Friends of Animals, a 200,000-member non-profit international animal advocacy organization, opposes delisting by the U.S. Fish and Wildlife Service of wolves in the Eastern Distinct Population Segment. Delisting would rely on unwarranted assumptions about the current status of EDPS wolves and would result in implementation of state management plans for Minnesota, Wisconsin, and Michigan that we feel are seriously deficient from biological and ethical standpoints. Following are our comments. Please include them in the record.

There are three fundamental problems.

First, delisting assumes there is no question as to whether the EDPS wolves are any longer threatened or endangered or might become threatened or endangered once the states assume management authority. But this depends on the criteria used for determining “threatened” and “endangered.” USF&WS and Minnesota, Wisconsin, and Michigan (the latter three in their proposed management plans) rely almost entirely on numerical status, i.e., the number of wolves present. At least one prominent scientific publication (Haber 1996) that neither USF&WS nor the states have considered in their proposals concludes that numerical status is a grossly inadequate criterion even when it is possible to accurately estimate wolf numbers. Haber (1996) argues that various qualitative features in the biology of highly social species such as the wolf are of much greater importance as measures of well being than are simple numerical status, reproductive output, and related indices. This is especially true when there is substantial killing for control, sport, or other purposes, all of which would likely become routine, eventually, under state management authority. We share the concerns discussed in detail in Haber (1996) that such killing could seriously erode the most basic underpinnings of wolf biology long before the damage was reflected by the number of wolves present or in their reproductive more…success. Heavy reliance on numerical status becomes all the more questionable when one considers that the estimates themselves are highly subjective and often amount to guesswork. Neither the proposal to delist nor the state management plans adequately point out the inherent difficulties of obtaining even ballpark wolf estimates in the large expanses of forest that prevail in the EDPS.

Second, the state management plans would rely heavily on zonal and statewide wolf population goals determined in only vaguely described ways that have little to do with what the available prey populations could support, even in the remotest areas of each state where there is little or no potential for conflict with farmers, other landowners, or urban centers. In Wisconsin, varying degrees of government and landowner control (including extensive killing) would be used to try to keep wolf numbers at about 250-350, below the potential natural population of 300-500. The Minnesota and Michigan (Upper Peninsula) plans emphasize maintaining “minimum populations” — 1,400 and 200, respectively. However it is likely that these minimums would effectively translate into goals. They are far enough below the most recent estimates (Minnesota) or what biologists think the habitat can support (Michigan) — i.e., 2,450 and 800, respectively so that inevitably the differences would be viewed as “surpluses” for public sport hunting and trapping, to be controlled, or both. In all three cases killing would be allowed for livestock depredation and other control purposes, probably at higher levels than the pre-delisting Minnesota kill that we felt was already excessive enough to challenge in court (Friends of Animals v. USDI and USDA, 1995). In all three cases widespread public hunting and trapping could be allowed in five years or less, subject only to each state’s decision-making process. The Michigan plan is a close second to the Wisconsin plan in its candor about suppressing wolf numbers below natural levels, acknowledging the possibility of future “wolf population stabilization and control” based on how residents define the “cultural carrying capacity.”

This emphasis on suppression and stabilization, explicit or not in the three plans, provides an example of the “command and control” approach to management that a large and growing body of science is increasingly questioning from several standpoints for many kinds of systems (e.g., Holling and Meffe 1996; Gunderson and Holling 2002). Friends of Animals certainly questions it in this case. Consistent with the newer scientific thinking, we feel that wolf numbers should instead be set by available prey populations and allowed to fluctuate naturally around this baseline in each state. more…Gray Wolf Delist

Third, the high sentience of wolves by itself justifies far more protection than the state management plans would provide, yet there is next to nothing in the process to date about this or any other ethical concern. Perhaps the authors of the delisting proposal and state plans do not feel that ethical and biological considerations are appropriately mixed in discussions such as this. If so, they should read the opposite view in Haber (1996) and in various abstracts as well as the conference summary from the 2003 World Wolf Congress held in Banff, Alberta, taking note that the former appears in a prominent scientific journal and the latter are from the largest scientific wolf conference ever convened. Friends of Animals feels that for these and other reasons it would not be appropriate to delist EDPS wolves at this time. We ask that all EDPS wolves remain under federal management authority with the maximum possible levels of protection in place.

Sincerely,

Priscilla Feral
President, Friends of Animals
feral@friendsofanimals.org

Gray Wolf Delist — Eastern Distinct Population Segment
c/o Content Analysis Team
P.O. Box 221150
Salt Lake City, Utah 84122-1150

Footnotes