We applaud the efforts that the USFWS and its partners have put into recovering the Red Wolf (Canis rufus). However, we have serious concerns over the recently proposed changes to the 10(j) regulations of the Nonessential Experimental Population (NEP) of Red Wolves in North Carolina (hereon referred to as the “NEP regulations”). Listed below are our major worries:

Under the proposed NEP regulations, the North Carolina NEP Management Area (NCNEPMA) would be reduced from the five counties it currently encompasses to federal lands in two county. The newly defined NCNEPMA would be able to sustain a population of only 15 Red Wolves, which is less than the current population size of the species in the wild (USFWS 2018a). This extremely small population size is unsustainable and puts the species at higher risk of extinction in the wild, as smaller populations are at greater risk of going extinct due to inbreeding and stochasticity. In addition, a previous attempt by the USFWS to restrict the land area of Red Wolves is one of the factors that resulted in the failure of the reintroduction project in Great Smoky Mountains National Park (Hinton et al. 2013, Faust et al. 2016, USFWS 2018b). Instead of reducing the size of the NCNEPMA and decreasing the wild population of Red Wolves, the USFWS should either enlarge or maintain the current size of the NCNEPMA, work to increase the wild population of Red Wolves within the NCNEPMA, and reintroduce Red Wolves into other regions.

Under the proposed NEP regulations, landowners would be allowed to legally take Red Wolves outside of the revised NCNEPMA (USFWS 2018a). Yet gunshot is the largest source of mortality for Red Wolves and remains a major threat to the survival of the species in the wild. Over the past decade, the wild population of Red Wolves has dropped from approximately 150 to less than 45, and could go extinct in as soon as eight years. In addition to reducing the wild population size, the legalization of take creates the risks that landowners will kill genetically valuable Red Wolves and that hybridization between Red Wolves and Coyotes (Canis latrans) will increase (Hinton et al. 2013, Faust et al. 2016, USFWS 2018b). Instead of legalizing the take of Red Wolves, the USFWS should put more effort into preventing the illegal take of Red Wolves and should work with private landowners to increase their tolerance of Red Wolves. If Red Wolves must be removed from private lands, then removal should be non-lethal and the Red Wolves should be relocated (or brought under human care if relocation is unfeasible).

The purpose of the Endangered Species Act (ESA) is stated as “to provide a program for the conservation of… endangered species” (Congress 1973), with the ESA defining an Endangered species as “any species which is in danger of extinction throughout all or a significant portion of its range” (Congress 1973). The Red Wolf is listed as Endangered under the ESA (USFWS 2018). In addition, the Red Wolf is evaluated as Critically Endangered (CR) on the IUCN Red List of Threatened Species (Kelly, Beyer, and Phillips 2008), meaning that it faces “an extremely high risk of extinction in the wild” (IUCN 2012). As such the USFWS is obligated to protect and recover the species (Congress 1973). The proposed NEP regulations may be a violation of the ESA since they would provide inadequate conservation actions for the Red Wolf, and under a worst-case scenario, they could potentially result in the extinction of this Endangered species.

We ask that you please revise the NEP regulations so that they better reflect the science of what is necessary to recover the Red Wolf.

References:

Faust, L.J., J.S. Simonis, R. Harrison, W. Waddell, & S. Long. 2016. Red Wolf (Canis rufus) Population Viability Analysis – Report to U.S. Fish and Wildlife Service. Lincoln Park Zoo, Chicago.

Hinton, J.W., M.J. Chamberlain, & D.R. Rabon Jr. 2013. Red Wolf (Canis rufus) Recovery: a Review with Suggestions for Future Research. Animals 3(3): 722–744.

IUCN. 2012. IUCN Red List Categories and Criteria: Version 3.1. Second Edition. Gland, Switzerland and Cambridge, UK: IUCN. Iv + 32pp.

Kelly, B.T., A. Beyer, & M.K. Phillips, M.K. 2008. Canis rufus. The IUCN Red List of Threatened Species. Version 2014.2. <www.iucnredlist.org>

US Congress. 1973. Endangered Species Act. 16 U.S.C. <http://www.nmfs.noaa.gov/pr/pdfs/laws/esa.pdf>

USFWS. 2018a. Endangered and Threatened Wildlife and Plants; Proposed Replacement of the Regulations for the Nonessential Experimental Population of Red Wolves in Northeastern North Carolina. <https://www.federalregister.gov/documents/2018/06/28/2018-13906/endangered-and-threatened-wildlife-and-plants-proposed-replacement-of-the-regulations-for-the>

USFWS. 2018b. Red Wolf Species Status Assessment. <https://ecos.fws.gov/ServCat/DownloadFile/147196>