We are writing to you today to express our serious concerns about the legislation that has been introduced over the past few years to delist the Gray Wolf (Canis lupus) in either all or part of its listed range in the United States.

We acknowledge that the Gray Wolf has made a significant recovery in the Western Great Lakes and the Northern Rocky Mountains. However, it must be understood that there is much scientific debate on whether the species has recovered enough to be removed from the List of Endangered and Threatened Wildlife, and some scientists have expressed serious concerns over delisting at this time (ASM 2012; “Open Letter from Scientists” 2015).

The Endangered Species Act (ESA) demands that all decisions regarding protected species must be based “solely on the basis of the best scientific and commercial data” (Congress 1973). The wolf delisting legislation would make a permanent decision on a species whose recovery status is scientifically debatable. In fact, a group of 50 biologists wrote a letter in February 2015 urging Congress to oppose any legislation that would strip Gray Wolves of their ESA protections (“An Open Letter to Members of Congress” 2015). Since they does not represent the best available science, the wolf delisting legislation are a violation of the ESA.

While it can be argued that the wolf delisting legislation are securing the usage of the best available science by restoring decisions made by the United States Fish and Wildlife Service (USFWS), it must be mentioned that the agency has not always used the best science in regards to decisions about the Gray Wolf (Bergstrom et al. 2009; NCEAS 2014). In 2014 the Federal Court found that the USFWS violated the ESA when it delisted Gray Wolf populations in Wyoming (Wheeler 2014) and the Western Great Lakes Distinct Population Segment (Kearn 2014).

Congress already interfered with the protected status of the Gray Wolf when it stripped the Northern Rocky Mountain Distinct Population Segment of its ESA protections with a rider in the 2011 budget bill (Congress 2011). Instead of continuing to politically intervene with the protected status of the Gray Wolf, politicians should allow scientists (both governmental and non-governmental) to decide on whether the species is fully recovered and no longer in need of ESA protections.

Therefore, we ask that you please veto any anti-wolf legislation that makes its way through Congress. Thank you.

References:

American Society of Mammalogists (ASM). 2012. ASM position letter on Wyoming gray wolf delisting. <http://www.mammalsociety.org/uploads/committee_files/ASM%20USFWS%20wolf%20letter%20512.pdf>.

An open letter to members of Congress from scientists on federal wolf delisting. 2015. <http://blog.humanesociety.org/wp-content/uploads/2015/02/WolfScientistCongress_SignOnLetter-FINAL.pdf>.

Bergstrom, Bradley J., Sacha Vignieri, Steven R. Sheffield, Wes Sechrest, and Anne A. Carlson. 2009. The northern rocky mountain gray wolf Is not yet recovered. BioScience 59(11): 991 - 999.

Kearn, Rebekah. 2014. Big win for Great Lakes' gray wolves." Courthouse News Service. <http://www.courthousenews.com/2014/12/23/big-win-for-great-lakes-gray-wolves.htm>.

National Center for Ecological Analysis and Synthesis (NCEAS). 2014. "Review of proposed rule regarding status of the wolf under the Endangered Species Act. <http://www.fws.gov/home/wolfrecovery/pdf/Final_Review_of_Proposed_rule_regarding_wolves2014.pdf>.

Open letter from scientists and scholars on wolf recovery in the Great Lakes region and beyond. 2015. <http://blog.hslf.org/files/wolf_conservation_letter_70_scientists__scholars_30nov2015.pdf>.

US Congress. 1973. "Endangered Species Act of 1973." <http://www.epw.senate.gov/esa73.pdf>.

US Congress. 2011. H.R.1473 - Department of Defense and Full-Year Continuing Appropriations Act, 2011. 112th Congress (2011-2012).

Wheeler, Ted. 2014. "Wyoming loses bid to manage its gray wolves." Courthouse News Service. <http://www.courthousenews.com/2014/09/25/71827.htm>.