Write Comments to help Lobos by May 16, 2022!

The U.S. Fish and Wildlife Service (USFWS) is revising its 2017 Mexican Wolf Recovery Plan. A Federal court found that the Recovery Plan violates the Endangered Species Act by failing to address the human-caused mortality that continues to threaten critically endangered Mexican gray wolves.

April 14, 2022 to 11:59 p.m. Eastern Time May 16, 2022 marks a 30-day public comment period, which is your opportunity to demand that USFWS follow the court order and ensure that Mexican gray wolves can safely thrive and recover in the wild places where they belong.

How You Can Help
Submit a Written Comment

• Comments can be submitted electronically here.
• Comments may also be mailed to: Public Comments Processing, Attn: Docket No. FWS-R2-ES-2022-0018; U.S. Fish and Wildlife Service Headquarters, MS: PRB/3W; 5275 Leesburg Pike; Falls Church, VA 22041-3803.
• Review the Recovery Plan revision and the summary of proposed recovery actions.
• Review and personalize the talking points below. Using your own words to speak up for lobos is critical for making your comment count! It’s important to add a paragraph or more of unique information that you have personalized to ensure your comment is counted.
• Your comment should also include references and citations that are relevant to the Mexican Wolf Recovery Plan and the proposed recovery actions addressing human-caused mortality.
• As always, be respectful in your comment and stay focused on the substance of your request to improve the Recovery Plan to better conserve Mexican gray wolves.
• Don’t delay! The deadline to comment is May 16, 2022 at 11:59 Eastern Time.
• Please help spread the word and encourage others to speak out!

Talking Points – Please Personalize Using Your Own Words!

Background

• At the end of 2021, only 196 Mexican gray wolves roamed in Arizona and New Mexico, and only about 40 could be found in Mexico, making these wolves among the rarest native species found in the Southwest.
• Mexican gray wolves are essential and play a critical role in our environment. Their lives should be valued and protected accordingly.
• The majority of people in Arizona and New Mexico support conserving endangered Mexican gray wolves. People want to see these rare native wolves protected and thriving for generations to come!
• 70% of Mexican wolf deaths are human-caused and illegal killing remains a major threat to the future of these rare wolves. Human-caused mortality must be addressed to ensure recovery for these endangered wolves.

Stronger Legal Protections Reduce Illegal Killing

• Policies that loosen legal protections lead to substantial increases in illegal killing. USFWS should adopt and enforce the strictest Endangered Species Act protections for Mexican gray wolves to reduce the risk of illegal killing.
• USFWS should not only increase law enforcement presence but must also follow through with increased prosecution of poachers. Both investigation and enforcement must increase to send a message that illegal killing will not be tolerated.
• The McKittrick Policy continues to limit the number of successful prosecutions of illegal killing of Mexican gray wolves. This policy must be overturned to ensure that Mexican wolves are protected from claims of mistaken identity that prevent justice from being served.” I thought it was a coyote” should never be an acceptable defense for killing an endangered wolf.
• USFWS should increase law enforcement during hunting seasons, when wolves are at greater risk of illegal killing (both intentional and accidental).
• USFWS 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.

Funding and Staff Capacity Must Increase to Reduce Mortality and Improve Public Outreach

• USFWS and cooperating agencies 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.
• Current outreach activities such as the Mexican Wolf Recovery Program website, public wolf location map, public meetings or hearings, media relations, and emails are important components of an outreach program but are not sufficient for raising awareness about the importance of Mexican gray wolves and their protected status. Outreach efforts must expand beyond these minimal steps.
• USFWS and cooperating agencies have previously committed to expand community outreach in areas like the Tonto National Forest and Sitgreaves National Forest. To date, little outreach has occurred in these areas. Agencies claim that this is due to a lack of capacity and a need to focus on areas where wolves are concentrated. Capacity must be increased to ensure outreach can effectively expand to areas where wolves are dispersing, or the proposed recovery action to conduct more outreach is meaningless.
• USFWS should consider the role of volunteers in helping with community outreach, building a robust volunteer program to support staff in conducting outreach in more places where wolves are returning.
• USFWS calls for reducing wolf killings through public outreach and education, protective fencing, and overpasses — but without adding a dime to make it happen. USFWS must budget to ensure the success of these programs.
• USFWS claims it will increase law enforcement presence and investigation in over half of Arizona and New Mexico with funding that would cover salaries for less than two law enforcement officers! Far more law enforcement capacity must be created to ensure endangered lobos are protected wherever they may roam.
• USFWS and cooperating agencies should conduct more outreach to hunters and outfitters to reduce the risk of someone mistakenly killing a Mexican gray wolf. Mistaken identity should never be an excuse for illegally killing an endangered wolf.
• USFWS and cooperating agencies 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 road map to recover the subspecies. Tribal consultation should include meaningful ways to reduce human-caused mortality and honor the relationships indigenous communities have with wolves.
• USFWS and cooperating agencies often use outreach messaging that implies that wolves do not belong north of I-40, potentially leading to increased intolerance and attitudes that wolves dispersing outside of the Mexican Wolf Experimental Population Area (MWEPA) should be killed. Messaging must change to stop the hostile environment being created for dispersing wolves.
• We strongly urge consideration for how outreach messaging may be inadvertently contributing to intolerance for wolves.
• Cooperating agencies like the National Park Service, U.S. Forest Service, and Bureau of Land Management all have important roles in protecting endangered species on federal public lands. These cooperating agencies should embrace this responsibility and increase their community outreach in parallel with USFWS.
• Cooperating agencies like Arizona Game and Fish Department and New Mexico Department of Game and Fish have important roles in protecting endangered species throughout their states. These cooperating agencies should expand their community outreach in support of Mexican gray wolves returning to their states, celebrating the restoration of a native species and clearly communicating the intrinsic value and protected status of Mexican gray wolves. These agencies should be emphasizing that wolves are welcome and that illegal killing will not be tolerated.
  

Non-Lethal Techniques are a Necessity for Protecting Wolves and Reducing Conflict

• USFWS should 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.
• Policies that allow for lethal control of wolves fail to prevent livestock conflict and incentivize illegal killing by devaluing the lives of wolves. Proactive non-lethal strategies are the most effective ways to reduce conflict.
  

Releasing Wolves in More Places and Proactively Supporting Natural Dispersal Will Reduce Mortality and Decrease Conflict

• If USFWS released well-bonded wolf families in more places, this would allow for both expansion of the wolf population into additional suitable habitat as well as reduction of livestock conflict. Releases in more places, including suitable habitat in northern Arizona and the Southern Rockies, would allow wolves to live in places with less livestock grazing, reducing livestock conflict, improving tolerance, and reducing human-caused mortality both in the form of illegal killing and lethal control.
• 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. USFWS 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, ensuring that dispersing wolves are protected wherever they travel. Community outreach, law enforcement, and measures to reduce vehicle mortality should expand to broader areas to address climate impacts on dispersal of Mexican wolves.
• 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 FWS acknowledges that territory north of I-40 will likely be required for future recovery and recognizes the importance of natural dispersal and expanding the species’ range, it nevertheless imposes a hard limit on dispersal north of I-40.
• Capture efforts to move Mexican gray wolves that travel north of Interstate 40 put Mexican gray wolves at risk of potential harm. Wolves should be allowed to continue on their journeys, and the agencies should focus on keeping endangered wolves safe wherever they roam. This requires both avoiding the risk of human-caused mortality due to capture-related complications and reducing the risk of illegal killing and vehicle-caused mortalities for dispersing wolves.
• Lack of habitat connectivity is one of the greatest threats to biodiversity worldwide. USFWS is still artificially limiting wolves’ ability to seek new habitats and expand throughout their historic range and is not doing enough to ensure connectivity between populations in the U.S. and Mexico. The Recovery Plan fails to consider the border wall and its impact on connectivity and recovery. Wolves need to be able to travel between connected habitats, and they need safe corridors where they will be protected from illegal killing and vehicle mortalities.
• USFWS must do more to facilitate Mexican wolf movement across existing and new roads, working with other agencies and community partners to install safe wildlife crossings that reduce vehicle collisions. USFWS should also expand signage warning drivers of the presence of wolves in and around the MWEPA, including areas where wolves are dispersing.
• 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. The establishment of a larger metapopulation will safeguard against the impacts of human-caused mortality.
• 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. A smaller population will always remain vulnerable to the impacts of human-caused mortality.
• 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. Lethal control should not be used to artificially limit the Mexican wolf population.
  

Improved Gene Diversity and Reduced Wolf Mortality Go Hand in Hand in Achieving Recovery

• USFWS must develop more concrete ways to assess and improve the genetics of the wild population and to address the impacts of human-caused mortality on gene diversity, including agency management actions that impact pack stability and pup survival.
• 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. Human-caused mortality also puts cross-fostered pups at risk, and more must be done to protect wolf families and keep them together and safe in the wild.
• The release of well-bonded wolf packs with their dependent pups from the Mexican Wolf Species Survival Plan (SSP) should also be included as a strategy for achieving gene diversity. 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 and the ongoing impacts of human-caused mortality. Waiting years for cross-fostering to have enough of an effect may be too late for these rare wolves.
• The Recovery Plan should provide for compensatory releases when wolves are killed, including releases of well-bonded wolf families from the SSP.
  USFWS could discourage illegal killings by releasing wolves and wolf families to replace those illegally killed.
• 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. Robust legal protections are needed to reduce the risk of illegal killing for all wolf families, wherever they may roam.
  

Measuring Mortality and Reducing Error in Assumptions about Human-Caused Losses

• USFWS assumes that the Mexican wolf population will grow or remain stable if the mean adult mortality rate is less than 25 percent. However, some of the world’s best wolf scientists indicate that an estimated annual rate of human-caused losses must average less than 20 percent over an 8-year period as measured by a statistically reliable monitoring effort. There is a significant discrepancy between the modeling assumptions being used by USFWS and the recommendations of independent scientists. USFWS should use the more conservative modeling assumptions to ensure that high human-caused mortality does not jeopardize recovery efforts.
• USFWS has been slow to publish mortality data, including causes of death that are under investigation as potential illegal killings. USFWS has a responsibility to not only measure mortality but investigate and publish the results in a timely manner as part of a transparent process of tracking mortality and working to reduce human-caused mortality. Up-to-date mortality data should be readily available for all members of the public who have an interest in the recovery and stewardship of Mexican gray wolves.