Verified by 
On June 7 the US Fish and Wildlife Service announced its intention to remove the gray wolf, Canis lupus, from the federal list of threatened and endangered plants and wildlife. Among the first species listed under the Endangered Species Act of 1973, it was being dropped not because it had recovered across even a large part of its former range but because the Fish and Wildlife Service had determined after forty years that Canis lupus was “not a valid species under the [Endangered Species] Act.”
On its face, the statement is preposterous. But it appears repeatedly in the draft rule the Fish and Wildlife Service placed in the Federal Register, June 13, 2013, and seems to serve one key purpose: By declaring Canis lupus an invalid species in terms of the Endangered Species Act, the Fish and Wildlife Service frees itself from any responsibility for its fate because it then technically ceases to exist in America. This verbal abracadabra could well lead to the very real loss of a species that was just beginning to recover after centuries of persecution.
Perhaps the widest ranging large terrestrial carnivore in the world, Canis lupus at the time it was first listedpersisted in small numbers in only one of the lower 48 states that had once constituted its range. (There is disagreement on this point, largely based on questions of whether the Southeastern wolf was a separate species.)
The five-thousand or so gray wolves found in six states by 2011, when a Congressionally mandated delisting took place, can hardly be said to represent a species recovery across even a significant fraction of the species’ former range. The Fish and Wildlife Service claims a higher number of states because it includes those where wolves are “believed” to exist. Wolf hunting, which accompanied delisting, has already begun to eat into the number who do exist and threatens to push recovery into a downward spiral. A recent New York Times op-ed by Jim Dutcher, Jamie Dutcher and Garrick Dutcher addressed the issue and is found here.
Reasons for the delisting are vague and confused although they seem to boil down to the Fish and Wildlife Service’s determination that the gray wolf at no time during three putative invasions of North America penetrated east of the western Great Lakes and Mississippi River. By their account, the Southeast belonged to the red wolf, Canis rufus; the Northeast, including eastern Canada to the Great Lakes, was the home of the Eastern timber wolf. Now considered a subspecies of the gray wolf, the timber wolf would under this rule become a separate species, Canis lycaon, highly endangered, like the red wolf through interbreeding with coyotes.
Canis lupus does not need saving globally, the Fish and Wildlife Service concluded, although certain subspecies and distinct populations might need various levels of protection. The service overlooks the central fact that its responsibility is the state of wolves in the U.S., and that remains tenuous.
The Fish and Wildlife Service claims its determination was based on “best science,” not political considerations. That is what the law requires. A more appropriate term might be “select science,” because the agency clearly picked the science that suited its agenda. Virtually everything it proposes is controversial at best. Its focus on subspecies and distinct populations completely overlooks that the species is the fundamental bedrock of evolution. In far ranging, widely dispersing animals like the gray wolf, subspecies that arise, as well as “distinct populations,” are highly contingent and mutable. Over time, they can be refined or redefined out of existence. Sometimes the existence of such groups is due less to any biological fact than to a human belief that even seemingly minor differences in appearance and behavior are significant.
In this case, many of the scientists whose work is invoked to justify the proposed changes have written Secretary of Interior Sally Jewel and Fish and WildlifeService Director Dan Ashe, asking that the rule not be promulgated. “Based on a careful review of the rule, we donot believe that the rule reflects the conclusions of our work or the best available science concerning the recovery of wolves, or is in accordance with the fundamental purpose of the Endangered Species Act to conserve endangered species and the ecosystems upon which they depend,” the scientists wrote. A full copy of the letter appears following this post.
According to the Fish and Wildlife Service’s new wolf story, before the massive slaughter of wolves in the first half of the twentieth century, three gray wolf subspecies were dispersed across the western two-thirds of the country in overlapping territories, with possibly a fourth poking down the Northwest Pacific coast. The oldest and most southerly was the Mexican wolf, Canis lupus baileyi. Canis lupus nobilus was next and wasfound from the western Great Lakes to the Pacific coast; and then came the Northern Rocky Mountain wolf, Canis lupus occidentalis.
Of the three gray wolf subspecies, the Fish and Wildlife Service deems only one endangered, the Mexican wolf, C. lupus baileyi. The new plan would formally classify it as a gray wolf subspecies, list it as endangered, and strength its sagging reintroduction program.
The new arrangement also allows the Fish and Wildlife Service to deny federal protection for wolves moving out of British Columbia into the Pacific Northwest on the grounds that do not represent a distinct population segment because they are mixing with wolves from the Rocky Mountains who have already been delisted.
Scientists point out that Northwest coastal wolves have unique genetic profiles and mixing between populations and even subspecies of wide-ranging species like the gray wolf is common and valuable for maintaining genetic diversity. Under the new rule, dispersing wolves can be classified as invasive and removed if they enter the range of another subspecies.
The new rule also allows the Fish and Wildlife Service to ignore questions about the nature of the New England canid, the wolf/coyote/dog hybrid that is colonizing the Eastern United States
The proposed delisting of the gray wolf has the appearance of a decision driven by politics, not science. It seems fundamentally grounded in the disproven notion that a wide-ranging species can be confined to discrete management areas that minimize conflict with people.
Its publication in the Federal Register marked the beginning of a 90-day period for public comments. Directions for how to comment are provided.
Expectant wolf.
Scientists' Lettetr Protest Gray Wolf Delisting
Following is the letter by leading wolf researchers to Interior Secretary Sally Jewel and Fish and Wildlife Director Dan Ashe protesting the misuse of their scientific work in the proposed delisting of the gray wolf and asking that the rule be withdrawn and reconsidered.
May 21, 2013
Secretary Sally Jewell
Department of Interior
1849 C Street NW
Washington, DC 20240
CC: Dan Ashe, Director
U.S. Fish and Wildlife Service
1849 C Street NW
Washington, DC 20240
Dear Secretary Jewell,
As scientists with expertise in carnivore taxonomy and conservation biology, we are writing to express serious concerns with a recent draft rule leaked to the press that proposes to remove Endangered Species Act protections for gray wolves across the Lower 48 States, excluding the range of the Mexican gray wolf. Collectively, we represent many of the scientists responsible for the research referenced in the draft rule. Based on a careful review of the rule, we do not believe that the rule reflects the conclusions of our work or the best available science concerning the recovery of wolves, or is in accordance with the fundamental purpose of the Endangered
Species Act to conserve endangered species and the ecosystems upon which they depend.
The Service’s draft rule proposes to: 1) “remove the gray wolf from the List of Threatened and Endangered Wildlife”; 2) “maintain endangered status for the Mexican wolf by listing it as a subspecies (Canis lupus baileyi)”; 3) “recognize a new species of wolf known as Canis lycaon [that] occurs in southeastern Canada and historically occurred in the northeastern United States and portions of the upper Midwest (eastern and western Great Lakes regions)”; and 4) deny protection to wolves in the Pacific Northwest because they do not qualify as a distinct population segment for lack of discreteness from wolves in the northern Rocky Mountains.
We find these proposals problematic both in terms of their scientific support and theirconsistency with the intent of the statute. Specifically:
1) Removal of the gray wolf from the List of Threatened and Endangered Wildlife
The gray wolf has barely begun to recover or is absent from significant portions of its former range where substantial suitable habitat remains. The Service’s draft rule fails to consider science identifying extensive suitable habitat in the Pacific Northwest, California, the southern Rocky Mountains and the Northeast. It also fails to consider the importance of these areas to the long-term survival and recovery of wolves, or the importance of wolves to the ecosystems of these regions.
2) Maintain endangered status for the Mexican wolf by listing it as a subspecies
Although the taxonomic distinctness of the Mexican wolf is well-supported, and we thus support subspecific listing as appropriate, the draft rule fails to delineate the geographic extent of the area in which wolves would receive protection, specifying only that Mexican wolves would be protected “where found”. Genetic analysis of historic Mexican wolves showed that the range of the Mexican wolf likely extended beyond the historic range initially inferred from limited record data. At the same time, the Service has inexplicably delayed completion of the recovery plan for the Mexican wolf, the draft of which had concluded that habitat to the north of the current recovery area may be essential for recovery of the subspecies. The lack of specificity in the rule, coupled with past actions by the Service, encourages continued efforts by stakeholders to block recovery actions essential to recover a subspecies that is among the most endangered mammals in North America.
3) Recognize a new species of wolf known as Canis lycaon
There is not sufficient information to support recognition of a new species of wolf, C. lycaon, and the geographic range reduction for Canis lupus in the eastern US as currently proposed. The Service acknowledged this problem in 2011, concluding:
While Chambers et al. (in prep.) provide a scientific basis for arguing the existence of eastern wolves as a distinct species, this represents neither a scientific consensus nor the majority opinion of researchers on the taxonomy of wolves, as others continue to argue that eastern wolves are forms of gray wolves (Koblmuller et al. 2009, vonHoldt et al. 2011). 76 Fed Reg. 81669.
While we encourage the Service to continue to review the taxonomic history of wolves in the eastern US, any future proposed taxonomic revision of canids should be a reflection of a more settled, broader scientific consensus rather than a premature policy decision based on ongoing and unsettled scientific debate. New evidence from complete genome sequencing efforts will likely supersede previous limited genetic evidence. Whether the Service moves forward with recognizing C. lycaon should have no bearing on the possibility that C. lupus’ range may haveextended into some, if not many, of the eastern states. If the Service is intent on recognition of C. lycaon, this new species itself needs immediate protection as an endangered species. The draft rule provides no coherent scientific or statutory basis for not protecting wolves in the northeastern United States. The rule also ignores the threat that interspecific hybridization may have on the listed wolf species.
4) Conclude that wolves in the Pacific Northwest do not qualify as a distinct population segment
Finally, we cannot support the conclusion that wolves in the Pacific Northwest do not qualify as a distinct population segment due to lack of discreteness from other wolf populations. In 2007, the boundary between the northern Rocky Mountains population and the Pacific Northwest was established by the Service in order to recognize the recovery that has occurred, and delist Northern Rocky Mountain (NRM) wolves. The 2007 rule correctly stated that the “DPS policy does not require complete separation of one DPS from other U.S. packs or populations. If occasional individual wolves or packs disperse among populations, the NRM DPS could still display the required discreteness.” It defies logic for the Service to now argue that “dispersal of wolves across the NRM DPS boundary is likely to continue” and that such occasional dispersal prevents recognition of a DPS that would protect wolves that are beginning to establish in the Pacific Northwest. Additionally, genetic testing of gray wolves that have migrated naturally into the Pacific Northwest has established that some derive from British Columbia coastal wolf populations which are genetically distinct from the inland stock of wolves used as a source for reintroduction to the northern Rocky Mountains.
The extirpation of wolves and large carnivores from large portions of the landscape is a global phenomenon with broad ecological consequences. There is a growing body of scientific literature demonstrating that top predators play critical roles in maintaining a diversity of other wildlife species and as such the composition and function of ecosystems. Research in Yellowstone National Park, for example, found that reintroduction of wolves caused changes in elk numbers and behavior which then facilitated recovery of streamside vegetation, benefitting beavers, fish and songbirds. In this and other ways, wolves shape North American landscapes.
Given the importance of wolves and the fact that they have only just begun to recover in some regions and not at all in others, we hope you will reconsider the Service’s proposal to remove protections across most of the United States.
Respectfully,
Bradley Bergstrom, PhD
Valdosta State University
Valdosta, Georgia
Christine Bozarth, PhD
Northern Virginia Community College,
Alexandria, Virginia
Jeremy Bruskotter, PhD
The Ohio State University
Columbus, Ohio
Carlos Carroll, PhD
Klamath Center for Conservation Research
Orleans, California
Phil Hedrick, PhD
Arizona State University
Tempe, Arizona
Roland Kays, PhD
North Carolina State University
Raleigh, North Carolina
Jennifer Leonard, PhD
Estación Biológica de Doñana
Sevilla, Spain
Jesus Maldonado, PhD
Center for Conservation and Evolutionary Genetics, Smithsonian
Washington DC
Michael P. Nelson, PhD
Oregon State University
Corvallis, Oregon
Reed F. Noss, PhD
University of Central Florida
Orlando, Florida
Stuart L. Pimm, PhD
The Nicholas School, Duke University,
Durham, North Carolina
John P. Pollinger, PhD
University of California, Los Angeles
Los Angeles, California
Michael Soulé, PhD
Prof. Emeritus, University of California, Santa Cruz
Paonia, Colorado
Bridgett vonHoldt, PhD
University of California, Los Angeles
Los Angeles, California
John Vucetich, PhD
Michigan Technological University
Houghton, Michigan
Robert Wayne, PhD
University of California, Los Angele
Los Angeles, California
