Red Wolf Proposed 10J Rule - TAKE ACTION
On June 28, the U.S. Fish and Wildlife Service (USFWS) announced a proposal that will no doubt result in the extinction of red wolves in the wild. Today, fewer than 30 wolves remain in the wild.
Beyond reducing the red wolf recovery area by nearly 90% and limiting the wild population to just 10-15 wolves, USFWS, the very agency charged by federal law with protecting endangered species, will allow people to kill red wolves who stray beyond the newly-designated recovery area – and without any repercussions.
There is a perceived notion that red wolves are a local or regional issue and that only the residents of North Carolina are impacted by the results of this recovery effort. Endangered species recovery, however, is a matter of pride and concern for all U.S. citizens. This is not an isolated issue for North Carolina. By succumbing to political pressure, the USFWS is allowing a small group of vocal landowners to dictate endangered species policy instead of adhering to proven scientific principles and practices.
The public comment period for the Proposed Red Wolf 10J Rule (Proposed Replacement of the Regulations for the Nonessential Experimental Population of Red Wolves in Northeastern North Carolina) opened on June 28, 2018, and continued through July 30, 2018. NOTE: The comment period has been reopened. Individuals can submit comments from August 13, 2018, through August 28, 2018. Information on how to comment can be found here or via www.regulations.gov under docket number FWS-R4-ES-2018-0035-14783.
SUGGESTED TALKING POINTS
I strongly oppose the proposed 10(j) Rule for the wild red wolf population in Eastern North Carolina. The proposal would effectively abandon the recovery effort and doom the species to extinction in the wild. The Endangered Species Act (ESA) was enacted in 1973 to preserve animal and plant species, yet U.S. Fish and Wildlife’s proposed rule directly contradicts the primary purpose of the ESA. Without a dedicated effort to conserve both captive and wild red wolf populations, the survival of this rare species is at risk.
- There is a perceived notion that red wolves are a local or regional issue and that only the residents of North Carolina are impacted by the results of this recovery effort. Endangered species recovery, however, is a matter of pride and concern for all U.S. citizens. This is not an isolated issue for North Carolina. By succumbing to political pressure, the USFWS is allowing a small group of vocal landowners to dictate endangered species policy instead of adhering to proven scientific principles and practices.
In a joint scientific letter delivered to FWS in July of 2017, the signatories urge the Service to: (1) restore the Red Wolf Recovery Program (Program) in eastern North Carolina to its capacity prior to 2014; (2) establish an effective management response to mitigate gunshot mortality through stronger regulation of coyote hunting and implementation of stronger regulatory mechanisms to protect red wolves; (3) continue ongoing research and develop further methodology to control hybridization and other threats to the reintroduced population; (4) improve public perception of red wolves through tailored education and outreach programs for hunters and the general public; and (5) work with the local public and government to facilitate cooperation without curtailment of the Program.
The signatories go on to say:
Perhaps the most important aspect of revised management is to restore the field program to the same level of intensity prior to 2014 that achieved success in bringing about a functioning wolf population that once numbered over 150 animals (Gese et al. 2015; Hinton et al. 2017a). After 2014, the Service stopped reintroducing captive-born red wolves into the reintroduced population, ceased implementing the Red Wolf Adaptive Management Plan (RWAMP) that limited hybridization via management of coyotes, removed wolves from private lands, and issued take permits (i.e., kill) to landowners (Kozak 2016; Fears 2016).
Under the preferred alternative (alternative number 3), USFWS would limit the North Carolina Non-Essential Experimental Population (NC NECP) to a fraction of the red wolf’s current protected range: the Alligator River National Wildlife Refuge and Dare County Bombing Range. The Service would also eliminate any take prohibitions for red wolves that stray outside of these boundaries. Dispersal is natural for wolves, a fact acknowledged by the Service [“It is anticipated that some red wolves would leave the NWR and Bombing Range on a fairly regular basis.”] as it allows for genetic diversity and the creation of new family groups. Yet under this proposed ruling, these naturally dispersing wolves could be legally killed without punishment. In 2017, scientists specifically urged the Service to establish a management response to mitigate gunshot mortality through the regulation of coyote hunting and implementation of stronger regulatory mechanisms to protect red wolves. Alternative number 3 blatantly ignores science in favor of appeasing a small yet vocal group of private landowners. I urge USFWS to follow the science and create a mechanism that will decrease, not increase, gunshot mortalities of red wolves. Read USFWS's Draft Environmental Assessment to learn more about the various alternatives.
Red wolf historic range with non-essential experimental population management area. Map by Jose Barrios, USFWS.
Research papers and articles about red wolves can be found here.
HOW WILL THE PROPOSED RULE IMPACT THE WILD POPULATION OF RED WOLVES?
Under the proposed rule, "take" (or killing) of red wolves outside the NEP is permitted, and is mentioned frequently in the proposed rule.
- "It is anticipated that some red wolves would leave the NC NEP management area on a fairly regular basis. Although these red wolves would be considered part of the NC NEP, the proposed regulations would contain no take prohibitions of these animals on private lands and non-Federal public lands. As such, the Service has determined that no take prohibitions will apply outside the NC NEP management area. The proposed rule would require only that the Service be notified within 24 hours regarding the take of any collared animals and that the collars be returned to the Service."
- "Animals having genetic importance may be trapped and moved to either the NC NEP management area or captivity; however, most would remain on the landscape with their survival dependent on landowner tolerance and cooperation without regulation. It is unknown whether such a balance can be struck in eastern North Carolina or elsewhere, but this proposed rule seeks to find that balance. The Service is committed to investing locally in public education and outreach, with a goal towards local red wolf appreciation and peaceful coexistence with landowners since landowners will have no take prohibitions of red wolves on private lands."
". . .this proposed rule has a goal of furthering red wolf appreciation and peaceful coexistence with local landowners since landowners will have no take prohibitions of red wolves on private lands."
"We expect that there could still be some level of gunshot mortality, but we believe that, over time, if landowners adjacent to but outside the NC NEP management area are no longer regulated differently from the rest of the State, these circumstances would improve. Countering the risk of increased mortality outside the smaller NC NEP management area risk would require regular augmentation of the NC NEP with releases from the captive population." Essentially, USFWS will release captive red wolves to balance the wild red wolves that will be killed outside of the NEP and can release up to 5 captive red wolves per year.