WildEarth Guardians

A Force for Nature

An Essential Time for Lobos: Be a Voice!


Pack Pup by U.S. Fish and Wildlife Service

Please sign our citizens' comment letter to the U.S. Fish and Wildlife Service on the flawed draft plan by August 28th. Join us in telling the Service to put science and the law ahead of political pettiness. Then take a few moments to write your own comments here.

Sign on to our letter:

Public Comments Processing
Attn: FWS-R2-ES-2017-0036
U.S. Fish & Wildlife Service
5275 Leesburg Pike
Falls Church, VA 22041-3803

RE:    Citizens’ Letter Regarding Public Comments on the Draft Mexican Wolf Recovery Plan (Docket No. FWS-R2-ES-2017-0036)

Dear Recovery Coordinator Barrett,

          We, the undersigned individuals, hereby submit this joint letter of public comment in response to the U.S. Fish and Wildlife Service’s (“Service’s”) notice of availability and request for comments on the Draft Mexican Wolf Recovery Plan, First Revision (“Draft Plan”) and associated supporting documents. 82 Fed. Reg. 29918 (June 30, 2017).

          Mexican wolves are one our nation’s most critically imperiled species, with fewer than 113 remaining in the wild in the United States at last count. 82 Fed. Reg. at 29919. As the Service acknowledges in the Draft Plan, lobos are in the midst of a severe genetic crisis, while simultaneously facing devastatingly high rates of human-caused mortality. Draft Plan at 18. Added to these threats are the impacts of a demonstrated state-led regime of obstructionism trying desperately to thwart the species’ eventual recovery to their native Southwestern landscapes. While we appreciate the Service’s continuing efforts to recover the species in accordance with its duties under the Endangered Species Act (“ESA”), we are disappointed that the Draft Plan appears to erroneously place political pettiness ahead of science and the law.

          First, the Draft Plan’s blatant abdication of federal responsibility over recovery actions to states that are clearly hostile to coexisting with Mexican wolves within their borders is plainly unacceptable. The Draft Plan provides for the states of New Mexico and Arizona to “determine the timing, location and circumstances of releases of wolves into the wild” from the captive population. Draft Plan at 23. However, the Draft Plan fails to consider the reality of this renunciation of federal responsibility. For example, the state of New Mexico is currently suing the Service seeking to obstruct the release of any Mexican wolves from the captive population into the wilds within the state’s borders. See New Mexico Dep’t of Game and Fish v. U.S. Dep’t of the Interior, 854 F.3d 1236 (10th Cir. 2017) (vacating and reversing lower court’s grant of state’s preliminary injunction blocking wolf releases and remanding case for decision on the merits). The State of Arizona can hardly be trusted to carry out good faith recovery actions either, having filed an amicus brief in support of New Mexico’s obstructionist attempt in the preliminary phase of the litigation and authoring letters opposing wolf reintroduction. The Service’s abdication to states of this vital facet of the recovery program is demonstrably unworkable and must be revised in the final version of the plan.

          Second, the biological and geographic limits outlined in the Draft Plan are not rooted in the best available science, as required by the ESA. The Draft Plan calls for managing the Mexican wolf population in the United States to between only 320 and 380 wolves. Draft Plan at 28. The Service further provides that “all forms of management actions” (i.e., presumably including regulated hunting and lethal removals) will be employed “to ensure that population growth does not continue unchecked.” 82 Fed. Reg. 29920. This is utterly unacceptable. The Service must revise the final plan to account for the fact that viable habitat in the United States can support a carrying capacity of more than 1,000 wolves (Draft Plan at 9), and that the best available science has indicated that a minimum of three interconnected subpopulations of at least 200 animals each (and at least 750 animals total) is needed to establish a viable self-sustaining lobo population and achieve recovery goals. See Wayne and Hedrick (2010) and Carroll (2014). The Draft Plan’s reliance on establishing a minimum of only two unconnected subpopulations –– only one of which would be located in the United States (Draft Plan at 20) –– is not supported by the best available science and must be revised in the final plan.

          Additionally, the Draft Plan’s complete failure to consider recovery actions in suitable habitat in areas located north of the arbitrary boundary line depicted by Interstate-40, and areas of suitable habitat in the states of Texas, Utah, and Colorado is in error. The Draft Plan’s geographic limits fail to properly consider the historic range of the species. It is inappropriate that the Draft Plan’s supplemental Habitat Suitability Analysis (attached as Appendix B to the Draft Biological Report (Martinez-Meyer, et al. 2017)) is wholly based on an analysis limited to this arbitrary region, thereby prohibiting due consideration of already identified suitable habitat elsewhere from the start.

          Third, the Service’s reliance on the success of recovery efforts in Mexico to achieve the recovery mandates of the ESA is wholly inappropriate. The Service cannot rely on another country to carry out the duties of our federal officials to achieve the mandates of our federal environmental laws. This is especially egregious considering the veritable lack of necessary data, lack of necessary enforcement capacity, and lack of binding accountability on behalf of Mexico to ensure the recovery actions in the Draft Plan are duly carried out. Moreover, the Service fails to properly take into account the impacts a potential border wall will have on inhibiting natural disbursement and connectivity among wolf subpopulations on either side of the international border. The Service plainly ignores the fact that the highest-quality habitat for Mexican wolves is actually located in the United States; a fact that scientists readily admit. Draft Plan, Appendix B (Martinez-Meyer et al. 2017) at 66. The Service has the foremost duty to ensure Mexican wolves are appropriately recovered in the United States, and must revise the final plan accordingly.

           In sum, we are disappointed that the Draft Plan appears to be founded more upon the scientifically unsound political desires of anti-wolf states, than firmly rooted in science and the law as it should be. We appreciate the Service’s due consideration of our serious concerns with the Draft Plan and encourage the Service to revise the Draft Plan in accordance with our comments. We look forward to welcoming lobos home to their native habitat and restoring the balance of a healthy Southwestern landscape.



photo: U.S. Fish and Wildlife Service

















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