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Call on Secretary Jewell to Withdraw USFWS’s Delisting Proposal

USFWS Draft Rule “Regarding Status of the Wolf Under the Endangered Species Act”

On June 7, 2013, the U.S. Fish and Wildlife Service (USFWS) officially announced its proposal to remove Endangered Species Act (ESA) protections for the gray wolf (Canis lupus) in the contiguous United States.  Federal ESA protections would remain only for the small population of Mexican gray wolves (Canis lupus baileyi) in the desert Southwest.  In addition to maintaining protection for the Mexican wolf, the Service is also proposing to and expand recovery efforts and recognize this southernmost gray wolf in North America as a distinct sub-species of the gray wolf.

Required: Objective Scientific Review

The ESA requires USFWS to base all listing and delisting decisions on the best available science.  Thus when determining whether or not to end endangered species protection, federal law requires that an independent panel of scientists be commissioned to provide an objective scientific review of the federal agency’s proposals.

Peer Review Findings

On February 7, 2014, USFWS released the Independent Peer review of its wolf delisting plan. The five member panel of scientists  agreed unanimously that the delisting rule is based on insufficient science.

Map: Science and Nature (

The review committee was particularly critical of the Service’s determination that the gray wolf never occurred in 29 eastern states. Based in part on preliminary conclusions from a single 2012 paper written by biologists employed by USFWS, the Service contended  that the eastern half of the U.S. was occupied by Canis lycaon or the “eastern wolf,” a distinct species of wolf and not belonging to the gray wolf species, Canis lupus.

Under the ESA, USFWS is obligated to recover endangered species across a “significant portion” of its historic range.  If the eastern half of the U.S. was never a part of the gray wolf’s historic range, USFWS contends that Canis lupus (a.k.a. gray wolves) now occupy enough of its historic range to be considered recovered. Thus, USFWS made its determination that gray wolves no longer warrant ESA protection.

The peer review reported  that “there is not currently sufficient scientific support for the recognition of C. lycaon [eastern wolf] as a separate species… thus  “there was unanimity among the panel that the [delisting] rule does not currently represent the ‘best available science.’ “

In a Feb. 10 critique, “Service Manufactures Scientific Studies to Support Politically Negotiated Deals” Public Employees for Environmental Responsibly (PEER) reported that Dave Parsons, FWS’ first Mexican Wolf Recovery Coordinator from 1990-1999 and primary author of the Mexican gray wolf rule that would be replaced by the proposed FWS plan, has been unambiguously critical. He stated, “Based on my observations over the years, political influence and pressure has so pervaded the FWS hierarchy that professional staff feel so helpless, demoralized, and in fear of career repercussions that they dare not defy orders from higher authorities….Has FWS completely lost its soul and dedication to its mission?”

What about the Mexican Gray Wolf?

Although the peer review reported that USFWS draft rule is flawed, both the Service and the independent scientists agree Mexican gray wolves are a distinct sub-species of the gray wolf.

Call on Secretary Jewell to Withdraw USFWS’s Delisting Proposal.

The value and importance of conserving endangered species and ensuring biodiversity is an accepted axiom of the 21st century. The importance of a keystone predator such as the gray wolf to a balanced ecosystem is undeniable. That our policies would and should be motivated by the best available scientific principles is critical.

Wildlife and other natural resources are a public trust which means that every citizen has an interest and a voice in the management of natural resources.  The public trust is a legal concept that implies that we all share equal, undivided interests in America’s wildlife. The public trust doctrine imposes limits on governments to ensure public access to and protection of important natural resources.
Thus, decision-making and resulting wildlife policy should be developed based on sound science and carried out in a democratic manner responsive to the voice of the people.

In response to the peer review, USFWS has again opened public comment on its wolf delisting proposal for 45 days until March 27th. Please join the Wolf Conservation Center and Stand For Wolves –  Call on Secretary Jewell to withdraw USFWS’s delisting proposal.

Talking Points

  • Beyond its role as a living symbol of our natural landscape, the wolf is a keystone species.  Its presence is critical to maintaining the structure and integrity of native ecosystems.  Federal protections for wolves are essential to help this animal recover and expand into still-suitable parts of its former range, just as the bald eagle was allowed to do before having its federal protections removed.
  • The ESA requires USFWS to base all listing and delisting decisions on the best available science.  A panel of independent scientists who  was commissioned to give an objective review agree unanimously that the delisting rule is based on insufficient science.
  • Modern scientific evidence shows that top predators like wolves play critical roles in maintaining a diversity of other wildlife species and healthy, balanced ecosystems. The gray wolf has barely begun to recover or is absent from significant portions of its former range where substantial suitable habitat remains in the Pacific Northwest, California, the southern Rocky Mountains, Southwest and the Northeast. These areas are important to the long-term survival and recovery of wolves and to the ecosystems of these regions.
  • Scientists unanimously agree that Mexican gray wolves should be listed as a separate endangered subspecies.  With only 83 remaining on the wild landscape at the end of 2013, it is essential that the Service list Mexican wolves immediately without waiting to see what happens with the USFWS’ nationwide treatment of the gray wolf.