Wednesday, March 21, 2007

Comments on the proposed delisting of the gray wolf in the Northern Rocky Mountains

Through April 9, 2007 the US Fish and Wildlife Service is accepting public comments on their proposal to delist the gray wolf in the northern rocky mountains of the United States from the Federal list of Endangered and Threatened Species.  You can view the proposal at . They have concluded the public hearings, but are still accepting email and paper comments. You may email your feedback to .

As you might expect from reading my blog, I am not a supporter of the proposal.  Here is a copy of the comments that I submitted in opposition to the plan.

U.S. Fish and Wildlife Service,

I am writing this message to provide my feedback on the proposed de-listing from the Federal Endangered Species List, the Gray Wolf within the Northern Rocky Mountains.

Having read the proposal published in the Federal Register, I would like to express my opposition to the plan as highlighted. I will hereby explain my objections.
I, first and foremost, disagree with delisting the gray wolf before they have had the opportunity to reach and maintain their carrying capacity across the broad ecosystem. It is clear from the statistics mentioned in your proposal that wolves have reached the carrying capacity in the greater Yellowstone area and most likely in the Northwest Montana Recovery Area, illustrated by multiple years of steady or declining population levels. It is also clear that they have not reached the carry capacity within the state of Idaho, illustrated by their continued population growth.

Reaching and sustaining the carrying capacity of the environment is critical for a number of reasons.
1. Trophic Cascade. Research cited in your proposal, indicates that the presence of a top predator, such as the wolf, has a dramatic positive impact on a health of an ecosystem. If the population of wolves, as the keystone predator, is artificially restricted, our eco-systems will not receive the full health benefit and will continue to have problems effecting people, wildlife, and specifically other endangered and threatened species. The states, specifically Idaho and Wyoming, have made it very clear that they intend to manage the population to the lowest number possible. Neither state's plan includes an acknowledgement of the criticality of the wolf in the trophic cascade. This omission alone should be the basis for rejecting their plans.

2. Dispersion throughout the Northern Rocky Mountain (NRM) Distinct Population Segment (DPS). Much of your proposed distinct population segment does not include wolves today (Eastern Washington and Oregon, Northern Utah, etc). This is due to the fact that these areas are not the premier territory for wolves. It should not then be assumed that these are not acceptable territories. If we artificially restrict the population of wolves in the premier territory, then they will not disperse to other acceptable territories. The results is that those other acceptable territories will not receive the benefits of the trophic cascade and will not be returned to healthy ecosystems.

3. Dispersion beyond the NRM DPS into other endangered areas. Per the proposal, wolves will remain endangered beyond the NRM DPS. Once again, if wolves are artificially limited inside the NRM DPS, how can we expect them to disperse to these other endangered areas. We will be removing dispersal candidates and decreasing competition, in turn, decreasing the chance of wolf dispersion. Many of these areas do include prime habitat for wolves, for example, northern Nevada, Central Oregon, Colorado, South Dakota, etc. If we are patient, and give the population a chance, they will disperse to these areas. As you cite in the proposal, a number already have. We have to let the population rise and competition rise, for more dispersion to occur.

The bottom line is that we have learned, after re-introduction, that the role of the wolf in our ecosystems is far more important than previously expected. We have to be patient and let these benefits be achieved broadly within and outside of the NRM DPS. By de-listing wolves at this time, we will prevent these benefits from being widely achieved.

Thank you for your time and consideration.

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