Friday, September 19, 2014

Speak up for wolves before it's too late


U.S. Fish and Wildlife Service will allow public commentary regarding their

Draft Environmental Impact Statement (download pdf)

until 11:59pm EST on 09/23/2014.

Within the EIS the agency hopes to make changes to the reintroduction program: two of these changes are good for wolf recovery; unfortunately, the rest of the changes will push the 83 Mexican wolves in the wild back to the brink of extinction. The changes open up new areas for wolves to roam but shut them off permanently from some of the best remaining habitat for wolves in the Southwest, expand the provisions for "take" (removing a wolf lethally or for management purposes) of wolves in the wild, and maintain the fiction that the wild population of wolves is non-essential.
This will be one of the last chances to speak for Mexican wolves. It's up to you to ensure this native to the Southwest is recovered and future generations are able to appreciate these beautiful animals.

Submit your comments electronically here: 

Or mail your comments here: 
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.
Use the following talking points to help write your comments: 


1. The proposed rule effectively prevents wolves returning to the Grand Canyon region, including northern Arizona and southern Utah, or to northern New Mexico and southern Colorado. The USFWS should eliminate boundaries to the wolves’ movement.
Scientists say that at least two additional populations of Mexican wolves are necessary for their recovery and genetic health, as is the ability for wolves to move among populations. Yet the proposed rule, although it allows wolves to roam over a larger area than currently allowed, would still prevent Mexican wolves from recolonizing these important areas and make it nearly impossible to establish additional populations.

2. The USFWS should not expand provisions for "take" (removing wolves lethally and for management purposes from the wild).
Alternatives 1 and 2 in the Draft EIS propose expanded provisions for "take" of wolves in the wild. USFWS should be tightening the provisions on "take", not expanding them. Over half of all Mexican wolf mortalities since the beginning of the reintroduction program have been caused by illegal mortalities.
In the past 10 years, USFWS has only released 4 wolves from captivity into the wild. Conversely, in those same 10 years USFWS has removed 11 wolves from the wild lethally and 14 wolves permanently from the wild. Scientists agree that the best way to recover the subspecies is by releasing more wolves into the wild now, not increasing ways they can be removed.

3. The USFWS should not continue the fiction of designating Mexican gray wolves as an "experimental, non-essential" population. By labeling all of the wild wolves as “nonessential” the USFWS ignores science, logic and reality.

The USFWS is proposing to continue with the "nonessential" classification of wild Mexican wolves--a regulatory term under the Endangered Species Act that provides less protection than an "essential" designation. The agency claims that even if all of the 83 wolves in the wild--the only Mexican wolves in the wild, with the possible exception of a few recently reintroduced wolves in Mexico--are wiped out, this is not “likely to appreciably reduce the likelihood” of survival of lobos in the wild. Huh? This defies logic.

4. One good change is to allow direct releases of Mexican wolves throughout the Blue Range Wolf Recovery Area.

This change has been recommended by experts for over 10 years and can be made faster and with less bureaucratic delay than any other part of the proposed rule. The current rule allows direct releases only in a small area in Arizona, comprising about 16 percent of the entire recovery area.
Additional talking points:

  • USFWS should stop stalling and create a new comprehensive recovery plan that includes scientifically adequate goals for recovery. USFWS admits that their current 1982, typewritten plan is not scientifically sound and does not meet current legal requirements. Scientists agree that in order to truly achieve recovery there must be at least three distinct populations of wolves, yet the current recovery plan maintains the woefully inadequate number of 100 wolves in the wild.
  • USFWS should maintain full protections for Mexican wolves crossing the border from Mexico into the US. Mexico began a reintroduction program in 2011 and just this year celebrated the first wild-born litter of pups. Currently, if Mexican wolves crossed the border they would maintain their protected status under the Endangered Species Act. Under all 3 Alternatives within the Draft EIS, these wolves would be designated as "non-essential, experimental".
  • USFWS should include a provision to require livestock producers to remove or render inedible livestock carcasses. These carcasses can attract Mexican wolves and habituate them to livestock
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