Take Action for Mexican Gray Wolves Today!

By: Dave Parsons

March 13, 2026

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Carnivore Conservation Biologist Dave Parsons has annotated various provisions of the H.R. 4255 that are based on fiction rather than facts or that violate the requirements and procedures of the ESA for formally declaring species to be “recovered” and no longer threatened with extinction. See below.

*Annotated notes on the bill are in bold and underlined. 

IN THE HOUSE OF REPRESENTATIVES
June 30, 2025

Mr. Gosar (for himself, Mr. Biggs of Arizona, Ms. Boebert, Mr. Crane, Ms. Hageman, Mr. Hamadeh of Arizona, Mr. Hurd of Colorado, Mr. LaMalfa, Mr. Stauber, Mr. Tiffany, and Mr. Zinke) introduced the following bill; which was referred to the Committee on Natural Resources

A BILL
(H.R. 4255)

To remove the Mexican wolf from the lists of threatened species and endangered species published pursuant to the Endangered Species Act of 1973, and for other purposes.

Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, 

SECTION 1. SHORT TITLE.

This Act may be cited as the “Enhancing Safety for Animals Act of 2025.”

Wolves are animals, too, and are protected by the Endangered Species Act. All agencies have an affirmative mandate under the ESA to take measures to support their protection and recovery.

SEC. 2. DELISTING OF MEXICAN WOLF.

(a) Findings.—The Congress finds the following:

(1) The Mexican wolf population has increased for 9 consecutive years, growing by at least 11 percent in 2024.

(2) At the end of 2024, the United States Fish and Wildlife Service documented a presence of at least 286 wild Mexican wolves and approximately 350 captive Mexican wolves.

(3) The United States Mexican Wolf population is thriving and will meet its recovery goals for gene diversity, population growth, and abundance.

Not true. Current recovery goals are not supported by the best available science as required by the ESA; and goals established in the current plan are only met when stable populations are established in both the U.S. (320) and Mexico (200). Independent scientists, not affiliated with the state and federal agencies, believe these goals are inadequate to prevent the extinction of Mexican wolves. Under the current 2022 recovery plan, the U.S. goal of 320 wolves allows for downlisting Mexican wolves to the ESA status of “threatened.” It is not a “recovery” or “delisting” goal.

(4) The United States Fish and Wildlife Service has repeatedly moved Mexican wolf recovery goalposts through amended recovery plans, revised population and genetic objectives, and reduced mitigation opportunities.

Not true. The original 1982 recovery plan was focused on preventing extinction of Mexican wolves. It proposed an initial reintroduction goal of establishing 100 wolves in an area of at least 5,000 square miles of suitable wolf habitat. This was not a recovery (delisting) goal. A second recovery plan was not approved until 2017 and was slightly revised in 2022. Both the 2017 and 2022 plans have the same recovery (delisting) goal of 320 wolves in the U.S. and 200 wolves in Mexico.

(5) Current United States Fish and Wildlife recovery strategies and goals encompass not only the Mexican wolf population in the United States, but also in Mexico.

True.

(6) Americans in the Mexican Wolf Experimental Population Area bear the brunt of a rapidly growing United States Mexican wolf population without any chance of recovery because of failing conservation activities in Mexico, a foreign country.

Mexican wolf conservation/recovery in Mexico lags well behind goals established in the recovery plan. Following more than a decade of recovery efforts, fewer than two dozen Mexican wolves are estimated to exist in the wild. The U.S. Fish and Wildlife Service should not have relied on the recovery performance of a foreign country, over which it has no authority or control, for meeting ESA delisting requirements for Mexican wolves. A draft recovery plan developed by USFWS-appointed independent scientists in 2012 presented a plan for full recovery within the U.S. Southwest. That plan was rejected by the states and never approved by USFWS.

(7) Mexican wolves in the United States routinely kill livestock, pose serious safety risks to humans and pets, excessively prey upon game animals, and reduce recreational opportunities.

Mexican wolves do occasionally kill livestock and pets. Methods exist for effectively reducing depredation losses and fostering coexistence between human enterprises and wolves in their native environments. Such methods are not widely used by livestock owners within the Mexican wolf recovery area. Agency data show that the rate of livestock depredations is actually declining.

In all of recorded history, there has not been a single incident of a Mexican wolf attacking or harming a human.

There is no credible evidence of reduced recreational opportunities caused by the presence of Mexican wolves. To the contrary, the experience of many recreational users in the wolf recovery area is enhanced by the presence of wolves and the possibility of seeing or hearing them in their native habitat.

Lastly, Mexican wolves do not prey “excessively” on game animals. Population estimates of game animals and the success of hunters have not declined following the reintroduction of Mexican wolves, which began in 1998.

(8) Depredation of cattle, horses, and other livestock by Mexican wolves financially burdens American farmers and ranchers living in and near the Mexican Wolf Experimental Population Area.

All federal agencies are mandated under the Endangered Species Act to implement programs to achieve recovery of listed endangered species on lands they manage. Endangered species recovery is a mandated and authorized use of federal lands, which is generally not tolerated on private lands. Authorized grazing allotments are nearly ubiquitously distributed on federal lands throughout the designated Mexican wolf recovery area. According to USDA data, the federal grazing fee of $1.69 per month for a cow and her calf is about 8% of the private rate for leasing Southwestern grazing lands (https://www.nass.usda.gov/Charts_and_Maps/Grazing_Fees/gf_am.php). This establishes a de-facto subsidy for potential livestock production losses resulting from the overlay of other authorized, co-equal uses of the federal lands, such as endangered species recovery.

(9) Rather than streamline Mexican wolf depredation evidentiary standards to ensure ranchers are properly compensated for livestock losses, the Wildlife Services division of the Animal and Plant Health Inspection Service imposed for a year a new standard requiring that subcutaneous hemorrhaging be present on carcasses as a condition of confirming that an animal was killed by a Mexican wolf.

(10) Confirming that livestock were killed by Mexican wolves is often impossible under the newly adopted evidentiary standard because livestock grazing areas in and near the Mexican Wolf Experimental Population Area are often thousands of acres in size, depredations are commonly only discovered days after they occur, scavengers often devour livestock carcasses along with depredation evidence, and subcutaneous hemorrhaging remains preset for a short period of time following depredation.

An effective method for reducing livestock losses is to monitor the herd by a “range rider.” And maintaining livestock in a herd has also been shown to reduce predation as compared to allowing livestock to be scattered throughout their range. Confining mother cows for calving (as opposed to random calving on the open range) can significantly reduce depredation of calves. This is common sense animal husbandry, especially in areas with native carnivores like cougars, bears, coyotes, and wolves.

(11) Requiring evidence of subcutaneous hemorrhaging is inconsistent with other widely accepted depredation evidentiary standards like bite marks, tracks, and signs of struggle, and significantly reduces the ability for livestock owners to be made whole financially after suffering losses through Mexican wolf depredation.

(12) The Animal and Plant Health Inspection Service’s opaque depredation evidentiary standards are not subject to a public notice and comment process but are nevertheless blindly adopted by the United States Fish and Wildlife Service.

These evidentiary standards were developed to reduce the prevalence of erroneous depredation confirmations. Fraudulent calls were recently exposed by a former New Mexico state director of Wildlife Services, an agency within the USDA.

Robert “Goose” Gosnell administered Wildlife Services in New Mexico for a year and a half as state director of the USDA Animal and Plant Health Inspection Service, a job at which he says he inherited an entrenched and systemic corruption problem. “I know some of those depredation [report]s that caused [wolf] removals were illegal,” he told The Intercept, explaining that inspectors had been instructed by superiors to confirm livestock loss incidents as “wolf kills” for ranchers. “My guys in the field were going and rubber-stamping anything those people asked them to.” He described how many also worked second jobs as hunting guides for the same ranchers whose claims they evaluated — a violation of federal ethics codes. (https://theintercept.com/2022/05/24/mexican-gray-wolf-endangered-wildlife-services-fraud/)

(13) The United States Fish and Wildlife Service has refused to take or approve sufficient lethal removal actions against Mexican wolves despite the deaths, injuries, and damage caused by Mexican wolves leading to at least 2 counties within the Mexican Wolf Experimental Population Area declaring a public disaster and emergency, and at least 1 Tribal government formally supporting such declaration

Lethal removal should be the “last resort” action after non-lethal methods have been earnestly implemented without success; and is not justified if monetary compensation is paid for the lost livestock, unless persistent efforts using non-lethal deterrence methods fail.

(b) Delisting Of Mexican Wolf.—Notwithstanding any other provision of law, the Mexican wolf (Canis lupus baileyi) is removed from the lists of threatened species and endangered species, as applicable, that are published pursuant to section 4 of the Endangered Species Act of 1973 (16 U.S.C. 1533).

The ESA prohibits delisting of a listed species until science-based recovery criteria have been met. This standard has not been met even under the scientifically deficient criteria of the current recovery plan. Section 7(a)(2) of the ESA, requires federal agencies to base their decisions on the best available scientific data. Unscientific, politically motivated decisions are specifically prohibited.

(c) Nullification Of Rules Relating To Mexican Wolf.—The following final rules issued by the United States Fish and Wildlife Service with respect to the Mexican wolf shall have no force or effect:

(1) The final rule titled “Endangered and Threatened Wildlife and Plants; Endangered Status for the Mexican Wolf” (80 Fed. Reg. 2488; published January 16, 2015).

(2) The final rule titled “Endangered and Threatened Wildlife and Plants; Revision to the Nonessential Experimental Population of the Mexican Wolf” (87 Fed. Reg. 39348; published July 1, 2022).

Rulemaking (or unmaking) is the purview of the Administrative Branch not the Legislative Branch.

(d) Bifurcation Of Mexican Wolf Population Criteria.—If the Mexican wolf (Canis lupus baileyi) is listed as a threatened species or an endangered species under the Endangered Species Act of 1973 (16 U.S.C. 1531 et seq.) after the date of the enactment of this section, the Secretary of the Interior, acting through the Director of the United States Fish and Wildlife Service, may not reference or otherwise consider—

(1) the status of the recovery of the Mexican wolf in Mexico in developing or implementing under section 4(f) of that Act (16 U.S.C. 1533(f)) a plan for the Mexican wolf; or

(2) the status of the Mexican wolf in Mexico in determining under section 4(c) of that Act (16 U.S.C. 1533(c)) whether the Mexican wolf should be—

(A) changed in status from an endangered species to a threatened species;

(B) changed in status from a threatened species to an endangered species; or

(C) removed from the lists of threatened species and endangered species, as applicable, that are published pursuant to section 4 of the Endangered Species Act of 1973 (16 U.S.C. 1533).

Wolf conservation advocates agree that coupling wolf recovery efforts in Mexico with recovery efforts in the United States to achieve ESA delisting criteria is delaying the achievement of established recovery goals for Lobos in the U.S. Southwest. The Endangered Species Act is a U.S. law with no legal effect in Mexico. While wolf recovery in Mexico is supported by the public, U.S. Fish and Wildlife Service, and the states of Arizona and New Mexico, recovery efforts in Mexico should not be considered as part of the delisting criteria.

Critique provided by David Parsons, Wildlife Biologist: U.S. Fish and Wildlife Service, retired, and former Mexican Wolf Recovery Coordinator for USFWS. March 04, 2026.