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Comments are being accepted through July 31, 2005

The Rewilding Institute
POB 13768, Albuquerque, NM 87192 * TRI@rewilding.org www.rewilding.org

May 25, 2005

Mexican Wolf Reintroduction Project
Arizona Game and Fish Department
Attention: Terry B. Johnson
2221 West Greenway Road
Phoenix, Arizona 85023.

U.S. Fish and Wildlife Service
Mexican Wolf Recovery Project
New Mexico Ecological Services Field Office
2105 Osuna Road NE
Albuquerque, NM 87113

Re: Comments on Mexican Wolf Blue Range Reintroduction Project Adaptive Management Oversight Committee Proposed 1-Year Moratorium on New Releases and Proposed Standard Operating Procedure 13. Issued for public comment on April 26, 2005

The Rewilding Institute (TRI), a conservation think tank, welcomes the opportunity to comment on the proposed release/relocation moratorium and standard operating procedure (SOP 13) for the control of Mexican wolves.

We commend the various agencies that cooperatively implement the Mexican Wolf Reintroduction Project for adopting “adaptive management” as the operational paradigm for implementing and managing this very complex project. Inherent uncertainties and complex technical and social issues associated with this project justify the flexibility that derives from properly applied adaptive management approaches.

Adaptive management is not just a buzzword for allowing agencies to haphazardly try new approaches when old approaches fail or to respond reactively to the faction that shouts the loudest—rather it is a serious discipline requiring diligent and rigorous application. Under adaptive management, actions and policies are treated as scientific experiments where certain outcomes are hypothesized but not known for certain. Anticipated outcomes are compared with actual outcomes and adaptations are guided by what has been learned through monitoring and assessment. Definitions of adaptive management abound and we offer the following for the adaptive management process being used for this project: Adaptive management is an approach to managing complex natural systems or projects that builds on learning—based on common sense, experience, targeted monitoring, and periodic rigorous analysis of accumulated data—by adjusting practices based on what has been learned. Adaptive management processes are usually implemented through partnerships of managers, scientists, and citizens that learn together and seek to find reasonable solutions to achieve a common management goal (Borman et al. 1999, Johnson 1999, Lee 1999). Key to the success of adaptive management processes is acceptance of the management goal by all participants. Adaptive management processes offer serious challenges and many attempts to implement them have failed (Lee 1999). One common cause of such failures is the involvement of stakeholders who oppose the goal.

The goal of this project is the establishment of a self-sustaining population of at least 100 Mexican wolves. This goal derives from recovery mandates of the Endangered Species Act (ESA) and the Mexican Wolf Recovery Plan. The current reintroduction project plan was developed through an interagency NEPA (National Environmental Policy Act) process and a concomitant parallel planning process conducted by the Arizona Game and Fish Department (AGFD) with substantive public involvement in both processes.

Adaptive management is best served by a model or set of specific objectives that define periodic progress and the ultimate success of the project. Such objectives were set forth in the final Environmental Impact Statement (EIS) for this project and are summarized in Table 2-2 of that document. Specific projections based upon the best available science were made for yearly population growth from the initial releases to the achievement of the 100-wolf population objective, predicted to occur eight years later. At the end of the sixth year (2004) the expected population was projected to comprise 68 wolves and 13 established packs (10 successfully breeding in 2004). Releases were predicted to have ceased at the end of 2002 with the population attaining the remaining growth through successful reproduction and sufficient survival in the wild. These projections serve as the baseline against which monitoring results are compared. Formal evaluations were required at 3 and 5 years after initial releases to provide the data and information for guiding the adaptive management process.

According to the inter-agency annual report for the period ending December 31, 2004, the “confirmed” wild population numbered 44-48 wolves. There were 11 established packs or “groups” of which 6 successfully reproduced. Releases have continued every year beginning in 1998, with 2 packs totaling 12 wolves being released in 2004. Over twice as many wolves than were projected to be released have been released to date. We note that the 2004 population estimate represents a 13-25% decline from the end of 2003 population estimate of 55 wolves. Clearly, population growth and self-sufficiency of the wild population are not meeting established objectives, and the population has undergone an alarming decline in the past year.

In 2001, a 3-year review of the project was conducted by a panel of non-agency wolf experts led by internationally recognized wolf ecologist Dr. Paul Paquet (Paquet et al. 2001). In addition, a workshop was held to receive and capture information from stakeholders with knowledge and/or concerns about the project. Crucial findings and recommendations from the technical component of the 3-year review include the following:

Findings

  • Frequent recaptures and re-releases may be interfering with pack formation and establishment and maintenance of home ranges.
  • Survival and recruitment rates are far too low to ensure population growth and persistence. Without dramatic improvement in these vital rates, the population will fall short of predictions for upcoming years.
  • Livestock are omnipresent in the BRWRA and interactions with wolves are unavoidable.
  • Livestock producers using public lands can make a substantive contribution to reducing conflicts with wolves through improved husbandry and better management of carcasses.
  • The small size of the primary recovery zone and the restriction of wolves to the small BRWRA are hindering recovery of a self-sustaining and viable population of Mexican wolves. Dispersal of wolves outside the recovery area boundaries is required if the regional population is to be viable.
  • Adaptive management is the appropriate operational paradigm.
    Many wildlife restoration projects are unsuccessful because of a failure to accommodate new information. (In other words, the failure to appropriately apply an adaptive management process.)

Recommendations

  • Immediately modify the final rule and develop the authority to conduct initial releases into the Gila National Forest.
  • Immediately modify the final rule to allow wolves that are not management problems to establish territories outside the BRWRA.
  • Require livestock operators on public land to take some responsibility for carcass management or disposal to reduce the likelihood that wolves become habituated to feeding on livestock.

Over the ensuing 4 years, none of these recommendations has been implemented or initiated by the FWS or cooperating agencies.

In late 2004, the FWS issued a draft 5-year review of the status of the Mexican Wolf Reintroduction Project in the BRWRA and requested public comment. This review was conducted by technical experts employed by the various cooperating agencies. The Rewilding Institute submitted comments on the 5-year review and we incorporate those comments as part of these comments—see Appendix A. One phase of the 5-year review—the socio-economic analysis—has yet to be released for public review and comment. We note that the current proposed moratorium and standard operating procedures for wolf control have been issued before the FWS and cooperating agencies have completed the review of public comments and issued a final 5-year review document. This is contrary to the adaptive management process. Crucial preliminary findings and recommendations from the draft documents of the 5-year review include the following:


Findings

  • Many packs had a portion of their home range outside of the current reintroduction boundary.
  • The average litter size for wild-conceived and wild-born pups was 2.1 pups/litter (n = 16, range 1-5), far below that observed in other populations and the projections in the EIS.
  • Wolf removal rates were higher than mortality rates and together were the dominating processes influencing the population. Combining removal and mortality rates to form a “failure rate” indicated that overall levels were much higher than that predicted within the EIS. (The reported average annual failure rate was 62%. We noted in our comments on the 5-year review that such a high failure rate was not sustainable without population supplementation.)
  • 47% of radio-collared wolves were involved in at least one confirmed depredation incident and an additional 11% were removed for engaging in human-nuisance behavior.
  • On average, for every confirmed depredation incident, a wolf was removed from the wild or translocated.
  • 91% of wolves known to have scavenged dead livestock carcasses were confirmed to have subsequently killed living domestic livestock.
  • The projected population and current population are very similar (based on end of 2003 data). However, releases are also higher than projected in the EIS, and thus the population is likely artificially high (i.e., augmented by ongoing releases; emphasis is ours). (We note above that the population has declined since the 5-year review analyses.)
  • Each of the five measures used to define a successful depredation control program indicated that the current [wolf control] methods were adequate (emphasis is ours). The number of confirmed wolf-killed cattle was within the projections made in the EIS, although slightly higher than that observed in other populations of gray wolves. This higher relative number of killed cattle within the BRWRA relative to other wolf populations likely relates to differing grazing schemes between the areas (i.e., year-round grazing).
  • The frequent management of these populations may influence the ability of these wolves to fully exploit their territory. Indeed, the two packs that produced the greatest number of pups in the wild (5) were within their respective territories for approximately 3 years prior to producing litters of this size.

Recommendations

  • The project modify the final non-essential experimental rule to allow wolves to occur in areas within the southwestern distinct population segment (SWDPS) of the gray wolf (U.S. Fish and Wildlife Service 2003) where they do not conflict with livestock or humans.
  • Wolves with wild experience continue to be translocated after their first removal event, except in extreme situations.


We offered additional recommendations in our comments on the 5-year review (see Appendix A). The FWS and cooperators have not implemented or initiated findings and recommendations of the 5-year review. In fact, the 5-year review has not been completed; public comments have not yet been reviewed and considered; and a final 5-year review report has not yet been issued.

In an August 2, 2004, report to the Recovery Team, Dr. Philip Hedrick (conservation geneticist) noted that the wild population lacked important genetic ancestry from the Aragon and Ghost Ranch lineages of Mexican wolves. Stressing the urgency of the need to correct this genetic deficiency, Dr. Hedrick recommended incorporating ancestry from both the Aragon and Ghost Ranch lineages into the wild population “as soon as possible.” Another genetic concern is high inbreeding coefficients within the wild population. Addressing these issues would require strategic and expeditious releases of captive animals and the freedom to translocate genetically important wolves throughout the recovery area.

Notwithstanding information and recommendations provided by reviewers of the draft 5-year review documents, the collective findings and recommendations of the 3 and 5-year reviews and the Hedrick report when considered under an adaptive management process argue for project modifications that would be expected to: 1) reduce wolf recaptures, 2) reduce wolf removal rates, 2) reduce wolf mortalities, 3) reduce wolf-livestock conflicts, 4) reduce disturbance of wolves by management activities, 5) expeditiously increase genetic representation of Aragon and Ghost Ranch lineages in the wild population 6) increase number of packs successfully breeding in the wild, 7) increase litter size, 8 ) remove barriers to wolf movements, and 9) allow wolves to be released throughout the recovery area. Project modifications to achieve these and other appropriate objectives should follow expeditious completion of the 5-year review through application of the adaptive management process. Some management measures (e.g., genetic supplementation) should not be delayed.

However, in a radical departure from the adaptive management process, the Adaptive Management Oversight Committee (AMOC; Chaired by the AGFD) has proposed a one-year moratorium on the release and translocation of wolves (with some limited exceptions) and new procedures for the control of “problem” and “nuisance” wolves that will likely increase mortality and removal of wolves while reducing population supplementation through releases and translocations.

The justification provided for the proposed 1-year moratorium on releases and translocations is that a select group of project opponents meeting privately with high-level FWS regional officials at the request of Congressman Pearce (R-NM) asked for it. The proposal notes that the additional time saved by not releasing wolves will be allocated to five ongoing project activities. This action flies in the face of the adaptive management process and is neither appropriate, ethical, nor acceptable. And it is an insult to those who have expended considerable time and effort to participate in this process under established rules.

Furthermore, the proposed moratorium on releases and translocations and the proposed SOP 13 on wolf control have been issued during the ongoing 5-year review process, thus creating new proposals and a new public review process within an existing public review process. How can the cooperating agencies possibly have completed a thorough and legitimate analysis as a basis for proposing sweeping changes to the project when the 5-year review and analysis has not been completed? It is disingenuous of the agencies to ask for public comments and claim that they value and will carefully consider those comments and then propose project changes before having done so.

The proposed moratorium on releases and translocations appears politically motivated, premature, and unjustified on the basis of findings of the 3-year review and preliminary findings of the 5-year review, both summarized above. We fail to find any compelling justification in support of the necessity or urgency of the proposed moratorium and we recommend that it be rescinded immediately. Furthermore, the proposed moratorium contains a self-rescinding provision of the prohibition of initial releases of captive-reared wolves that is triggered when the number of breeding pairs in the wild falls below six. Following the currently ordered and ongoing efforts to kill or capture the Francisco Pack, this criterion will be met—the resulting number of breeding pairs will be five or fewer. That the number of breeding pairs currently in the wild is already this low also supports our conclusion that the proposed moratorium is unjustified and our recommendation that it should be rescinded in its entirety.

Similar arguments can be made for SOP 13 on wolf control measures. It appears to completely ignore important findings from the 3 and 5-year reviews and proposes no new policies or procedures that would reduce the removal or mortality of wolves or promote changes in livestock husbandry or management practices that would reduce conflicts or increase the compatibility of wolf restoration and livestock grazing on our public lands. To the contrary, the proposed measures would potentially increase removal and mortality rates. We note that the draft 5-year review found that current wolf control methods were adequate which calls into question the need for revisions, especially prior to completion of the 5-year review process. The resolution of conflicts between wolf recovery goals and livestock grazing on public lands calls for “novel ideas” and “creative solutions” not more trapping and shooting of wolves. Government wolf control procedures and private compensation programs combine to form a perverse incentive—under existing and proposed wolf control policies, if a rancher wants wolves removed all he needs to do is encourage a conflict between wolves and livestock for which he will be compensated. We’re not suggesting that wolf recovery area ranchers would resort to such tactics, but current policies certainly provide the temptation. The proposed SOP 13 contains no provisions that would encourage innovations in ranching practices that would reduce wolf-livestock conflicts and, thus, reduce wolf removals and mortality. See additional discussion and proposed solutions for resolving this problem in Appendix A. As with the proposed moratorium, we fail to find any compelling justification in support of the necessity, urgency, or appropriateness of SOP 13 as currently proposed, and we recommend that it be rescinded immediately. Any future wolf control policy should be firmly based on the best current data and findings from the 3 and 5-year reviews addressed through the adaptive management process such that proposed solutions promote attainment of wolf reintroduction goals.

Wolf recovery is controversial; and the FWS adopted the “non-essential experimental population” classification under section 10(j) of the ESA to have more flexibility in finding and applying creative solutions for reducing conflicts while recovering the Mexican wolf. But there is one legally-binding criterion that the agencies appear to be ignoring—releases of listed species under section 10(j) provisions must “further the conservation” of the species. Based on our analysis presented herein, we conclude that the “conservation” test (ESA 10(j)(2)(A)) is not being met.

Frankly, we are appalled by the blatant disregard of valid data and professional analyses performed by both internal and external experts and the apparent misapplication of the adaptive management process in response to political pressure.

The Rewilding Institute appreciates this opportunity to comment. These comments are also endorsed by the individuals and organizations whose names appear below the signature block.

Sincerely,



David R. Parsons
Wildlife Biologist
Vice Chairman & Science Fellow

The following individuals and organizations endorse these comments:

Dave Foreman
Director, Senior Conservation Fellow, and Board Chairman
The Rewilding Institute
Albuquerque, New Mexico

Michael Soulé, Ph.D.
Senior Science Fellow – The Rewilding Institute
Professor Emeritus in Environmental Studies
University of California, Santa Cruz.

Paul Paquet, Ph.D.
Three-Year Review Author
Wolf Biologist
University of Calgary & Conservation Science, Inc.
Calgary, Alberta, Canada

Mike Phillips
Three-Year Review Author
Executive Director
Turner Endangered Species Fund
Bozeman, Montana

Philip Hedrick, Ph.D.
Ullmann Professor
School of Life Sciences
Arizona State University
Tempe, Arizona

Tina Arapkiles
Co-Director
Southern Rockies Wolf Restoration Project
Boulder, Colorado

Sandy Bahr
Conservation Outreach Director
Sierra Club - Grand Canyon Chapter
Phoenix, Arizona

C. Dustin Becker, Ph.D.
Program Manager & Faculty
UNM-Gallup Zuni Campus
Zuni, New Mexico

Paul Beier, Ph.D.
Conservation Chair
Colorado Plateau Chapter
Society for Conservation Biology
Flagstaff, Arizona

Kevin Bixby
Director
Southwest Environmental Center
Las Cruces, New Mexico

Stephen Capra
Executive Director
New Mexico Wilderness Alliance
Albuquerque, New Mexico

Matthew Clark
Conservation Fellow – The Rewilding Institute
Graduate Student in Conservation Biology
Northern Arizona University

Nicole J Corbo
Coordinator
Grand Canyon Wolf Recovery Project
Flagstaff, Arizona

Kim Crumbo
Conservation Fellow – The Rewilding Institute
Wilderness and Planning Coordinator
Grand Canyon Wildlands Council
Flagstaff, Arizona

Rob Edward
Director - Carnivore Restoration Program
Sinapu
Boulder, Colorado

Thomas L. Fleischner, Ph.D.
Professor of Environmental Studies
Prescott College
Prescott, Arizona

Camilla H. Fox
Director of Wildlife Programs
Animal Protection Institute
Sacramento, California

Ed Grumbine, Ph.D.
Conservation Biologist
Environmental Studies
Prescott College
Prescott, Arizona

Don Hoffman
Executive Director
Arizona Wilderness Coalition
Alpine, Arizona

John C. Horning
Forest Guardians
Santa Fe, New Mexico

Malcolm R. MacPherson, Ph.D.,
Scientist and Conservationist
Santa Fe, New Mexico

Susan Morgan, Ph.D.
Conservation Fellow – The Rewilding Institute
Albuquerque, New Mexico

Stephanie Nichols-Young
President
Animal Defense League of Arizona
Tucson, Arizona

Tony Povilitis, Ph.D.
Conservation Biologist
Zuni, New Mexico

Michael Robinson
Carnivore Conservation Coordinator
Center for Biological Diversity
Pinos Altos, New Mexico

Thomas P. Rooney, Ph.D.
Science Fellow – The Rewilding Institute
Assistant Scientist
University of Wisconsin-Madison

Oscar Simpson
President
New Mexico Wildlife Federation
Albuquerque, New Mexico

Paul Sneed, Ph.D.
Environmental Studies Core Faculty -Graduate Programs
Prescott College
Prescott, Arizona

Kim Vacariu
Southwest Director
The Wildlands Project
Tucson, Arizona

Donald M. Waller, Ph.D.
Professor
Department of Botany
University of Wisconsin-Madison

Jeff Williamson
President
Arizona Zoological Society



References Cited:

Bormann, B.T., J.R. Martin, F.H. Wagner, G. Wood, J. Alegria, P.G. Cunningham, M.H. Brookes, P. Friesema, J. Berg, and J. Henshaw. 1999. Adaptive management. Pages 505-534 in: N.C. Johnson, A.J. Malk, W. Sexton, and R. Szaro (eds.) Ecological Stewardship: A common reference for ecosystem management. Elsevier, Amsterdam.

Johnson, B. L. 1999. The role of adaptive management as an operational approach for resource management agencies. Conservation Ecology 3(2): 8. [online] URL: http://www.consecol.org/vol3/iss2/art8/

Lee, K. N. 1999. Appraising adaptive management. Conservation Ecology 3(2): 3. [online] URL: http://www.consecol.org/vol3/iss2/art3/

Paquet, P.C., J. Vucetich, M.K. Phillips, and L. Vucetich. 2001. Mexican wolf recovery: three year program review and assessment. Prepared by the Conservation Breeding specialist Group for the U.S/ Fish and Wildlife Service.

Walters, C. 1997. Challenges in adaptive management of riparian and coastal ecosystems. Conservation Ecology [online]1(2):1. Available from the Internet. URL: http://www.consecol.org/vol1/iss2/art1/


APPENDIX A

The Rewilding Institute
POB 13768, Albuquerque, NM 87192 * TRI@rewilding.org www.rewilding.org


March 15, 2005

U.S. Fish and Wildlife Service
New Mexico Ecological Services Field Office
2105 Osuna Road NE
Albuquerque, NM 87113
ATTENTION: Mexican Wolf Project: Five-Year Review

Re: Comments on Mexican Gray Wolf Project Five-Year Review

The Rewilding Institute (TRI), a conservation think tank, welcomes the opportunity to comment on the U.S. Fish and Wildlife Service’s (FWS) draft 5-year review of the Mexican Wolf Reintroduction Project. We compliment the FWS for the detailed analyses and comprehensive assessments presented in the three documents that collectively represent the 5-year review of this ESA-mandated recovery program. Our comments on each of the three primary review documents follow.

Mexican Wolf Recovery: Technical Component of the Five-Year Program Review and Assessment

With some exceptions as noted below, TRI generally agrees with the four recommendations in the technical report for improving the Mexican wolf reintroduction project: 1) modify the current non-essential experimental population rule to allow wolves to colonize suitable habitats throughout the Southwestern Gray Wolf Distinct Population Segment (SWDPS) where they do not conflict with livestock or humans; 2) translocate wolves with wild experience after their first removal; 3) improve project databases; and 4) fund more research.

We strongly agree that there should be no restrictions to wolf movements throughout the geographic scope of the SWDPS or the geographic scope of the 1978 gray wolf listing rule, whichever rule currently applies. However, we strongly disagree with the part of recommendation number 1 that would exclude areas from wolf occupation where wolves “conflict with livestock and humans.” Most of the SWDPS comprises areas where wolves may come into conflict with livestock or humans. The report documents that 47% of the radio-collared wolves released into the Blue Range Wolf Recovery Area (BRWRA) were involved in at least one confirmed depredation incident and an additional 11% were removed for engaging in human-nuisance behavior. The report does not document how many individual wolves came into conflict with humans, but we assume it was more than the number of wolves removed from the wild for this reason. Wolf recovery goals (yet to be established by the Recovery Team) in the SWDPS may not be achievable if “conflict with livestock or humans” excludes areas from wolf recolonization. Thus, in areas within the SWDPS with high potential suitability for wolves (not considering conflict potential), innovative solutions for conflict resolution that do not result in the removal or exclusion of wolves from the area may be necessary for the achievement of SWDPS recovery goals and the goals of the current Mexican wolf reintroduction project. We request that the language of recommendation 1 be revised to indicate that while conflicts with livestock and humans must be addressed and resolved, they will not automatically preclude wolf recovery in a given area.

We strongly recommend that the experimental population rule be revised to allow initial releases of wolves anywhere in the Blue Range Wolf Recovery Area (BRWRA), Fort Apache Indian Reservation, and any other Native American or private lands within Mexican wolf historic range where the owners have entered into agreements to support wolf recovery. Data from the review document fully support this recommendation. To date there have been only 8 successful dispersals, only 3 of which were “natural.” Only 9 of 17 translocated (for depredation) wolves reproduced in the wild. Few, if any, suitable release sites remain in the primary wolf recovery zone because the area is mostly occupied by existing wolf packs. Large areas of the secondary wolf recovery zone (currently off limits to “direct” releases) remain unoccupied or sparsely occupied by wolves. Releases in New Mexico (secondary zone) have been more than twice as successful as releases in Arizona. The failure rate (mortality + removal) of radio-collared wolves is high (62%) and more releases are needed to meet population growth objectives. Wolves should be released in places that offer the greatest chances of success. There is no science-based reason to exclude from direct releases of wolves any part of the BRWRA or nearby areas where wolf recovery is authorized.

As recommended by the FWS report, existing boundaries limiting Mexican wolf recovery to the BRWRA must be removed. These boundaries were politically motivated and are not supported by sound science or FWS policy or practices for other endangered species. The greatest cause (36%) for removing reintroduced Mexican wolves from the wild has been their movement outside the established recovery boundaries. Sixty-eight percent of lone wolves have moved outside the boundary at least once; and 28% of all pack home ranges are partly outside the recovery area. Obviously, these boundaries are not recognized by the wolves. Removal of these wolves is unnecessarily slowing recovery and adding to recovery costs. Long-term recovery of wolves in the Southwest will require multiple populations connected by linkages that are suitable for the movement of wolves among the core populations. Existing boundaries are counterproductive to both short- and long-term recovery goals for wolves in the Southwest and are not supported by science or ESA policy.

We are deeply concerned by the conflict that exists between wolf recovery and livestock production on the public lands within the BRWRA and its effect on recovery success. On average, for every confirmed depredation incident, a wolf is removed from the wild or translocated. Nearly half of all monitored wolves eventually were involved in confirmed depredation incidents, which usually trigger a management response of removal from the wild or translocation. Wolves have the opportunity to learn to prey on domestic livestock nearly everywhere within the BRWRA. Rates of wolf removal exceed mortality rates and the combination of these rates (62%) is not sustainable. Under current rules, land use priorities, and management practices, we believe that self-sustained population growth achieving the project objective of at least 100 wolves will not occur without continued releases of wolves. Figure 3 clearly shows that population growth is heavily subsidized by continued releases of wolves to offset unsustainable failure (mortalities + removals) rates. Indeed, the EIS predicted that releases would not be needed beyond the year 2002, after which the population would be self-perpetuating (i. e., reproductive success would exceed failure rate). However in actual practice, releases have continued through 2004. This is not yet a “recovery” scenario. The report adds that removals of wolves for reasons of livestock depredation are not likely to decline. Given the near-ubiquitous distribution of livestock within the BRWRA, we view this as a serious impediment to wolf recovery. In our opinion, the restored population has not yet reached a “source” status, and we question whether it ever will under current rules. Many conservation biologists believe that large core areas capable of supporting viable “source” populations are key to recovery success. Unpublished research by Dr. Carlos Carroll has shown that the BRWRA has the potential to support a source population of wolves, but his analysis did not account for the high level of “management” removals in response to livestock depredations that are currently occurring and projected to continue in the BRWRA. The FWS report states that “[t]he overall pattern of source-sink dynamics within the BRWRA suggest that a large area may be required to maintain a viable population of wolves within the southwestern United States….” We agree.

We recommend that the revised rule prohibit the removal or lethal control (aversive harassment should continue to be encouraged) of wolves for engaging in livestock depredation within the currently defined BRWRA. Wolf recovery should be established as at least a co-equal (to livestock grazing) priority on the approximately 7,000 square miles of public lands within the BRWRA. We recognize that this is potentially a very controversial recommendation; and we are not recommending forced elimination of grazing privileges within the BRWRA. What we are recommending are innovative solutions that are fair to all interests and that promote wolf recovery. For example, these solutions may take the form of compensatory incentives to implement new livestock husbandry and management practices that minimize wolf-livestock conflicts and are compatible with wolf recovery objectives or voluntary grazing allotment retirement programs where permittees who choose to participate are generously compensated for the permanent retirement of their grazing allotment. Such approaches have been recommended elsewhere and bills pending in Congress proposing voluntary buyouts of grazing privileges on public lands have broad support from both livestock and conservation interests. If approached correctly with the involvement of key stakeholders, this need not be a controversial or adversarial recommendation. We believe it is essential to successful wolf recovery in the Southwest.

Having not done a legal analysis, it is not clear to us whether the above recommendation can be accomplished under the current “non-essential experimental population” classification. We believe that the current level of “take” of wolves authorized and accomplished through the provisions of the existing non-essential experimental population rule is unsustainable and violates the provision of section 10(j)(2)(A) of the ESA requiring that releases of listed species under section 10(j) provisions must “further the conservation” of the species. If the above recommendations cannot be accomplished under a revised non-essential experimental population classification, then we recommend that the revised rule reclassify this population as either “essential experimental” or fully endangered. In the latter case, the rule would be rescinded rather than revised.

Some specific comments on the technical report follow.

On page 70, the description of “event 1” is not entirely accurate. The dog was not “in camp” when it was attacked by the wolf, and the wolf was not “in camp” when it was shot. These events took place some distance away from the actual “camp” site.

Page 97, Comment #49: Scientists and administrators involved in the program need to have a high level of sensitivity to the political factors, operating at various levels, that seek to influence the program and resist purely politically motivated solutions to problems.

We strongly agree with this comment and note that the current short-comings of the Mexican Wolf Reintroduction Project stem directly from politically-motivated project components incorporated into the initial project design and non-essential experimental population rule. We strongly recommend a science-based revision of the current rule and science-based implementation of the project from this point forward.

Page 101, Comment #66: The primary author of this review is a member of the SWDPS Recovery Team and has no knowledge of a “population/habitat viability analysis of the wild population in the BRWRA” being conducted by the Recovery Team. Even if this statement by the FWS was true at the time this document was written, this action cannot now be categorized as “being implemented,” because activities of the SWDPS Recovery Team have been placed on indefinite hold, pending FWS interpretation of a recent litigation decision nullifying the validity of the 2003 rule that established the SWDPS as a listed entity under the ESA.


Mexican Gray Wolf Reintroduction Project Five-Year Review - Section B - Administrative Component

The Introduction section of this document fails to mention the turn-over in the Mexican Wolf Recovery Project Leader position and the long lapses of time during which the position remained vacant.

On page 10, this document states that “the Regional Director has stated that in order to revise the rule, the Service must first have a unified, consensus recommendation from the SWDPS Recovery Team, including both the Technical and Stakeholder sub-groups.” Anyone familiar with the makeup of the Recovery Team would conclude that this requirement is extremely unrealistic. Some members of the Recovery Team are also members of organizations that have twice sued the FWS in attempts to kill the reintroduction project and have all wolves removed from the wild. The Regional Director may as well require that “pigs fly.” As noted above the SWDPS Recovery Team’s status is currently “on hold,” and the Team is not currently active. The FWS recently cancelled the Recovery Team meeting scheduled for April and stated that no further meetings were scheduled.

The FWS has an affirmative responsibility and a mandate under the ESA to recover endangered species. That responsibility cannot be transferred to a non-government entity like the Recovery Team. Plus, as noted above, the Team's current and future status is uncertain. Furthermore, the nullification of the 2003 gray wolf listing rule does not obviate the FWS’s mandate under the ESA to continue to recover the Mexican gray wolf. Rather, the mandate reverts to the 1978 listing under which Mexican wolf recovery was conceived and implemented. The FWS has no legitimate excuse or reason to delay actions necessary for the recovery of the Mexican wolf. Indeed, it has every reason to expedite these actions.

Beginning at the bottom of page 12, the report states the following: “A modification to the rule to address the boundary has larger implications than allowing direct releases of wolves into the SRZ. The establishment of the SWDPS requires the Service to view recovery from a large-scale perspective encompassing the entire DPS, not just the BRWRA. As such, the Service needs to carefully consider how a rule modification for the BRWRA fits into the broader picture of delisting the SWDPS, including established recovery goals and objectives to be defined within the Recovery Plan. As discussed above in #4 however, the Service will not seek to modify the rule unless the Service receives a recommendation from the Recovery Team. After weighing the considerations from the Recovery Team and this Five-Year Review, the Service will be prepared to proceed with any necessary actions if altering the BRWRA boundary is determined to be a necessary outcome to recover the gray wolf in the SWDPS.” Please apply comments in the paragraph above to this section of the report, as well. In addition, it should be abundantly clear to the FWS and to the Recovery Team that successful recovery of gray wolves in the SWDPS depends upon and is advanced by successful recovery of the BRWRA population. Clearly, changes that will improve chances for the success of the BRWRA reintroduction project will contribute to and expedite the achievement of the ultimate objective of the SWDPS recovery plan, if such a plan is ever prepared. Such changes are clearly necessary to achieve the objectives of the project under review here. As mentioned above, recent litigation decisions do not absolve the FWS of its responsibility or authority to recover gray wolves under the ESA. The authority and mandate for advancing the recovery of the Mexican gray wolf derives, for the foreseeable future, from the 1978 listing document. Furthermore, the controlling objective for the BRWRA reintroduction project derives from the formally approved Mexican Wolf Recovery Plan. Thus, the existing Mexican Wolf Recovery Plan remains the controlling recovery document for this action. It is inappropriate and an abrogation of ESA responsibility for the FWS to postpone currently authorized recovery actions for the Mexican gray wolf, pending some uncertain future decision or plan rendered by the now inactive SWDPS Recovery Team.

The comments above apply equally to the last paragraph on page 13 of the report. Furthermore, the existing EIS analyzes an alternative without boundaries. Any additional NEPA analysis required for a revised rule should require considerably less time than the original EIS. The fact that additional analysis will be required before the rule can be changed also argues for getting started sooner rather than later.

We believe the issue of livestock carcasses serving as attractants to wolves and possible catalysts for the onset of livestock depredation behavior by wolves must be addressed through revisions to the rule. Compelling evidence for this recommendation is contained within the FWS report. The report states that 91% of wolves known to have scavenged dead livestock carcasses were confirmed to have subsequently killed living domestic livestock at least once; and up to 68% of those engaged in additional livestock depredation activities. Removal of wolves for livestock depredation is a significant component of the high failure rate reported by the FWS and a continuing cause of the failure to meet population growth objectives when continuing annual releases are discounted. To date 27 wolves have been removed from the wild for depredation and an additional 24 have been translocated. The report fails to discuss the “attractant” aspect of livestock carcasses and the role carcasses may play in bring wolves into close proximity of living livestock.

Methodology for Evaluating Socioeconomic Impacts Associated with the
Reintroduction of the Mexican Wolf

This evaluation should place livestock depredation by wolves in proper perspective by comparing this source of livestock mortality to all other sources of livestock mortality.

To be fair, the socio-economic assessment should address both the potential effects/conflicts of wolf recovery on the existing/future socio-economic landscape of the region and the potential effects/conflicts of the existing/future socio-economic landscape of the region on the success of wolf recovery efforts. Even though the FWS’s goal is to overlay wolf recovery onto existing land use practices, this analysis needs to remain open to the possibility that land use priorities on public lands may need to change (as discussed above) to accommodate wolf recovery at a meaningful level. One major difference between this and other gray wolf recovery projects is the lack of a large wild “core” recovery area where conflicts between wolf recovery and other land uses generally do not exist.

Additionally, this analysis must address the potential economic benefits to the region from wolf recovery as well as the potential costs.

Finally, we note that this is the third technical review of this project since 1999—all of which have recommend that the existing rule be revised. Also, in September of 1999, the Regional Director and the Assistant Secretary of the Interior for Fish Wildlife and Parks authorized the FWS to carry out actions that would result in an expeditious revision of the rule. These recommendations have come from both external independent scientists and internal agency scientists and decision makers. The consensus opinion of the scientific experts is that the rule needs to be revised to enhance the prospects for recovery of the Mexican gray wolf. We set forth our recommendations for rule revisions in these comments. The FWS has now delayed this important decision for 5.5 years! Further delays cannot be justified.

The Rewilding Institute appreciates this opportunity to comment. These official comments of The Rewilding Institute are also endorsed by the individuals and organizations whose names appear below the signature block.

Sincerely,



David R. Parsons
Wildlife Biologist
Vice Chairman & Science Fellow

The following individuals and organizations endorse these comments:

Dave Foreman
Director, Senior Conservation Fellow, and Board Chairman
The Rewilding Institute
Albuquerque, New Mexico

Michael Soulé, PhD
Senior Science Fellow – The Rewilding Institute
Professor Emeritus in Environmental Studies
University of California, Santa Cruz.

Animal Defense League of Arizona
Tucson, Arizona

Arizona Wilderness Coalition
Alpine, Arizona

Paul Beier, PhD
Professor
Conservation Biology & Wildlife Ecology
Northern Arizona University

Matthew Clark
Conservation Fellow – The Rewilding Institute
Graduate Student in Conservation Biology
Northern Arizona University

Colorado Plateau Chapter of the Society for Conservation Biology
Flagstaff, Arizona

Nicole J Corbo
Coordinator, Grand Canyon Wolf Recovery Project
Flagstaff, Arizona

Kim Crumbo
Conservation Fellow – The Rewilding Institute
Wilderness and Planning Coordinator
Grand Canyon Wildlands Council
Flagstaff, Arizona

Forest Guardians
Santa Fe, New Mexico

Grand Canyon Wildlands Council
Flagstaff, Arizona

Grand Canyon Wolf Recovery Project
Flagstaff, Arizona

Ed Grumbine, PhD
Conservation Biologist
Prescott College
Prescott, Arizona

Robert Howard, PhD
Conservation Fellow – The Rewilding Institute
El Dorado, New Mexico

Allison Jones
Science Fellow – The Rewilding Institute
Conservation Biologist
Wild Utah Project
Salt Lake City, Utah

C. Wesley Leonard
Chairman, New Mexico Wilderness Alliance
El Paso, Texas

Brian Miller, PhD
Science Fellow – The Rewilding Institute
Conservation Biologist
Wind River Ranch Foundation
Watrous, New Mexico

Susan Morgan, PhD
Conservation Fellow – The Rewilding Institute
Albuquerque, New Mexico

New Mexico Wilderness Alliance
Albuquerque, New Mexico

New Mexico Wildlife Federation
Albuquerque, New Mexico

Paul Paquet, PhD
Science Fellow – The Rewilding Institute
Wolf Biologist
University of Calgary & Conservation Science, Inc.
Calgary, Alberta, Canada

Tony Povilitis, PhD
Conservation Biologist
Zuni, New Mexico

Thomas P. Rooney, PhD
Science Fellow – The Rewilding Institute
Assistant Scientist
University of Wisconsin-Madison

Donald M. Waller, PhD
Professor
Department of Botany
University of Wisconsin-Madison


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