Be A Voice for Wolves! Public Comments needed on the revised management rules for Mexican gray wolves!

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Now is the time to speak out in support of Mexican gray wolf recovery during the upcoming public comment period for the draft Supplemental Environmental Impact Statement and proposed 10(j) Management Rule!

Background:
At the end of 2020, only 186 Mexican gray wolves roamed in Arizona and New Mexico, and only about 35-40 could be found in Mexico, making these wolves among the rarest native species found in the Southwest.

The U.S. Fish and Wildlife Service (USFWS) is revising its 2015 Mexican gray wolf 10(j) Management Rule, which a Federal court found does not rely on the best available science and violates the Endangered Species Act by failing to conserve the endangered Mexican gray wolf.

October 29, 2021 to 11:59 p.m. Eastern Time January 27, 2022 marks a 90-day public comment period, which is your opportunity to demand that the agency follow the court order and base the revised management rule on independent academic science rather than political pressure.

A science-based management rule would:

  • designate Mexican gray wolves as “essential,” giving them full protection under the law
  • lead to a distribution and population size that achieves ecological effectiveness, allowing Mexican gray wolves to play their natural role as top predators
  • ameliorate the crisis of declining genetic diversity and include measurable genetic standards for assuring progress toward recovery benchmarks based on the best available science
  • measure -- not just model -- the genetic diversity and inbreeding of the wild population
  • require the release of well-bonded wolf families into the wild, taking into consideration the highly social nature of wolves
  • limit intentional human-caused mortality
  • include firm requirements to prevent conflicts with livestock and support non-lethal resolution of conflicts
  • Hold the USFWS accountable for actual results — it would not just be a wish-list of goals

Science tells us we need at least 750-1000 Mexican gray wolves in several populations (three in the United States and one in Mexico).

We have an opportunity to tell USFWS to follow the science and eliminate the existing population cap (325 wolves) and remove or revise the northern boundary, currently marked at Interstate-40.

The majority of people in Arizona and New Mexico support conserving endangered Mexican gray wolves.

How You Can Help
Send a written comment to U.S. Fish and Wildlife Service by 11:59 pm EST on January 27, 2022.

Written comments can be submitted during the public comment period either online through Regulations.gov (Docket FWS-R2-ES-2021-0103​) or by hard copy to: ​

Public Comments Processing​
Attn: FWS-R2-ES-2021-0103​
U.S. Fish and Wildlife Service​
MS: PRB/3W​
5275 Leesburg Pike​
Falls Church, VA 22041-3803

You can find the full proposed rule here and the draft Supplemental Environmental Impact Statement here.

Please attend the final virtual public meeting on January 11, 2022:

You can personalize these talking points:

  • Mexican gray wolves are essential. Losing our existing population of wolves in Arizona and New Mexico would jeopardize recovery. The zoos and captive breeding facilities in the Mexican Wolf Species Survival Plan could no longer replace the nearly 200 wolves in the wild.
  • We need several populations of Mexican gray wolves, including one in the Grand Canyon ecoregion and one in the Southern Rockies, in addition to the existing populations in the Mexican Wolf Experimental Population Area and in Mexico.
  • Some of the world’s best wolf scientists have recommended a population of 750-1000 Mexican gray wolves. Managing for an average of 320 Mexican gray wolves in Arizona and New Mexico is inadequate for ensuring their long term recovery.
  • The Mexican gray wolf population should not be managed based on a population average. Rather, the population should be allowed to reach a point of ecological effectiveness, allowing wolves to play their natural role as top predators.
  • We can predict that wildlife species will shift their ranges in response to climate change and Mexican wolves will likely move further northward into the Grand Canyon region if allowed to do so. The U.S. Fish and Wildlife Service must adequately address the potential changes in wolf habitat, prey species, water and vegetation distribution, and wolf movements due to the impacts of climate change in the revised Mexican Wolf 10(j) Management Rule.
  • There is highly suitable wolf habitat north of Interstate 40. U.S. Fish and Wildlife Service should be pursuing recovery in an expanded area. Although the U.S. Fish and Wildlife Service acknowledges that territory north of I-40 will likely be required for future recovery and recognized the importance of natural dispersal and expanding the species’ range, it nevertheless imposes a hard limit on dispersal north of I-40.
  • You strongly oppose any capture efforts to move Mexican gray wolves that travel north of Interstate 40. Wolves should be allowed to continue on their journeys without risking potential harm during recapture and translocation, and the agencies should focus on keeping an endangered wolf safe wherever they roam.
  • Lack of habitat connectivity is one of the greatest threats to biodiversity worldwide. The proposed rule still artificially limits wolves’ ability to seek new habitats and expand throughout their suitable range and does not do enough to ensure connectivity between populations in the U.S. and Mexico.
  • The U.S. Fish and Wildlife Service must develop more concrete ways to assess and improve the genetics of the wild population.
  • The U.S. Fish and Wildlife Service must include an effective migration rate to protect against genetic deterioration.
  • Cross-fostering is one tool for introducing gene diversity, but unless cross-fostered wolves survive to breeding age and reproduce, they are not contributing their genes to the wild population and should not count toward achieving a genetic objective.
  • Wolves should count toward a genetic objective only after they have reproduced in the wild.
  • The release of well-bonded wolf packs with their dependent pups from the Mexican Wolf Species Survival Plan should also be included as a strategy for achieving genetic objectives. U.S. Fish and Wildlife Service should have plans in place to take this recovery action in the short-term to address the growing genetic crisis, especially if genetic metrics are not being reached. Waiting years for cross-fostering to have enough of an effect may be too late for these rare wolves.
  • Cross-fostering takes place in areas where packs are already concentrated and established. Bonded wolf family group releases could allow wolves to recover in more places.
  • While it is a positive step that the U.S. Fish and Wildlife Service has agreed to limit certain kinds of take of Mexican gray wolves, the Service must do more to limit human-caused mortality, including illegal killing.
  • U.S. Fish and Wildlife Service should also include firm requirements to prevent conflicts with livestock and support non-lethal resolution of conflicts.
  • There are a variety of conflict avoidance techniques and management policies that the U.S. Fish and Wildlife Service and U.S. Forest Service should require on public lands, including but not limited to retiring grazing allotments with a history of repeated wolf-livestock conflict, removing or rendering inedible carcasses to prevent scavenging and future livestock predation, and increasing livestock monitoring through range riders that can move livestock out of areas where they are vulnerable to allow wolves to use the habitat they need to recover.
  • U.S. Fish and Wildlife Service should be increasing their capacity to conduct community outreach to educate people about endangered Mexican gray wolves, support communities living with wolves through non-lethal conflict avoidance projects, and fund law enforcement activities to ensure wild wolves are protected from poaching.
  • U.S. Fish and Wildlife Service should stop providing telemetry and GPS receivers and codes for Mexican gray wolves’ radio collars to anyone except government biologists and scientific investigators because the present practice contributes to the exceedingly high number of illegal killings of wolves.
  • U.S. Fish and Wildlife Service should do more to meaningfully include indigenous voices in Mexican gray wolf conservation. There are diverse perspectives on wolves amongst tribes in and around the Mexican Wolf Experimental Population Area, these perspectives should be uplifted as part of an inclusive and transparent rule change.
  • A federal court order prohibits aligning the 10(j) Rule with the Mexican Wolf Recovery Plan, yet the U.S. Fish and Wildlife Service continues to attempt to align the two documents.

It’s important to add a paragraph or more of unique information that you have personalized to ensure your comment is counted. We also recommend including references and citations that are relevant to the Mexican Wolf 10(j) Management Rule, but do not let that prevent you from submitting a comment if you do not have them. We have numerous references that support wolf recovery in the Grand Canyon region listed here.

Not sure how to personalize a comment? Attend a free comment-writing workshop hosted by Lobos of the Southwest on January 24th at 5:00 pm MST. Click here to register!

And check out this video on how to make your comment count!

As always, be respectful in your comment and stay focused on the substance of your request to improve the 10(j) Rule to better conserve Mexican gray wolves.