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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:


  • 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 th