Category Archives: Open letters

Comment on FWS-R3-ES-2011-0029, proposed rule to remove western Great Lakes wolves from the Endangered Species List

On May 5, 2011, the United States Fish and Wildlife Service announced a proposal to remove wolves in the western Great Lakes from the Endangered Species List. The proposal would also recognize the eastern wolf (Canis lycaon) as a distinct species and revise the ranges of the gray wolf (C. lupus) and the eastern wolf accordingly. Finally, the proposal would review the status of the eastern wolf to see if it should be added to the federal list of endangered and threatened wildlife. Public comments were accepted until July 5, 2011. My comment follows.

Please accept my comments below on the May 5, 2011 Federal Register notice on wolves: Docket No. FWS-R3-ES-2011-0029.

Please remove the Western Great Lakes Designated Population Segment of gray wolves from the List of Endangered and Threatened Wildlife. The Western Great Lakes states of Minnesota, Wisconsin, and Michigan all have large areas of contiguous, high-quality habitat with a healthy, sustainable wolf population that is either growing or stable. The management plans that would take effect upon delisting assure that the their wolf population will not decline to a level that will threaten its viability. In addition, post-delisting monitoring of the wolf population will provide an adequate warning of any threat to the population’s viability.

As the wolf population in the Western Great Lakes has increased, so have conflicts between wolves and humans. In particular, wolves are responsible for killing increasing numbers of pets and livestock every year. Continued federal Endangered Species protection of wolves while these conflicts grow will turn public opinion against their recovery and, I believe, a negative public opinion of wolves poses a greater long-term threat to their recovery than delisting. The Western Great Lakes states have fostered a sustainable and healthy wolf population, and their game departments and residents should control its management.

Notwithstanding the Western Great Lakes states and their successful wolf recovery, there are still vast areas of the wolf’s former range that contain suitable habitat but few or no wolves. Please continue to protect wolves as endangered in the Rocky Mountains (eastern Washington and Oregon, Idaho, Montana, Wyoming, Utah, and Colorado), the Pacific Northwest (the Cascade Mountains, the Olympic Peninsula, the Coastal Range, the Klamath Mountains, the Sierra Nevada, and the Great Basin), and the Southwest (Arizona and New Mexico) as endangered and proceed with their recovery.

In light of recent taxonomic evidence, the eastern wolf (Canis lycaon) should be restored and protected in New York and New England, which were part of its former range, and where habitat exists that may support over 1,000 wolves. Restoring this species in the Northeast is in line with the U.S. Fish and Wildlife Service’s national wolf strategy to restore all substantially unique genetic lineages.

Wolves are an umbrella species, and land that sustains wolves is healthy and capable of sustaining many other forms of life. Wolves naturally reduce populations of deer and elk, and this in turn reduces browsing pressure, increases songbird abundance and diversity, provides food for scavengers, and reduces the populations of smaller predators, which are themselves a significant nuisance.

Wolves are also a species with great existence value. Many surveys have shown that Americans want a healthy, wild population of wolves, even if they never experience the wolves themselves. Many of our forests have become sterile landscapes dominated by herbivores, and returning these beautiful, intelligent, and social animals will bring them back to life.

Thank you for your consideration.