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"Comments to USFWS on Rules for Wild Population of Mexican Wolves"
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On behalf of the Rio Grande and Grand Canyon Chapters of the Sierra Club, please accept these comments on the draft revisions to the 2015 ESA Section 10(j) rule for the wild population of Mexican Wolves. [...] Our combined chapters have 26,000 members in Arizona, New Mexico and West Texas and have long advocated for and have a significant interest in recovery of the Mexican wolf.
The U.S. Fish and Wildlife Service (USFWS) is under court order to redraft the 2015 revisions to the Endangered Species Act (ESA)section 10(j) rule for the wild population of Mexican gray wolves to remedy deficiencies that the court identified. The court found that that the 2015 rule failed to further the conservation of the Mexican gray wolf. The USFWS now has an opportunity to correct these flaws and at last take actions that live up to its responsibility to fully recover this iconic species.
Essentiality
Under section 10(j), the test for determining "essentiality" is whether the loss of the population would appreciably reduce the likelihood of the survival of the species in the wild. The court found the USFWS determination that the wild population is not essential to the continued existence of Mexican wolves in the wild to be arbitrary and capricious. [... 6 more paragraphs...]
Providing for the genetic health of the wild wolf population
Coming from so few founding wolves, the last remaining in the wild and two pairs from captivity, the lobo was rescued from the brink of extinction but with a limited genome. Scientists have warned of this looming crisis for many years. Repeatedly scientists and conservationists have urged the USFWS to release more wolves from captivity into the wild while the population was small to quickly allow new genes to be passed on. [... 3 more paragraphs...]
The arbitrary northern boundary of Interstate-40 is not science based and does not further Mexican wolf recovery.
[...] Limiting Mexican wolves to areas south of I-40 arbitrarily constrains them, limits and impairs the ability to reach the minimum desired population of 750, and prevents the establishment of sub-populations. Keeping wolves out of these areas where they once roamed and where the biotic community is incomplete without them is also contrary to the spirit of the Endangered Species Act. [... 5 more paragraphs...]
Improperly limiting the population
The new draft changes the population objective for the Mexican Wolf Experimental Population Area (MWEPA) from the previous hard cap of 325 to a “population average greater than or equal to 320 wolves in Arizona and New Mexico.” The court found that the population cap of 325 wolves does not further the conservation of the species and must be eliminated or increased. [... 2 more paragraphs...]
Killing and removing wolves from the wild
[...] The provision to disallow killing wolves for killing elk should be made permanent. We further assert that healthy wolves should not be killed for any reason except to protect human health and safety. [... 4 more paragraphs...]
In summary,
the following changes should be made to the preferred alternative not only to satisfy the legal requirements of the court remand, but also to ensure a self-sustaining and restored Mexican Wolf population:
• Change the 10(j) classification to Essential from Non-essential.
• Improve the rate at which more genetic diversity is introduced to the wild by releasing adult wolf pairs with pups along with cross fostering and ensure desired genetic goals are being met by measuring genetic diversity, not the breeding age of genetically valuable wolves.
• Remove the upper limit on the number of wolves in the wild, whether as a cap or average. Let wolf numbers grow to have an ecologically meaningful impact on their habitat.
• Remove all boundaries for wolf dispersal, translocation and release.
In addition, the endless cycle of litigation not only harms the credibility of the US Fish and Wildlife Service; it harms the potential for Mexican wolf success. The law is clear. The court order is clear. We urge the agency to take both to heart.
Thank you for considering our comments.