Conservation, or Curation?

AUGUST 20, 2014

Originally published in the New York Times – August 20, 2014

THE United States Fish and Wildlife Service — the main agency for the conservation of species — recently announced a new interpretation of the Endangered Species Act that severely limits its reach and retreats from the conservation ethic that healthy landscapes depend on native plants and animals.

The law says that a species qualifies for protection if it is in danger of extinction “throughout all or a significant portion of its range.” A species does not need to be at risk of extinction everywhere it lives if it is endangered in a significant portion of its range. But what is “significant”? And how is “range” defined?

Now, under a policy that took effect July 31, the agency has provided answers. The law’s protections, for practical purposes, will be applied only if a species is at risk of extinction in a vital (read, significant) portion of its range where its loss would put the entire species at risk of extinction. And the concept of range no longer takes into account its historical distribution but defines the concept in terms of where the species is found now.

This means that as long as a small, geographically isolated population remains viable, it won’t matter if the animal or plant in question has disappeared across the vast swath of its former habitat. It won’t qualify for protection.

This interpretation threatens to reduce the Endangered Species Act to a mechanism that merely preserves representatives of a species, like curating rare pieces in a museum. Also likely to suffer are efforts to protect or repopulate areas where endangered species once lived.

Imagine if this new approach had been in place when the bald eagle was being considered for protection in the 1970s. Arguably, the national bird might never have been listed as endangered in most of the lower 48 states, even though it had virtually been extirpated by illegal hunting and the pesticide DDT. Why? Because a healthy population of bald eagles remained in Alaska and Canada.

Today, the return of the bald eagle is one of the great successes of the Endangered Species Act. The bird is flourishing in the very areas where it had been wiped out and reasserting its position in the ecological order that was disrupted by its absence. This was accomplished in part by using the authority in the law to protect nesting sites and summer and winter roost sites and to reintroduce the bird into its historical range.

(The Fish and Wildlife Service says it still would have protected the bald eagle under this new interpretation. Nevertheless, a case could have been made to withhold the law’s safeguards once the bird was no longer at risk of extinction outright.)

More recently, other threatened animals haven’t been so lucky.

In cases involving the gray wolf, wolverine and swift fox, the agency, employing the logic of this new policy to guide it, decided or proposed to remove or withhold protections for those animals after concluding there was no risk that they would go extinct. Never mind that they had vanished from much of the territory they once inhabited. (The gray wolf, which is in the administrative process of losing its protection under the law, had been lost from 85 percent of its range but securely inhabits the last 15 percent.) The agency reasoned that there were enough of these animals left in their much-diminished range to survive.

Several years ago, the Fish and Wildlife Service and a sister agency, the National Marine Fisheries Service, began developing a uniform policy for interpreting that key phrase in the Endangered Species Act — the line that says that a species must be at risk “throughout all or a significant portion of its range” to qualify for protection. Uncertainty over the meaning of that phrase and government decisions based on varying interpretations had led to controversy and litigation.

The two agencies call their reading of the law a “reasonable interpretation,” although they acknowledge that “there is no single best interpretation.” In fact, their reading is especially narrow and possibly contrary to Congress’s intent when it passed one of the nation’s most important conservation laws. A more appropriate interpretation of range would be those portions of a species’ historical distribution that are suitable, or that can feasibly be made suitable, by mitigating or removing the threats that had caused the species’ decline.

If the purpose of conservation is merely to preserve the fewest possible members of a species, then this new policy might be adequate. But this approach amounts to a retreat from two conservation aspirations that had long animated the law: first, to mitigate harms that humans had perpetrated against certain species, such as severely reducing their geographic range; and second, to make it possible for species to return to landscapes where they had been extirpated. The idea was that healthy ecosystems depend on the presence of native species.

Since taking effect in 1973, the law has been instrumental in saving many species from extinction, including the California condor, American crocodile, whooping crane and black-footed ferret. Some 1,400 plants, animals and fish are now on the list.

This new approach does not mean that endangered species won’t still be saved. But it falls far short of the conservation aspirations the law once embodied. This new policy will result in a world for our children even more diminished than the one we live in.

John A. Vucetich is an ecologist at Michigan Technological University. Michael Paul Nelson is an environmental ethicist at Oregon State University.

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There’s a new trend in our country and it’s not a good one…
We’re ignoring science.

Although U.S. Fish & Wildlife is bound by the Endangered Species Act to base its species listing & delisting decisions on the best available science, the federal agency has been ignoring science to give in to political pressures instead. We’ve seen this in FWS’ draft proposal the nationwide gray wolf delisting, rule changes for the Mexican wolf, and last week’s decision to abandon proposed protections for the wolverine.  Since FWS has chosen to ignore the best available science, including advice from the Service’s own wildlife experts, has science itself gone extinct?

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The U.S. Fish and Wildlife Service (USFWS) has released a draft proposal to change the rules governing the Mexican wolf reintroduction.

The draft proposal, if implemented, will seriously jeopardize the continued existence of critically endangered Mexican gray wolves, who currently number less than 90 in the wild. The proposal ignores the best available science and recommendations by top wolf scientists.

USFWS proposes to allow more Mexican wolves to be shot, trapped, and permanently removed from the wild.

The proposal continues to designate the wild population of lobos as “non-essential,” failing to give them additional protections necessary to their survival.
And, while it does expand the area wolves can roam, it restricts them to parts of New Mexico and Arizona below I-40, even though leading wolf scientists say that populations of Mexican wolves north of I-40 are essential to the lobo’s recovery.

The only completely good thing it does is to finally allow new wolves from the captive breeding population to be released into a larger area, a change desperately needed for genetic rescue of the wild population.

USFWS has released this draft proposal with a draft Environmental Impact Statement (DEIS) for public comment and will hold hearings on August 11 in Pinetop, AZ August 11 and on August 13 in Truth or Consequences, NM.


If at all possible, attend a hearing in August. It is crucial that we demonstrate tremendous public support for Mexican wolf recovery. More hearing details are here.

Submit comments on the draft proposal before 9/23/14 and include these specific talking points in addition to your personalized message:

1. I support expanding the area in which direct releases of Mexican wolves can occur, the one critical change included in the proposed rule.

  • This change has been recommended by experts for over 10 years and needs to be implemented immediately. Currently, new releases are hindered because they can only happen in part of Arizona.

2. The USFWS should eliminate boundaries to the wolves’ movement.

  • The draft proposed rule prevents wolves returning to northern New Mexico and southern Colorado or to the Grand Canyon region, including northern Arizona and southern Utah.
  • Preventing movement into northern New Mexico and southern Colorado and the Grand Canyon region, including northern Arizona and southern Utah, contradicts the best available science, which confirms that those areas are essential for Mexican wolf recovery.
  • Additional populations of Mexican wolves are necessary to their recovery and genetic health, as is the ability for wolves to move between populations.
  • Not allowing wolves outside of the Mexican Wolf Experimental Population Area will result in more captures that can result in death or trauma to the wolves. We can’t afford to lose rare Mexican wolves just because they crossed an arbitrary, scientifically unsupported boundary. There should be no restrictions on the movements of Mexican wolves.

3. The USFWS should designate Mexican gray wolves as essential.

  • The current labeling all of the wild wolves as “nonessential” ignores science and the reality of 15 years of experience with reintroducing wolves.
  • The USFWS claims that even if all of the 83 wolves in the wild are wiped out this is not “likely to appreciably reduce the likelihood” of recovery of Mexican wolves in the wild is unsupported by science or common sense.
  • The 83 wolves in the wild have up to four generations of experience in establishing packs and raising pups and are over 22% of all of the Mexican wolves in the world.
  • After multiple generations of captive breeding with few releases, scientists warn that there may be serious genetic problems making captive wolves less able to thrive in the wild.
  • The fourth generation wild lobos are not expendable and are essential to recovering this unique subspecies of wolf.

4. The USFWS needs to quit stalling and complete a comprehensive recovery plan.

  • USFWS admits that their present, typewritten, 1982 recovery plan is not scientifically sound and does not meet current legal requirements – yet in its proposed rule USFWS continues to emphasize a woefully inadequate population of only 100 wolves in the wild. Instead of following the best available science on recovery, the Service is chasing after what a 31-year-old inadequate plan suggested as a good first step.
  • Current proposals should contain no provisions that would preclude future recovery options.

5. The proposed expanded provisions for “take” (killing, trapping, and removals) of these critically endangered wolves are unacceptable and will not contribute to the wolves’ recovery.

  • Science-based program reviews have shown, and the USFWS has acknowledged, that the killing and permanent removal of wolves by agency managers to resolve “conflicts” has been a major cause of failing to meet the reintroduction objective.
  • The proposed rule changes offer additional excuses for removing wolves. USFWS needs to tighten restrictions for “take” of Mexican wolves, not loosen them.

Submit your comments electronically here:

Or by U.S. mail or hand delivery to:
Public Comments
Processing, Attn: FWS–R2–ES–2013–
0056; Division of Policy and Directives
Management; U.S. Fish and Wildlife
Service Headquarters, MS: BPHC, 5275
Leesburg Pike, Falls Church, VA 22041–3803.

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H.R. 4315 is package of four dangerous bills that would drastically change the way the Federal government protects endangered and threatened species. HR 4315 would add layers of bureaucracy, waste limited agency resources, and divert efforts to recover species under the Endangered Species Act. Of specific concern, the bill would require federal agencies to publish on the internet all data used in ESA listing determinations. Such a requirement would limit the amount and quality of information supporting ESA decisions by discouraging data sharing by scientists, State and local governments, and particularly private landowners, who do not want their information disclosed online. This provision could also expose vulnerable wildlife and rare plants to increased poaching or vandalism.


H.R. 4315
 requires the Secretary of Interior to make the data used for each ESA listing decision publicly available via the Internet
 would have the effect of discouraging states with privacy laws on their books from sharing their data with government decision makers.
 could discourage scientists and local governments from sharing data with the Fish and Wildlife Service
 would require private landowners and companies to share data associated with their property online
 would provide a roadmap to poachers looking for endangered wildlife

HR 4316
 would require the Secretary to submit an annual report to Congress detailing agency expenditures for “covered suits,” meaning “any civil action” under the ESA against the Department of the Interior, the Forest Service, and the National Marine Fisheries Service.
 will simply exacerbate the alleged problem that the authors of this bill claim it is trying to solve; will divert more resources away from recovery efforts, by now requiring the Department of Interior to report annually on the detailed costs of every citizen suit filed against it under the ESA.

  • If the legislators who drafted this bill complain that environmental groups are filing frivolous lawsuits at taxpayer expense, shouldn’t Congress be held to a similar standard? If so, maybe the agencies should also report how much they are spending, the number of full time employees, and the total number of employee hours spent responding to document requests, subpoenas and hearings from any Member of Congress.
  • This excessive abuse of the process is expensive for taxpayers and burdensome for agencies. If legislators believe in the merit of these requests, then they should have no trouble asking agencies to report how many taxpayer dollars it is costing them to comply.


HR 4317
 would redefine “best available science” and require the federal government to accept as the best available science ANY data submitted by a state, tribal, or county government.
 does not require the data to be of a high quality – or even a moderate quality; there is no standard at all.

  • If a county, state, or tribe wanted to submit incomplete or bad data, even that data would be anointed as the best available, regardless of what scientific experts have to say.
  • This dangerous bill attacks the essential protections that form the very foundation of the ESA. This bill will not improve the recovery of our nation’s most endangered wildlife. Instead, it will undermine the best available science for listing new species, and create new challenges to species recovery.
  • To weaken the scientific foundation of the Endangered Species Act is to doom more species to extinction. Scientists know we must protect species because they are working parts of our own life-support system. Once species become extinct, no corrective legislation can bring them back—they are gone forever.


HR 4318
 would limit the ability of citizens to participate in the Democratic process and hold the government accountable because it places an arbitrary cap on legal fees awarded to prevailing or partially prevailing parties in litigation against the government. The courts decide what are reasonable fees under this and scores of other laws every day, and they have a much better ability to objectively determine what is appropriate.


The Wolf Conservation Center believes H.R. 4315 and its related attached bills can potentially undermine essential protections that form the very foundation of the Endangered Species Act. None of these bills will improve the recovery of our nation’s endangered wildlife. Instead, they reduce the ability of the public to hold gov’t agencies accountable for complying with the law, undermine the best available science for listing new species, and create new challenges to species recovery. To weaken the scientific foundation of the Endangered Species Act is to doom more species to extinction.

Please consider joining the WCC in OPPOSING this political attack on our most historically significant environmental law. When you vote to OPPOSE H.R. 4315 via the WCC POPVOX legislative campaign, a message is sent directly to your Senators expressing your opposition.  Vote to OPPOSE here.

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Montana Fish, Wildlife & Parks (FWP) is seeking comments on its proposed Wolf Conservation Stamp. The comment period is remains open until Friday, August 22, 2014 11:59 PM. Below is the comment submitted by the Wolf Conservation Center.

Montana Fish, Wildlife & Parks
1420 East Sixth Avenue
P.O. Box 200701
Helena, MT 59620-0701
Attn: Commissioners, Director Hagener

Dear Director Hagener and Commissioners:

It is our understanding that the Commission is considering a proposal to sell wolf conservation stamps that will enable people, regardless of state, to contribute to responsible wolf policies in Montana. Non-consumptive users (i.e. non-hunting, non-trapping nature enthusiasts) have historically lacked a seat at the table when important conservation decisions are made.

It is important to note that Montana is already the beneficiary of substantial economic ecotourism dollars from people who visit the state from all over the world. In fact, on July 18th, 2014, the National Park Service reported (July 18 2014) that 3,188,030 visitors to Yellowstone National Park in 2013 spent almost $382 million in communities surrounding the park. That spending supported 5,300 jobs in the area. The report also shows $14.6 billion of direct spending by 273.6 million park visitors in communities within 60 miles of a national park. This spending supported more than 237,000 jobs nationally, with more than 197,000 jobs found in the gateway communities of the Park, and had a cumulative benefit to the U.S. economy of $26.5 billion. In addition, the Wolf Conservation Center continues to lead several wolf-watching tours to Yellowstone annually, thus bringing several hundred of our supporters from around the nation to your state to learn about and observe wolves in the wild. These and other activities in the state continue to contribute to this powerful economic engine.

Thus, the wolf conservation stamp has the potential for receiving overwhelming support, and can be perceived as an example of more inclusive approaches to wolf and wildlife conservation in Montana. While this is a step in the right direction, we would like to suggest some revisions to the proposed language:

1. Change the name of the stamp from “Wolf Management Stamp” to “Wolf Conservation Stamp.”
2. Include specific language in the rule that states the funds generated from the stamp will be exclusively dedicated for nonlethal wolf conservation activities. As you know, the Department already has a vast array of lethal tools in its management toolbox to monitor and control populations of wolves; non-consumptive users want reassurance that the generated revenue will only be spent on activities that sustain healthy populations of wolves.

  • helping to pay for nonlethal methods of preventing livestock depredations and keeping wolves and other large carnivores out of harm’s way
  • purchasing and protecting wolf habitat, conducting research, public education and outreach that benefits gray wolves and promotes their acceptance on the landscape;
  • hiring additional state game wardens in areas where wolves exist to reduce poaching of wolves.

3. Include a specific statement in the proposed rule that stipulates the Department will be completely transparent in the administration of this rule. We request that the Department generate and publish a complete annual expenditure report to the public about how funds from the Wolf Stamp revenue were used; this will ensure the future likelihood that supporters will continue to make similar donations via the stamp for years to come.

Please continue to consider new and different ways of incorporating the perspectives, concerns and voices of the non-hunting, non-trapping community in conserving the publicly owned wildlife in your state. We appreciate this opportunity to submit these comments on Montana’s proposed Wolf Conservation Stamp.

Respectfully submitted,

Action and Awareness Committee, Wolf Conservation Center

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WCC’s Family Walk to Protect America’s Wild Heritage

Wednesday, August 13th

1PM – 3PM

Ward pound Ridge Reservation Shelter 5

The Wolf Conservation Center’s second annual service-learning event, “WCC’s Family Walk to Protect America’s Wild Heritage,” invites children to celebrate the wildlife and wild lands of the largest park in the contiguous United States – New York State’s Adirondack State Park! The FREE outdoor adventure will lead participants through a circuit of educational workshops about the array of NY’s native wildlife and give opportunities to earn free raffle tickets for exciting prizes. In addition to these experiences, Northeast Wolf Coalition Junior representative Tommy Whiteley will present a keynote address and Wolf Conservation Center Ambassador Wolf Atka will lead all in a group howl. Each child will receive Adirondack Council’s “Wild Characters of the Adirondacks” booklet along with a certificate that acknowledges their participation. The event will be held on Wednesday, August 13th from 1:00 p.m. to 3:00 p.m. at the Ward Pound Ridge Reservation (Shelter 5) at 6 Reservation Road in Cross River, NY. Reservations are not required, but please let us know if you plan to attend by e-mailing We hope you can join us on this special day to raise awareness for New York’s wild beauty!

Check out this great video of last year’s event!

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WARNING –Video contains dangerously adorable footage of wolf pup Nikai!

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Representatives from dozens of facilities participating in the Mexican Wolf Species Survival Plan (MWSSP) are heading to the “Show me State” to meet at the Endangered Wolf Center in Eureka, MO for the MWSSP Annual Meeting!  This meeting is bringing together Fish and Wildlife Agencies from both US and Mexico, endangered species reproductive specialists, and many other organization representatives including Wolf Conservation Center (WCC) curator Rebecca Bose to tackle a myriad of issues associated with conserving the lobo. The bulk of the meeting will begin Wednesday but Rebecca, as a member of the Mexican Wolf Management Group, will get right down to business just a couple of hours after arriving later this evening to discuss all important matters concerning the ~ 300 captive Mexican gray wolves that call the U.S. and Mexico home. Other items on the meeting agenda include:

  • Report on the status of Mexican wolf recovery in both Mexico and the U.S.
  • Report on the Mexican wolf SSP and the status of the global captive studbook population
  • Report on reproductive research in 2013 and needs for 2014
  • Mexican wolves Genome Project
  • Criteria for selection of breeding pairs
  • Select pairs for breeding in 2014
  • Gamete banking plan and criteria for selection of candidates
  • Select semen and oocyte collection candidates for 2014
  • Select candidates for release in 2014

We’re looking forward to hearing Rebecca’s reports from the meeting so we can update you on all aspects of the program including how to best recover a sustainable population in the wild. Stay tuned!

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