• Range Writing

Assessing Wolf Relisting

The U.S. Fish and Wildlife Service (FWS or Service) announced last month that it had completed the initial review of two petitions filed to list gray wolves in the western U.S. as threatened or endangered under the Endangered Species Act (ESA). The Service finds that the petitions present substantial, credible information indicating that a listing action may be warranted and will initiate a comprehensive status review of the gray wolf in the western U.S. These findings mean that FWS will conduct an in-depth status review and analyses “using the best available science and information” to arrive at a 12-month finding on whether listing is warranted.


It’s important to understand the specifics of the FWS findings. The factors FWS found threatening to the wolf population occur only in Idaho and Montana, but the listing would encompass an area far larger than those states.


The agency had to assess five factors:

Pursuant to the ESA, the five factors to be assessed in making a listing determination are:

Factor A: The present or threatened destruction, modification, or curtailment of its habitat or range;

Factor B: Overutilization for commercial, recreational, scientific, or educational purposes;

Factor C: Disease or predation; Factor D: The inadequacy of existing regulatory mechanisms; and Factor E: Other natural or manmade factors affecting its continued existence.


According to FWS:

“Based on our review of the petitions and readily available information regarding human-caused mortality, we find that the petitioners present credible and substantial information that human-caused mortality (Factor B) may be a potential threat to the species in Idaho and Montana. These two States include approximately 75 percent of gray wolves in a potential Northern Rocky Mountains or Western DPS (distinct population segment).
The petitioners also provide credible and substantial information that new regulations in these two States may be inadequate to address this potential threat (Factor D).”

The two petitions differed in what they requested, and one is much more radical in its allegations and what it requested:


Petition 1 was filed by the Center for Biological Diversity, Humane Society of the United States, Humane Society Legislative Fund, and the Sierra Club. The petition requested that wolves in the Northern Rocky Mountains be relisted, or in the alternative, that the agency relist wolves in the entire western United States. This petition requests that FWS use best available science to determine if wolves should be relisted as threatened or endangered, while noting, “A threatened listing would preserve federal oversight to ensure gray wolf conservation, as the ESA requires, while providing the Service with the regulatory flexibility under Section 4(d) to work with states to manage conflicts with wolves, including limited ‘taking’ of wolves if consistent with the overarching conservation goals of the ESA and based on best available science.”


Petition 2 was filed by Western Watersheds Project, WildEarth Guardians, and a coalition of similar organizations (including Wyoming Untrapped and Wyoming Wildlife Advocates). The petitioners include one organization not based in the United States, as well as numerous organizations that are not usually involved in wolf issues, such as wild horse advocacy groups, and oceanic interests, and organizations founded to focus on other species (swans, etc.) or factory farming. This petition seeks endangered status for gray wolves in Idaho, Montana, Wyoming, Utah, Oregon, Washington, Colorado, California, Nevada, and northern Arizona.



Reduced prey base allegation

Although FWS cited only potential human-caused mortality and inadequate regulatory mechanisms as the factors used in moving forward in considering relisting, the agency will examine all five factors in its status review. The agency noted: “The petitioners also presented information suggesting that habitat modification due to a reduced prey base (Factor A), disease (Factor C), and loss of genetic diversity caused by isolation and small population size (Factor E) may be threats to the gray wolf. We will fully evaluate these and all other potential threats, as well as the validity of each DPS, in detail based on the best scientific and commercial data available when we conduct the status assessment and make the 12-month finding.”


The “reduced prey base” argument is a new one, and was only put forth in the petition led by Western Watersheds Project. What is the threat to the prey base for wolves? Predictably, Western Watersheds Project, an anti-grazing group, alleges that livestock grazing is a threat.


According to the Western Watersheds Project petition: “Wolves’ prey base is also affected by the reduced availability of ungulates on most public lands due to livestock grazing displacement and competition. Livestock are generally allocated about fifty percent of the annual vegetation production on national forests and Bureau of Land Management grazing allotments, and each cow is assumed to eat about 1000lbs of forage per month, known as an “AUM” or animal unit month. Each cow thus eats the equivalent forage that would otherwise be available to five mule deer, five antelope, one female bison or moose, sixty-two black-tailed jackrabbits, or three-hundred and eighty-five ground squirrels. With about 22 million AUM authorized on approximately 230 million acres of public land, an incalculable amount of otherwise available-as-prey wildlife are replaced by livestock, which wolves are penalized for preying upon. This represents a significant displacement and reduction in available food for wolves.”


It's worth a reminder that signing onto the Western Watersheds Project petition are WildEarth Guardians, and two Wyoming-based organizations: Wyoming Untrapped and Wyoming Wildlife Advocates.



Public comments

FWS has received more than 30,000 comments on its announcement that it intends to conduct a status review to determine if wolves should be relisted. The announcement specifically requested: “To ensure that the status review is comprehensive, we are requesting scientific and commercial data and other information regarding the species and factors that may affect its status.” What the agency received was thousands of comments expressing opinions rather than providing data, and thousands of form letters.


The Center for Biological Diversity apparently managed to generate more than 24,000 similar comments to generally “Restore Northern Rocky Mountain Wolves to the Endangered Species List.” Of these mass mailer/petition commenters, only 39 claimed to be from Wyoming, according to the Excel spreadsheet listing the comments; 164 from Idaho, and 133 from Montana. For comparison, there were more comments generated from Massachusetts (which does not have wolves) than from commenters in the tri-state region of the Northern Rockies where wolves actually live.


Many of the comments are duplicates, are anonymous, or have nothing to do with the issue at hand. A total of 407 comments mention “ranchers” and most of those mentions are not in a good way. Several simply state, “Ban cattle ranchers now!” or “Let the ranchers and hunters shoot each other instead.”


More than 850 comments use similar language to suggest that Idaho plans to cull up to 90% of its wolves – a talking point put forth by wolf advocates. Nearly 1,200 comments refer to the looming threat of wolf extinction. Others use identical language to reference Wyoming’s “open season” on wolves in the predator zone of the state.







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