Help Ensure the Survival of the Mexican Gray Wolf ~
Public Comment Period Open Through June 15, 2020
As explained in our recent Notes from the Field, the Mexican gray wolf is the most endangered gray wolf in North America. It is the southernmost subspecies of gray wolf and formerly ranged throughout the U.S. Southwest and northern Mexico. Like other gray wolves in the lower 48 U.S. states, it was persecuted to near extinction by the mid-1900s. In 1976, the Mexican gray wolf was placed on the list of endangered species under the Endangered Species Act.
Only seven Mexican gray wolves survived the relentless efforts by the U.S. and Mexican governments to exterminate them completely. These seven founders were bred in captivity until there were enough wolves in the captive population to support an effort to reintroduce the Lobos to their native habitats. The first releases took place in 1998 in the Apache National Forest in east-central Arizona. Subsequent releases have allowed the population to grow to a current estimate of 163 wolves in the wild in in both Arizona and New Mexico (the “States”).
While the increasing number of Mexican wolves in the wild is encouraging, many problems persist that continue to threaten their survival. These include severe genetic inbreeding, excessive human-caused mortality by both poachers and the agency managers (the U.S. Fish & Wildlife Service and the States), and political opposition to the recovery effort primarily from the States and hunting and livestock interests.
The initial releases were conducted under provisions in Section 10(j) of the Endangered Species Act, which authorizes the Secretary of the Interior to release “experimental populations” of endangered species to former habitats. This section requires the Secretary to determine whether the released population is “essential” or “non-essential” to the continued existence of the species in the wild. The initial releases in 1998 were determined to be non-essential. That classification has been retained to this day and was reaffirmed by the USFWS in the first revision of the Section 10(j) management rule in 2015.
Several conservation groups filed lawsuits to overturn the 2015 rule revision claiming that it would not lead to recovery of Mexican wolves, and United States District Court in Arizona ruled in their favor in March 2018. In a sweeping order, the Court ruled that the USFWS’s 2015 rule failed to apply the best available science and failed to provide adequate protections to ensure the eventual recovery of the Mexican gray wolf in the U.S. Southwest. The Court ordered the USFWS to revise the rule and to address the multiple deficiencies identified in the final Court Order by May of 2021.
The Court Order was a huge victory for Lobo advocates and provides what may be the last opportunity for the conservation community to convince the USFWS to make the necessary changes to the rule to ensure the long-term future of our native gray wolf—the Lobo of the Southwest.
We need your help now!
The USFWS has initiated the process of rule revision, and on April 15 opened a 60-day formal public “scoping” comment period.
Comments must be submitted by 11:59 p.m. ET on June 15, 2020.
Project Coyote, in cooperation with The Rewilding Institute, will be addressing multiple complex issues in our comments to the USFWS. (We are also partnering to present a free webinar on the topic on May 12 ~ more information here.)
This “public” comment period is also your opportunity to advise the USFWS on this important issue.
How to Submit Your Comments:
- Comments can be submitted electronically at http://www.regulations.gov. Follow the instructions for submitting comments to Docket No. FWS-R2-ES-2020-0007, which is the docket number for this Notice of Intent.
- Hard copy comments can be submitted by U.S. mail or hand-delivery to:
Public Comments Processing
Attn: FWS-R2-ES-2020-0007
S. Fish and Wildlife Service
MS: PRB/PERMA (JAO/1N)
5275 Leesburg Pike
Falls Church, VA 22041–3803.
Talking Points:
- Mexican wolves need greater protection to improve their genetic health and increase the likelihood of their recovery.
- More wolves from the genetically more diverse captive population need to be released into the wild. The genetic health of the wild population is steadily declining by every measure. The inbreeding coefficient is increasing, and genetic diversity is decreasing. If this trend continues, it will likely lead to the extinction of the Mexican wolf. In addition to cross-fostering captive pups into wild dens, the USFWS needs to release more well-bonded captive adult pairs with pups, which can yield more immediate genetic health improvements.
- The wild population’s classification under the Endangered Species Act must be changed from a “nonessential” experimental population to an “essential” population. Twenty-two years following the initial release of 11 wolves, the expanded population of 163 animals is undeniably essential to the Mexican wolf’s recovery and long-term survival in the wild. The change to essential status offers much needed greater protection for the wild population.
- The revised rule needs to provide for more wolves in more places to ensure their recovery. Independent scientists have determined that at least three populations totaling at least 750 wolves must be established in the U.S. Southwest to ensure their long-term survival and recovery. The current cap of 325 wolves in the U.S. population must be removed.
- The Court has ruled that the revised rule must further the recovery of Mexican wolves in the U.S. Southwest. The current rule prohibits wild Mexican wolves from dispersing north of Interstate 40 in Arizona and New Mexico. This politically motived restriction is the result of opposition to meaningful wolf recovery by the states of Arizona, New Mexico, Utah, and Colorado. Independent scientists have identified two significant regions with suitable wolf habitat north of Interstate 40, both of which are critically important to the recovery of Mexican wolves in the U.S. Southwest: the Grand Canyon ecoregion in northern Arizona and southern Utah, and the Southern Rocky Mountain ecoregion in northern New Mexico and southern Colorado.
- The revised rule should remove all barriers to the movement of Mexican wolves and all limits to the size of their populations. The wolves know better than government agencies the best places to live and can limit their numbers to fit the capacity of the ecosystem supporting them. When allowed to establish their natural population densities, wolves tend to improve the health and biodiversity of their ecosystems. In other words, they are essential to maintaining the balance of nature.
- The revised rule must include provisions to reduce wolf removals and promote non-lethal methods for addressing conflicts. The current rule allows too many opportunities for livestock owners and agency managers to kill or remove wolves to address perceived conflicts between wolves and human activities on public lands.
Since Mexican wolves were first released to their native habitats, 50 wolves have been caught in private traps, resulting in multiple deaths, limb amputations, and other injuries. Most wild Mexican wolves occupy public lands. These are only the known incidents of wolves being trapped, but there are undoubtedly many more unknown trapping incidents and undocumented wolf deaths. A simple solution is to ban trapping on public lands within the Mexican wolf recovery area.
Thank you for speaking up for Mexican wolves!
David R. Parsons, MS
Project Coyote Science Advisory Board
Camilla H. Fox
Founder & Executive Director