Scientists Reject Moves to Remove Wolf Protections
"Because of these significant shortcomings with the draft rule we request that FWS terminate the reclassification process. We understand the significance of our request. However, in the draft the FWS defines details concerning wolf recovery in the western U.S. that do not adhere to relevant biological or legal standards," the scientists' letter reads.
"Consequently, a final rule based on the draft will result in substantial litigation, diminish the significant progress with wolf recovery in the Great Lakes region and the northern Rockies, imply to many observers that the Rule is motivated by politics rather than science, and undermine the credibility of the Endangered Species Act and the Service's ability to implement the Act in an honest and objective manner."
Signers of the letter included many of the continent's most prominent wildlife biologists, ecologists, conservation biologists, population biologists, sociologists, and environmental scientists, including Dr. Paul Ehrlich of Stanford University, Dr. Stuart Pimm of Columbia University, Dr. Michael Soulé of the University of California at Santa Cruz, Dr. John Terborgh of Duke University and Dr. David Inouye of the University of Maryland. A copy of the letter and list of signers follows this release. "Secretary Norton wants to back away from the job of wolf recovery before the job's finished," said Dr. Mark Shaffer, senior vice president for programs at Defenders of Wildlife. "No one is more anxious to see successful wolf recovery than the signers of this letter and the conservation groups that have invested years in the project, but for FWS to pull the plug prematurely will undo the progress we've made and delay true recovery, perhaps for decades."
A core concern of the scientists signing the letter is that the draft rule would eliminate prospects of wolf recovery in vast areas of prime habitat outside of the Great Lakes and northern Rockies. The proposed rule "overlooks or abrogates scientific and legal principles including the FWS's affirmative responsibility to restore gray wolf populations to 'significant gaps' within the species' historic range that are currently unoccupied, but where restoration remains feasible."
"Scientists have concluded that top predators, notably the gray wolf, are absolutely essential for long-term maintenance of the balance of nature and therefore the long-term maintenance of biodiversity," noted Mike Phillips, executive director of the Turner Endangered Species Fund. The FWS proposal is coming under fire from all sides, including a letter from fish and wildlife agencies in five different states expressing serious concerns about the draft rule.
"Politics rather than science seems to be driving the department on this issue, but it seems to be driving them straight into a brick wall," said Jen Callahan, Rocky Mountain director of the Wildlands Project.
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The Turner Endangered Species Fund is a non-profit organization and a recognized leader in the conservation of nature through projects that ensure the persistence of imperiled species and their habitats with an emphasis on private land. For more information, visit www.tesf.org.
The mission of the Wildlands Project is to
protect and restore the natural heritage of North America through the
establishment of a connected system fo wildlands. Conservation biology is the
cornerstone of the work of the Wildlands Project and this work has influenced
how conservation organizations throughout North America protect biodiversity. To
learn more about Wildlands Project or their publication "Wild Earth," visit www.wildlandsproject.org."
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ATTACHMENTS FOLLOW:
Secretary Gale Norton, DOI
1849 C St. NW
Washington, DC 20240
May 29, 2002
Dear Secretary Norton:
We are writing to express our concern with the U.S. Fish and Wildlife Service's Proposal to Reclassify and Remove the Gray Wolf From the List of Endangered and Threatened Wildlife in Portions of the Conterminous United States; Proposal to Establish Three Special Regulations for Threatened Gray Wolves; Proposed Rule (50 CFR Part 17 pp. 43450-43496) that was released on July 13, 2000. As scientists (wildlife biologists, ecologists, conservation biologists, population biologists, sociologists, and environmental scientists) we are familiar with the Endangered Species Act and conservation of imperiled large carnivores. We believe that the proposed rule overlooks or abrogates scientific and legal principles including the FWS's affirmative responsibilities under the ESA to restore gray wolf populations to "significant gaps" within the species' historic range that are currently unoccupied, but where restoration remains feasible.
Feasibility studies have identified areas with habitat capable of sustaining populations of wolves in the Northeast (New York, Maine, Vermont, New Hampshire - Harrison and Chapin 1997, Mladenhoff et al.); Colorado (Bennett 1994, Martin et al. 2000, Carroll et al. in review); portions of California and Oregon (Carroll et al. 2001); and Washington (Laufer and Jenkins 1989, Dietz 1993, Hosack 1997, Ratti et al. 1999, Gaines et al. 2000). Similar studies are under way for northern Arizona (Sneed 2000), northern Utah, southeastern Idaho, southwestern and central Wyoming, and southeastern Utah, Arizona, New Mexico, and the northern portion of Mexico (Carroll et al. 2002). Inexplicably the FWS proposal intends to do nothing to pursue additional wolf restoration opportunities.
While unquestionable progress has been made towards wolf recovery in the lower 48 states for which the FWS should be commended, the proposed rule contains some major flaws that depart significantly from the letter and spirit of the Endangered Species Act (ESA), agency policies and regulations, the principles of conservation biology, and even from an important observation articulated by the FWS in the proposal: ...we [FWS] have identified geographic areas where wolf recovery is occurring or is feasible, and will focus recovery efforts on those geographic entities, regardless of the subspecies affiliation of current or historic gray wolves in those areas. We recognize the benefits to the species of focusing recovery efforts across a large expanse of the species' range in order to recover and retain as much of the remaining genetic variation as is feasible. This approach will promote the recovery of the gray wolf throughout representative areas of their historic range in the conterminous 48 States (65 Fed. Reg. 43451-43452, July 13, 2000).
It is also important for the FWS to acknowledge the role that top predators such as the gray wolf have in maintaining the health of ecosystems. Terborgh et al. (1999) concluded that top predators were essential for long-term maintenance of biodiversity and recommended that their reestablishment in areas where they had been extirpated be given high priority. This accepted scientific opinion could help the FWS fulfill the leading purpose of the ESA through wolf conservation, namely "to provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved ..." 16 U.S.C. § 1531(b).
Not having wolves in an ecosystem leaves the top predator niche filled by mesopredators. Mesopredators, when they are occupying the highest trophic level, can be responsible for decreased biodiversity because they tend to prey on a wide variety of smaller animals. Wolves will also increase the mount of available carrion in an ecosystem with potentially positive effects for scavenger species such as bear, foxes, weasels, and raptors (Crabtree and Sheldon 1999). There is ample evidence that highly interactive carnivores like the wolf perform other critical ecological functions; without them ecosystems tend to become simplified (lose species), are degraded (failure to recruit forest trees), or even lose entire habitats (such as beaver pond wetlands). Ecological principles as well as demographic goals should guide recovery decisions.
Because of these significant shortcomings with the draft rule we request that FWS terminate the reclassification process. We understand the significance of our request. However, in the draft the FWS defines details concerning wolf recovery in the western U.S. that do not adhere to relevant biological or legal standards. Consequently, a final rule based on the draft will result in substantial litigation, diminish the significant progress with wolf recovery in the Great Lakes region and the northern Rockies, imply to many observers that the Rule is motivated by politics rather than science, and undermine the credibility of the Endangered Species Act and the Service's ability to implement the Act in an honest and objective manner.
Because FWS has long been engaged in the rule-making process, ex parte concerns have prevented effective collaboration with state agencies, conservation NGOs, and the academic community. By withdrawing that portion of the rule specific to the western U.S. and continuing with recovery efforts specific for the northeast, the FWS will create an opportunity to collaborate with informed and affected parties to develop a strategy that protects wolves,provides for delisting where appropriate, and advances restoration to suitable but unoccupied habitat. This will ensure that eventually the species is recovered throughout a significant portion of its historic range, necessary to maximize the species' long-term prospects for survival.
We look forward to hearing from you concerning this matter. We would welcome an opportunity to discuss our concerns with your further. In this regard, we would be happy to help organize an informal workshop or meeting with you or your staff.
Sincerely,
See attached list of scientists
cc: Steve Williams, Director, U.S. Fish and Wildlife Service Gary Frazer, Assistant Director for Ecological Services, USFWS Additional copies to USFWS personnel via e-mail: Ron Refsnider, Ed Bangs, Brian Kelly, Dale Hall, Ralph Morgenweck, and Jim Tate
SIGNATURES:
1. Sean Anderson, Ph.D. Postdoctoral Fellow Center for Conservation Biology Department of Biological Sciences Stanford University
2. John J. Beecham, Ph.D. Sr. Conservation Zoologist Wildlife Conservation Society
3. Paul Beier, Ph.D. Professor, Wildl. Ecol. and Cons. Biol. School of Forestry Northern Arizona University
4. Jim Catlin, Ph.D. Project Coordinator Wild Utah Project
5. Tim W. Clark, Ph.D. Adjunct Professor, Wildlife Biology and Policy Yale School of Forestry and Environ. Studies
6. Kevin Crooks, Ph.D. Department of Wildlife Ecology University of Wisconsin - Madison
7. Paul K. Dayton, Ph.D. Scripps Institution of Oceanography
8. James Dietz, Ph.D. Conservation Biologist University of Maryland
9. Barbara L. Dugelby, Ph.D. Ecologist
10. Paul R. Ehrlich, Ph.D. Bing Professor of Population Studies President, Center for Cons. Biology Stanford University
11. James A. Estes, Ph.D. Research Scientist, USGS
12. Chris Fagan, M.Sc. Director , ParksWatch
13. Nina Fascione, M.A. Director of Carnivore Conservation Defenders of Wildlife
14. Curtis Freese, Ph.D. Director, Northern High Plains Ecoregion World Wildlife Fund
15. Ed Grumbine, Ph.D. University of California, Santa Cruz.
16. Hanne S. Hansen, Ph.D. Professor Animal Nutrition and Physiology
17. David W. Inouye, Ph.D. Director, Graduate Program Sustainable Development and Cons. Biol. University of Maryland
18. James R. Karr, Ph.D. Professor University of Washington
19. Renata Leite, Ph.D. Research Associate Center for Tropical Conservation
20. Rurik List, Ph.D. Instituto de Ecología UNAM
21. Gary Luck, Ph.D. Center for Conservation Biology Stanford University
22. Carlos Martínez del Rio, Ph.D. Department of Zoology and Physiology University of Wyoming
23. Jennifer MB Manson, M.A. Administrative Assistant Center for Conservation Biology
24. Gary K. Meffe, Ph.D. Editor-in-Chief, Conservation Biology Adjunct Professor, University of Florida
25. Brian Miller, Ph.D. Coordinator of Conservation Biology Denver Zoological Foundation
26. William Newmark, Ph.D. Research Curator Utah Museum of Natural History
27. Elliott A. Norse, Ph.D. President Marine Conservation Biology Institute
28. Barry R. Noon, Ph.D. Professor Dept. of Fishery and Wildlife Biology Colorado State University
29. Reed Noss, Ph.D. Chief Scientist Wildlands Project
30. Ronald M. Nowak, Ph.D. Mammalogist
31. David R. Parsons, M.Sc. Wildlife Biologist Former Mexican Wolf Recovery Coordinator
32. Paul C. Paquet, Ph.D. Faculty of Environmental Design University of Calgary Calgary, AB
33. Mike Phillips, M.Sc. Executive Director Turner Endangered Species Fund
34. Stuart Pimm, Ph.D. Professor of Conservation Biology Center for Environ. Res. and Conserv. Columbia University
35. Nigel Pitman, Ph.D. Research Associate Center for Tropical Conservation
36. G. Carleton Ray, Ph.D. Research Professor of Environ. Sciences University of Virginia
37. Richard P. Reading, Ph.D. Director of Conservation Biology Denver Zoological Foundation
38. Terry L. Root, Ph.D. Senior Fellow
39. Gary W. Roemer, Ph.D. Assistant Professor Dept. of Fishery and Wildlife Sciences New Mexico State University
40. Paul Sneed, Ph.D. Environmental Studies Core Faculty Master of Arts Program Prescott College
41. Mark Shaffer, Ph.D. Senior VP for Programs Defenders of Wildlife
42. Michael Soulé, Ph.D. Professor Emeritus University of California, Santa Cruz
43. Martin E. Smith, M.Sc. Carnivore Biologist Defenders of Wildlife
44. Peter Stacey, Ph.D. Research Professor University of New Mexico
45. John Terborgh, Ph.D. James B. Duke Professor Nicholas School of the Environment & the Center for Tropical Conservation Duke University
46. Stephen C. Torbit,Ph.D. Senior Scientist National Wildlife Federation
47. John A. Vucetich, Ph.D. Research Assistant Professor School of Forestry, Michigan Technological University
48. Robert K. Wayne, Ph.D Professor, Editor, Animal Conservation
Contact(s):
Brad DeVries, Defenders of Wildlife, (202) 772-0237Jen Clanahan, Wildlands Project, (720) 565-8630
Mike Phillips, Turner Endangered Species Fund, (406) 556-8500
