Record-breaking Number of Comments Delivered to Trump Administration Opposing Federal De-listing of Wolves

Agency logged 700,000 comments, but final total may be as high as 1.8 millionAnimal Wellness Action and the Animal Wellness Foundation submitted comments to the U.S. Fish and Wildlife Service in opposition to the agency’s March 15th proposed rule to remove federal Endangered Species Act protections for gray wolves across most of their range in the lower 48 states. The good news is, we were not alone.  As many as 1.8 million people may have weighed in and said it was a terrible idea. (Portions of this blog are drawn from our official public comment to the agency.

Of all the comments submitted, the best guess is that 99 percent of them shared our opinion that de-listing is premature, dangerous for wolves, and a derogation of duty by the federal government under the terms of the Endangered Species Act.  This volume of comments is an extraordinary outpouring of concern, and shows a sea-change in how the public views these animals.  The myths that have long been part of our culture, most prominently through the story of Little Red Riding Hood, are rightly being recognized as deeply flawed representations of wolves.

Two weeks ago, Animal Wellness placed a full-page ad in the New York Times appealing to President Trump to intervene with the Interior Department and to work to maintain protections for wolves – as he did in November 2017 when he called elephant hunting a “horror show” and stopped import permits for sport-hunted trophies of elephants from coming in the U.S. from Zambia and Zimbabwe.

While wolves are reproducing and surviving in a fraction of their former range, they face an array of mortality threats, most of them human-caused. That means that just maintaining populations in a human-occupied landscape is an uncertain proposition given the perils they confront.

Some years ago, the Northern Great Lakes states pledged a five-year moratorium on hunting and trapping of wolves after de-listing, but abandoned that pledge when the animals had federal protections taken away.  In fact, after federal delisting (which was subsequently reversed by the federal courts), Minnesota, Wisconsin, and Michigan rushed to institute trophy hunting and commercial trapping programs for wolves—exposing them to random killing for the first time in more than 40 years. Minnesota and Wisconsin especially authorized some of the most abusive and unsporting practices, including hound hunting, snares, baiting, electronic calls and the use of leg hold traps, producing a body count well past 1000 animals over two hunting seasons. Wolf numbers declined in every state – with Wisconsin alone losing 17 family units in just three seasons, a fifth of its total wolf population just through hunting and trapping.

The state agencies that have been clamoring to delist wolves have already demonstrated a failure to act with restraint, and that is powerful evidence that safeguards are not in place to maintain wolf populations. The delisting proposal – by giving wolf management authority to state fish and wildlife agencies – is a passing of the baton, but it comes with no requirements for the agencies to run straight and keep wolves protected. They can run in whatever direction they wish on the issue, and we know that so many state officials are taking cues from the trophy hunting, trapping, and ranching lobbies. There remains a small but influential segment of the population with a barely contained hatred of wolves, with the individuals exhibiting irrational human behavior and a lack of understanding about the wolves’ very modest impacts on livestock or their beneficial impacts on ecosystems. These retrograde attitudes combine to create a dangerous and toxic political atmosphere for wolves that continues to be a very practical threat to their survival.

The March 2019 de-listing proposal, unlike prior proposals to remove protections in the Northern Rockies or the Northern Great Lakes, calls for removing federal protections across the totality of their occupied range in the lower 48 states. Yet even a conservative assessment of their status suggests that wolves have a tenuous foothold in their habitats and the species is not yet recovered. Wolves are just starting to repopulate small and remote portions of California, Oregon, and Washington, which itself has killed entire packs in order to address supposed livestock depredations. There are just occasional reports of wolves in the Basin and Range province in Utah and Nevada, and wolves have yet to colonize the millions of acres of suitable habitat in Colorado. The absence of wolves in Colorado is a debilitating detail for the government because their presence on millions of acres would provide essential connectivity, linking the heavily persecuted populations in the Northern Rockies to the small and struggling Mexican wolves working every day to survive in Arizona and New Mexico.

What we have learned, even with the modest populations that inhabit our nation, is that wolves bring extraordinary ecological benefits to ecosystems.  Dozens of world-renowned wildlife biologists and scientists have attested to these benefits in writing to Congress and to the USFWS. Wolves play a critical role their native ecosystems, as anyone who has watched the powerful documentary How Wolves Change Rivers can see. Biologists in Yellowstone have found that wolves move deer and elk populations from overgrazed areas, enabling aspen and willow to reclaim ground for the first time in more than half a century.

With the help of beavers, wolves have restored streams and reduced flooding and bank erosion.  In Yellowstone, restored streams have attracted more plants, songbirds, water-wading birds, and moose. Wolf predation helps maintain healthy deer populations, lowering the frequency of deer-auto collisions and the prevalence of crop losses.  They cull weak, old, and sick animals from populations and mitigate browsing on vegetation and bringing great vitality to the entire ecosystem.  This has the potential to save human lives and tens of millions of dollars for the states.

Wolves also play an additional role in our economy.  Thousands of people have been drawn to Michigan’s Isle Royale National Park because of the lure of the storied predator-prey, wolf-moose relationships.  The International Wolf Center in Ely, Minn. contributes $3 million to the local economy annually. Annual visitor spending has increased by $35.5 million since the reintroduction of wolves in the states surrounding Yellowstone National Park.  The public would rather see wolves celebrated than cut down in their tracks. Many polls show Americans want wolves restored to the American landscape and conserved for future generations.

And although some wolves do occasionally prey on livestock, it’s minimal.  Wolves kill account for between just 0.1 percent and 0.6 percent of all livestock deaths.  And of all of the world’s top predators, they are among the least threatening to human beings – with no documented attacks by healthy, wild wolves on people in the lower 48 states in the last century.

A relatively recent 25-year Washington State University study found that indiscriminate killing actually increases the tendency of wolves to prey on livestock, in part by breaking up stable wolf packs and allowing younger, less dominant animals to start breeding and expanding into new territories.

Wolves are anything but the rapacious species that their critics caricature. The depth of their misunderstanding of wolves is on par with their overly optimistic reading of their current state of wolf population health. It is premature to remove federal protections for wolves, and we urge the agency to hear the collective voice of the people and not to court more legal confrontations. Wolves need continued federal protection and de-listing at this time is unwarranted and unsupported by the science or the law.