This in turn has benefitted such Yellowstone wildlife as beaver, bison, pronghorn, songbirds, raptors, and trout.

The return of the wolf has changed elk behavior and reduced some herds, but overall numbers remain strong in Idaho, Montana and Wyoming. According to Yellowstone biologist Doug Smith, the Yellowstone herds remain healthy despite its smaller size. The number is more in line with historic levels since wolves were reintroduced and grizzly bears and mountain lions returned naturally. Overall elk populations in the states of Idaho, Montana, and Wyoming remain healthy. However, elk populations are now more dynamic with the return of large carnivores and elk distribution has shifted to areas of refugia which make them more difficult to hunt.  Elk populations are affected by many variables including weather, disease, predation, and human mortality.

The Greater Yellowstone Coalition has consistently worked to find the middle ground on wolf management, to move beyond the ongoing conflicts. They continue to promote science-based management and increased tolerance for this iconic animal in the Greater Yellowstone Ecosystem.

How Wolves Change Rivers

Visit sustainableman.org/ to explore the world of sustainability.

For more from George Monbiot, visit monbiot.com/

"When we try to pick out anything by itself, we find it hitched to everything else in the Universe." - John Muir

When wolves were reintroduced to Yellowstone National Park in the United States after being absent nearly 70 years, the most remarkable "trophic cascade" occurred. What is a trophic cascade and how exactly do wolves change rivers? George Monbiot explains in this movie remix.

Dispelling the Myths About Wolves

So why is the reintroduction of the gray wolf back in to areas that was once their normal range been such a divisive issue? Much of it has to do with myths, misinformation, unfounded fears and plain old misguided emotions. Throw in a substantial dose of political backscratching and couple that with state conservation agencies that are, in effect state game managers beholding to those who fund their existence - namely the hunting population. Now add to the mix a serious lack of understanding regarding the critical role that an apex predator plays in their relation to healthy ecosystem and you've developed a recipe for less than efficient wolf management.

Hunters, Politicians and Game Commissions

First, understand that I am not anti-hunting nor am I a preservationist. I am a conservationist - meaning I focus on the wise use of our natural resources. As some one who, by profession is engaged in wildlife management, it is important to know that I see sport hunting as a tool to support science based decisions. It should always be the means to an end . . . never as the end itself.

It is often said that hunters are the foremost champions of conservation. That may be true for some, but in my experience, it is not necessarily an accurate title to be bestowed upon the majority. The reasons that individuals hunt are as varied as they game the seek; however I dare say, conservation in the purest form would rank somewhere close to the bottom of the list. Admittedly, the dollars hunters pay in licensing fees, equipment purchase taxes, violation fines etc do go to support state conservation agencies. Unfortunately, today wildlife management in many states is not conservation as a scientific discipline. More often than not, state wildlife agencies are simply game managers - charged with ensuring that an adequate numbers of targets are available for the next season. Know that in no way do I mean to disparage the fine men and women who serve as game wardens, conservation officers, biologists and field technicians who dutifully serve to protect and manage wildlife. My issue is with the commissions that are owned by local, power hungry, vote thirsty politicians who dictate policy without the education or background to make the necessary decisions which would benefit the ecosystem. It is simply the corrupt tradition of "follow the money". 

Not the wolve's historic range?

I've heard and read many instances of people who have "verifiable proof" that many areas in US (including the Greater Yellowstone Ecosystem) was never the range for the gray wolf. This is pure fallacy. The historic range of the gray wolf covered nearly two-thirds of the United States.

The reintroduction of the gray wolf back into what was once their historic range was a monumental effort to right a terrible wrong - The decline of North American wolf populations coincided with increasing human populations and the expansion of agriculture. In the 1800's, westward expansion brought settlers and their livestock into direct contact with native predator and prey species. Much of the wolves' prey base was destroyed as agriculture flourished. With the prey base removed, wolves began to prey on domestic stock, which resulted in humans eliminating wolves from most of their historical range. Predator control, including poisoning, was practiced here in the late 1800s and early 1900s. Other predators such as bears, cougars, and coyotes were also killed to protect livestock and "more desirable" wildlife species, such as deer and elk.

By the start of the 20th century, wolves had almost disappeared from the eastern USA, excepting some areas of the Appalachians and the north western Great Lakes Region. The gray wolf's decline in the prairies began with the extermination of the American bison and other ungulates in the 1860s–70s. From 1900–1930, the gray wolf was virtually eliminated from the western USA and adjoining parts of Canada, due to intensive predator control programs aimed at eradicating the species. The gray wolf was exterminated by federal and state governments from all of the USA by 1960, except in Alaska and northern Minnesota. Thousands of wolves were killed from the early 1950s to the early 1960s, mostly due to poisoning.

Officially, 1926 was the year that the last wolves were killed within Yellowstone’s boundaries. When the wolves were eradicated and hunting eliminated, the elk population boomed. Over the succeeding decades, elk populations grew so large that they unbalanced the local ecosystem. The number of elk and other large prey animals increased to the point that they gathered in large herds along valley bottoms and meadows overgrazing new-growth vegetation. Because of overgrazing, deciduous woody plant species such as upland aspen and riparian cottonwood became seriously diminished. So, because the keystone predators, the wolves, had been removed from the Yellowstone-Idaho ecosystem, the ecosystem changed. This change affected other species as well. Coyotes filled in the niche left by wolves, but couldn't control the large ungulate populations. Booming coyote numbers, furthermore, also had a negative effect on other species, particularly the red fox, pronghorn, and domestic sheep. Ranchers, though, remained steadfastly opposed to reintroducing a species of animal that they considered to be analogous to a plague, citing the hardships that would ensue with the potential loss of stock caused by wolves.

In the 1960's and 70's national awareness of environmental issues and consequences led to the passage of many laws designed to correct the mistakes of the past and help prevent similar mistakes in the future. One such law was the Endangered Species Act, passed in 1973. 

The US Fish and Wildlife Service is required by this law to restore endangered species that have been eliminated, if possible. By 1978, all wolf subspecies were on the federal list of endangered species for the lower 48 states except Minnesota.

In 1991, Congress provided funds to the US Fish and Wildlife Service to prepare, in consultation with the National Park Service and the US Forest Service, an environmental impact statement (EIS) on restoration of wolves. In June 1994 the Secretary of the Interior signed the Record of Decision for the final EIS for reintroduction of gray wolves to Yellowstone National Park and central Idaho.

Staff from the National Park Service, the US Fish and Wildlife Service, and participating states prepared for wolf restoration to Yellowstone and central Idaho. The US Fish and Wildlife Service prepared special regulations outlining how wolves would be managed as an experimental population and Grey wolf packs were reintroduced to Yellowstone National Park and Idaho starting in 1995.

MYTH: Wolves cause significant losses to livestock producers * 

Averaged percentage of total sheep loss in Wyoming to various predators between 2000-2005. Wolves are responsible for less than 1% of losses

A common belief is that attacks on livestock by wolves is a significant, or even one of the primary causes that account for losses incurred by livestock producers.

In the US emphasis is placed primarily on the financial side, and also often emphasizes that the inclusion of the wolf within the Endangered Species Act violates "property rights" and "constitutional freedoms". The "emotional trauma" suffered by livestock producers as a result of predation is also frequently mentioned.

"It may destroy our livelihood, and our entire
lifestyle is also in jeopardy."

"A person doesn’t know or realize the emotional stress and fears of those that have had animals killed or maimed by wolves until you have it happen to yourself"

Though ranchers and farmers are always ready to give the numbers of livestock affected by predation, these are never given as percentages, or even stated in relation to total herd numbers. In most states the losses of livestock due to wolf predation was less than 1%. In the state of Wyoming, which lies entirely within the Yellowstone re-introduction area the number varied depending on year between 0.9% and 2% in the period 2000-2005, averaging under 1% over the period. This compares with 33.7% to 48.3% over the same period for losses due to coyotes, 4.1% to 10.9% due to eagles, and from 11.2% to 20.7% due to weather. Indeed, poison, often left by livestock producers to kill wolves and other predators, was often responsible for a greater proportion of losses than those due to wolf predation.

Emotional trauma is of course impossible to either prove or disprove, but it is important to remember that livestock is ultimately reared for slaughter, either to directly obtain the primary products (meat and hides) or as means of profitably disposing of "spent" dairy or wool herds/flocks. Thus one would expect anyone working in the livestock industry to deal with the death and processing of animals into food and other end-products as part of the day to day running of their business. It is highly unlikely that any individual emotionally disturbed by the slaughter of animals for meat or other products would find livestock work tolerable as a long time career.

The inclusion of wolves in the ESA provides a mechanism for financial compensation to be paid for damages caused by wolves in partnership with the Wolf Compensation Trust, and in the case of wolves found in the act of attacking livestock or other domesticated animals within private property, it is permissible for the owner to take measures necessary to protect them. Therefore it is hard to see how such an act can be a "violation" of rights.

Adult wolves kill each other in territory disputes. Such disputes happen each year, but increase when food is less abundant. This may have been why so many adult wolves died in fights during 2008. That year, scientists also found two wolves whose deaths were partially due to starvation.

MYTH: Wolves decimate game herds

"All wolves must be eliminated to restore our big game herds."

"The Canadian wolves have decimated our elk, mule deer and moose populations to lows not seen since the ’60s."

There has been considerable misinformation over the impact of wolf populations on herds of elk. However the National Park Service studies indicate that wolf reintroduction to the park, a major reserve for elk herds, would have negligible affect on hunting activities, and that the effect of wolf predation on elk populations would not, in and of itself, have an impact sufficient to be the decisive factor in elk population management.

Although the reasons behind fluctuating wild animal populations are complex, Drs. Doug Smith, Daniel Stahler and John Vucetich conducted a joint National Park Service-MTU study into elk population at Yellowstone. Their findings found that:

• Elk population remained stable from the re-introduction of wolves in 1995 through to 2000, at around 17,000
• In the period 2000-2004 the population dropped 50% to 8,334. During this period the Greater Yellowstone Ecosystem area experienced drought conditions, and increased hunting of Elk by humans.

Though hunting permits did not allow for a kill level equivalent to the total population drop, the researchers concluded that hunting, led to a "super-additive" effect, whereby a 1% direct loss rate due to hunting was magnified to significant degree due to knock-on effects, which were only exacerbated by drought conditions. A recent study conducted by Montana Fish, Wildlife and Parks found that the primary killer of elk were mountain lions, followed by bears and wolves came in a distant third. Although wolf predation was acknowledged to exist, it's effect on the large population drops seen was regarded as a minor, largely insignificant factor:

"Our analysis indicates that there is greater justification for believing that the harvest rate and severe climate, together, account for at least much of the decline".

MYTH: Wolves attack humans all the time

While it is known that wolf attacks on humans do occur, those engaged in wolf hysteria deliberately exaggerate the risk out of all proportion to implant the idea in their audience that all wolves routinely kill and eat humans.

"Wolves are blood-thirsty predators that attack and kill pets, livestock, children, and adults"

"...we need to protect [the cattle industry] from these intruders...they’ve moved into my ecosystem, not the other way around"

"258 Congressional Members Support Funding for Mexican Wolves Stalking Children and Wolves Terrorizing Rural Citizens" The facts in no way bear out such hysteria. Those involved in wolf misinformation often recount reports from the 18th and 19th centuries recanting real or imagined wolf attacks in Europe and Asia.  Although European wolf subspecies are less wary of humans, and are able to live near higher-density human populations than their North American cousins there are no reports of attacks. As the map clearly shows, no wolf subspecies present on the Eurasian landmass is present on the North American landmass. Statistics compiled by Norwegian Institute for Nature Research (NINA) on global wild (not captive) wolf attacks show that in the period 1950-2000, (50 years) there were only 13 confirmed cases of wolf attacks on humans in North America, none of which were fatal. In the United States alone, approximately 1 million reported instances of domestic dogs biting humans per year, with an average of 16 to 18 fatal attacks per year. MYTH: Wolves spread disease Groups and politicians opposed to wolf conservation often use the claim that wolves spread diseases to livestock and game populations. Whilst wolf populations, like that of any wild animal, carry disease, as apex predators they are more often than not a "dead end" for transmission of disease, and are of little concern when it comes to disease management in most livestock and game populations. The most serious diseases affecting wolf populations are those which also affect domestic canines: parvo, mange and intestinal worms. In all cases, transmission of the disease is driven infinitely more by domestic dogs than wolves, and it is believed that in most cases these diseases have been introduced to the wolf population by domestic dogs. A notable exception is the presence of mange in North American wolf populations in the Rocky Mountains. This population was deliberately infected by government veterinarians in 1909 as an attempt to "exterminate" the wolf population, spread to coyotes and other mammals, and eventually re-infected wolves upon their reintroduction to the area. MYTH: Killing/trapping/hunting is the solution "I believe wolves need to be eliminated" A common refrain is that the only effective solution to any or all of the above is to drastically reduce the population of wolves. This inevitably entails lethal intervention on the part of humans. Such actions are proposed by many livestock producers as the panacea to all ills, and is, unsurprisingly, encouraged and guided by the hunting, trapping and fur lobby organizations, which naturally present themselves as the only viable way of going about any such lethal solution. Unfortunately, many hunting methods are exceedingly inhumane, with methods such as leg traps being commonplace in North America, though are banned in the EU due to concerns over its inhumane nature. * From "Wolf Hysteria"

The importance of predators: The Yellowstone case

Wolves were systematically killed in the Yellowstone region and many other areas of the West beginning in the late 1800s. A concentrated effort between 1914 and 1926 finished the job - the last known wolf pack disappeared in 1926.

This video provides a highly educational overview of the important role an apex predator like the
North American gray wolf plays in maintaining a healthy ecosystem.

Now, with the recent reintroduction of wolves back into Yellowstone in 1995, streamside shrubs and cottonwoods within the Lamar Valley are beginning to become more prevalent and taller, and were the focus of a second study in the same area. That study outlines how the fear of attack by wolves apparently prevents browsing elk from eating young cottonwood and willows in some streamside zones.

With the renewed presence of wolves, young cottonwoods and willows have been growing taller each year over on "high-risk" sites, where elk apparently feel vulnerable due to terrain or other conditions that might prevent escape. In contrast, on "low-risk" sites, they are still being browsed by elk and show little increase in height.

Traditionally, "keystone" predators such as wolves were known to influence the population of other animals that they preyed on directly, such as elk or antelope. What researchers are now coming to better understand is the "trophic effect," or cascade of changes that can take place in an ecosystem when an important part is removed.

What's the Matter With Idaho?

By Noah Greenwald
Huffington Post

Idaho's hateful treatment of wolves has reached disturbing new lows in recent weeks.

Late last month the sadly misnamed "Idaho for Wildlife" held a two-day "predator derby" out of Salmon, Idaho, offering prizes for the most coyotes and wolves killed and the biggest wolf taken.

Fortunately, no wolves were killed. But roughly 21 coyotes were gunned down in the event which was pitched as a family friendly opportunity to teach kids about responsible hunting.

How killing as many animals as you can, none for food, qualifies as responsible hunting defies reason -- but not Idaho law.

Also last month the Idaho Department of Fish and Game -- with approval from the U.S. Forest Service -- hired a bounty hunter to trek into the largest wilderness in the lower 48 states, the Frank Church-River of No Return Wilderness, and kill two entire wolf packs.

Read more . . . 

For more wonder, rewild the world

Wolves were once native to Yellowstone National Park -- until hunting wiped them out. But when, in 1995, the wolves began to come back (thanks to an aggressive management program), something interesting happened: the rest of the park began to find a new, more healthful balance. In a bold thought experiment, George Monbiot imagines a wilder world in which humans work to restore the complex, lost natural food chains that once surrounded us.

In his book "Feral," George Monbiot advocates the large-scale restoration of complex natural ecosystems.