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This is an update to my June 11th Wolves: "Mission Accomplished" diary. It was too early to post the Government Comment link on this issue. Thanks to Patriot Daily News ClearingHouse for providing it in last Saturday's Green Diary Rescue.

>>>>>>>You can contribute a COMMENT here until September 11, 2013.<<<<<<<


Removing Wolves from the Endangered Species Act


On June 7, 2013 in a Friday news dump
The Fish and Wildlife Service unveiled a proposal to eliminate the remaining restrictions across the country, saying wolves are flourishing again. The only populations to have protection, under the proposal, would be Mexican wolves in southern Arizona and New Mexico and a small experimental population in North Carolina.

The announcement by Daniel M. Ashe, the director of the Fish and Wildlife Service, marked the imminent end of 50 years of controversial efforts to bring back a predator that once roamed the continent but had been all but exterminated in the United States by the mid-20th century.In my last diary i purposely used the phrase Mission Accomplished in the title. This is an update to that diary with information for comments to the government about their delisting of the Gray Wolf.

Mission Accomplished
The image of the government declaring "Mission Accomplished" is etched in Americans’ minds, and not in a good way. Just as former President George W. Bush was wrong when he made that announcement about the Iraq war, the feds might well be wrong in declaring the gray wolf no longer in need of protection in the West.
Advocates for delisting the wolf say management decisions should be made at the state level, not by federal agencies, now that the reintroduction process is complete. The problem with state-level decisions is that in the minds of many officials, "management" of the wolf is synonymous with "eradicating" the animal. For example, Wyoming’s proposed management plan essentially allowed anyone to shoot any wolf on sight for any reason. That’s not management.

The Science on Wolves

Sylvia Fallon, a senior scientist and director of the wildlife conservation program with the Natural Resources Defense Council, said the move would effectively slam the door on wolf recovery nationwide.

“With continued protection, there’s great potential for them to return to their native range across the West and Northeast,” she said. “By stripping those needed protections, this proposal would leave wolves out in the cold. We urge the agency to take a hard look at the science and reconsider.”

Scientists Call on Obama Administration to Keep Gray Wolves Protected Under Endangered Species Act
Biologists Say Proposal to Remove Protections Fails to Follow Best Science

“The science simply doesn’t support removal of protections for wolves,” said Dr. Brad Bergstrom with the American Society of Mammalogists. “Wolves are altogether absent or barely beginning to recover in large swathes of the country that still contain excellent habitat.”

Signatories to the letter include several scientists who conducted research that’s relied on by the government in its draft proposed rule. Those scientists are now criticizing the agency for misrepresenting their work, stating: “Collectively, we represent many of the scientists responsible for the research referenced in the draft rule,” and “We do not believe that the rule reflects the conclusions of our work or the best available science concerning the recovery of wolves.”

Proposed ending of federal gray wolf protection: Another case of setting science aside?
Exerpt from a letter from 16 scientists sent to Secretary of the Interior Sally Jewell and Daniel M. Ashe, the director of the Fish and Wildlife Service.

The letter raises four issues bearing on the science-policy relationship including:

1) Removal of the gray wolf from the List of Threatened and Endangered Wildlife

The gray wolf has barely begun to recover or is absent from significant portions of its former range where substantial suitable habitat remains. The Service’s draft rule fails to consider science identifying extensive suitable habitat in the Pacific Northwest, California, the southern Rocky Mountains and the Northeast. It also fails to consider the importance of these areas to the long-term survival and recovery of wolves, or the importance of wolves to the ecosystems of these regions.

2) Maintain endangered status for the Mexican wolf by listing it as a subspecies

Although the taxonomic distinctness of the Mexican wolf is well-supported, and we thus support subspecific listing as appropriate, the draft rule fails to delineate the geographic extent of the area in which wolves would receive protection, specifying only that Mexican wolves would beprotected “where found”. Genetic analysis of historic Mexican wolves showed that the range of the Mexican wolf likely extended beyond the historic range initially inferred from limited record data. At the same time, the Service has inexplicably delayed completion of the recovery plan for the Mexican wolf, the draft of which had concluded that habitat to the north of the current recovery area may be essential for recovery of the subspecies. The lack of specificity in the rule, coupled with past actions by the Service, encourages continued efforts by stakeholders to block recovery actions essential to recover a subspecies that is among the most endangered mammals in North America.

The letter concludes:

The extirpation of wolves and large carnivores from large portions of the landscape is a global phenomenon with broad ecological consequences. There is a growing body of scientific literature demonstrating that top predators play critical roles in maintaining a diversity of other wildlife species and as such the composition and function of ecosystems. Research in Yellowstone National Park, for example, found that reintroduction of wolves caused changes in elk numbers and behavior which then facilitated recovery of streamside vegetation, benefitting beavers, fish and songbirds. In this and other ways, wolves shape North American landscapes.

Given the importance of wolves and the fact that they have only just begun to recover in some regions and not at all in others, we hope you will reconsider the Service’s proposal to remove protections across most of the United States.

Westren politicians and livestock ranchers do not find this message congenial. For them, it is too pro-wolf, too in favor of increasing wolf populations and geographic ranges.

During the comment period the Interior Department can expect to hear from those who support the views expressed by the scientists, and by environmental and conservation groups. Our friends at the Center for Biological Diversity issued this statement on June 7 (excerpt)




Background


Basic Facts
Population
There are an estimated 7,000 to 11,200 wolves in Alaska and more than 5,000 in the lower 48 states. Around the world there are an estimated 200,000 in 57 countries, compared to up to 2 million in earlier times.

Range
Wolves were once common throughout all of North America but were killed in most areas of the United States by the mid 1930s. Today their range has been reduced to Canada and the following portions of the United States: Alaska, Idaho, Michigan, Minnesota, Montana, Wisconsin and Wyoming. Mexican wolves are found in New Mexico and Arizona.

In April 2011 Congress attached a rider to a must-pass budget bill that stripped Endangered Species Act protections from wolves in all of Montana and Idaho, the eastern third of Washington and Oregon, and a small portion of northern Utah — an unprecedented action that, for the first time in the history of the Act, removed a species from the endangered list by political fiat instead of science. Wolves were delisted in Wyoming, as well, in September 2012. The Fish and Wildlife Service also removed protections from wolves in the Great Lakes region. Montana, Idaho, Wyoming, Minnesota and Wisconsin have begun public wolf hunting and/or trapping, and the U.S. Department of Agriculture, cooperating with state agencies, is expanding its program of trapping, radio-collaring and releasing, then aerial gunning the pack-mates of these collared wolves — a program that, while wolves were protected by the Act, had been limited to those that preyed on livestock.
Videos in excellent comment by divineorder

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You can contribute a COMMENT here until September 11, 2013.

Originally posted to DK GreenRoots on Mon Jun 17, 2013 at 07:00 AM PDT.

Also republished by Public Lands, Wildlife Endangered and Threatened, and DFH writers group.

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Comment Preferences

  •  Tipped/recc'd/tweeted (7+ / 0-)

    Thanks for keeping this issue in the forefront of our consciousness!

  •  thank you for the diary (3+ / 0-)

    Growth for the sake of growth is the ideology of the cancer cell. --Edward Abbey

    by greenbastard on Mon Jun 17, 2013 at 07:45:38 AM PDT

  •  Does the US govt do evil just for laughs? (4+ / 0-)

    because on too many days it sure seems like it.

  •  When you comment on the proposed rule (6+ / 0-)

    It is helpful to mention that 1) delisting requires that the threats to the species are no longer be present or threaten the species (and the actions of hunters shows that is not true, 2) that regulatory mechanisms be adequate for protection (which state game laws are utterly inadequate for, as we have seen, and 3) that the findings rely on the "best scientific and commercial data available" which the scientists above suggest is not key.  See the Endangered Species Act, 16 USC s 1533.

    Here's how the process works:  The comments raise issues to the agency.  If the agency does not comply with the law after having had an issue raised, then people can sue the agency for failing to comply with the requirements of the law.  If issues aren't raised in comments, then often you can't sue the agency for not doing them.

    Also, the sheer number of comments can exert serious political pressure to withdraw the proposed rule as well.

    Touch all that arises with a spirit of compassion

    by Mindful Nature on Mon Jun 17, 2013 at 07:58:18 AM PDT

    •  Thank you for that important information MN! (3+ / 0-)

      To thine ownself be true

      by Agathena on Mon Jun 17, 2013 at 08:05:00 AM PDT

      [ Parent ]

    •  also best to have your own comment (4+ / 0-)
      Recommended by:
      Agathena, CanyonWren, ZenTrainer, ColoTim

      because comments that appear to be form letters are tossed out essentially.

      eco and wildlife groups will have form comments that you can tweak by adding your own words with edit.

      "It is in the shelter of each other that people live." Irish Proverb

      by Patriot Daily News Clearinghouse on Mon Jun 17, 2013 at 08:15:59 AM PDT

      [ Parent ]

      •  Form letters are dealt in bulk (3+ / 0-)

        I've done responses to comments, and basically the form letters and ones that don't raise substantive issues (that is, comments that address the facts of the proposed rule, rather than expressing opinions) are usually dealt with in a single response to cover all letters.  Thus, the form letters are more like signatures on a petition showing opposition.  THis can be useful for putting political pressure to show how unpopular the move is, which can be very important.  HOwever, they don't play into the legal process in the same way.

        The agency is required to respond to all substantive issues, so beyond tweaking the letter, it is key to put in substantive issues.  If you have the time to do research, especially to find references they haven't included, that is always the best.

        Touch all that arises with a spirit of compassion

        by Mindful Nature on Mon Jun 17, 2013 at 09:00:16 AM PDT

        [ Parent ]

        •  yes, i know, as attorney post comments for (4+ / 0-)

          clients.

          form letters are part of the total quantity count, and that does apply political pressure. and made a difference in prior XL public comments.

          but in terms of substantive issues, the form letters are often not even considered anything more than a vote on the issue.

          "It is in the shelter of each other that people live." Irish Proverb

          by Patriot Daily News Clearinghouse on Mon Jun 17, 2013 at 09:21:56 AM PDT

          [ Parent ]

          •  is politics what we should be looking for in a (1+ / 0-)
            Recommended by:
            andalusi

            scientific decision? Shouldn't decisions be made on the science of the matter? What if they get 50K comments against delisting yet their best science tells them it is far past time? Should they go ahead and delist because it's the right thing scientifically or should they bow to pressure to make a political listing? What is the purpose of the public comment period, is it a vote?

            I find it interesting that in all these diaries I can find no link to the actual proposal itself. It's only one page and written to to be easily read. Is knowledge that dangerous?

            How big is your personal carbon footprint?

            by ban nock on Tue Jun 18, 2013 at 03:42:30 AM PDT

            [ Parent ]

        •  that's why I kind of chuckle at comments and (0+ / 0-)

          diaries. If anyone had bothered to read the proposed delisting they'd realize why I haven't seen one substantive reason yet on why delisting shouldn't occur, including that letter by 16 that was penned before there was any delisting proposal to respond to.

          Opinions drive donations, but not much else.

          How big is your personal carbon footprint?

          by ban nock on Tue Jun 18, 2013 at 03:31:17 AM PDT

          [ Parent ]

          •  The proposed delisting was linked to indirectly (0+ / 0-)

            You are right I didn't link directly to the FWS proposal but I did link indirectly. Even so, the proposal is not very informative. it's "wolves have recovered according to our definition of recovery therefore we are going to delist them."

            In my first Mission Accomplished diary:
            - I linked to the Salt Lake Tribune which included a link to the FWS proposal.

            - I linked to Natural Resources Defense Council Blog which had a link to the FWS proposal.

            In the action diary here:
            -Dan Ashe's statements are in this link
            http://www.nytimes.com/...

            Furthermore, in the Action diary there's a statement on the proposal in the Comment link at the top of this diary.

            Summary:
            We, the U.S. Fish and Wildlife Service (Service) evaluated the classification status of gray wolves (Canis lupus) currently listed in the contiguous United States and Mexico under the Endangered Species Act of 1973, as amended (Act). Based on our evaluation, we propose to remove the gray wolf from the List of Endangered and Threatened Wildlife but to maintain endangered status for the Mexican wolf by listing it as a subspecies (Canis lupus baileyi). We propose these actions because the best available scientific and commercial information indicates that the currently listed entity is not a valid species under the Act and that the Mexican wolf (C. l. baileyi) is an endangered subspecies.
            In addition, we recognize recent taxonomic information indicating that the gray wolf subspecies, Canis lupus lycaon, which occurs in southeastern Canada and historically occurred in the northeastern United States and portions of the upper Midwest (eastern and western Great Lakes regions) United States, should be recognized as a separate species, Canis lycaon. This proposed rule also constitutes the completion of a status review for gray wolves in the Pacific Northwest initiated on May 5, 2011.
            Finally, this proposed rule replaces our May 5, 2011, proposed action to remove protections for C. lupus in all or portions of 29 eastern states (76 FR 26086).
            I'm pretty sure most people read that before they wrote a comment.

            To thine ownself be true

            by Agathena on Tue Jun 18, 2013 at 12:23:07 PM PDT

            [ Parent ]

            •  You're getting close (0+ / 0-)

              It begins at the words "in addition"

              Earth Island Institute is the first group to get it.
              http://www.earthisland.org/...
              accompanied by the usual rhetoric.

              All of these sources are not so great. Newspapers just read the delisting, added some opinion about shooting wolves and noble predator, then some juicy quotes by the CBD or NRDC. They are cranking out copy, not informing. They didn't read the parts with scientific names cause it's boring. Seemingly no one went to the Q an A released at the same time.

              You call it propaganda, I'd more call it a carefully planned argument that they are prepared to back up in court based on science.

              There was a "leak" a couple few weeks ago in the LA Times I think. Then the group of 16 letter a few hours before Interior said they were indefinitely postponing delisting. And now delisting based on an entirely different set of reasons. Kabuki.

              “Conservation… is a positive exercise of skill and insight, not merely a negative exercise of abstinence and caution…” Aldo Leopold

              by ban nock on Tue Jun 18, 2013 at 02:22:33 PM PDT

              [ Parent ]

              •  I posted the Summary that goes with the (0+ / 0-)

                Comments.

                This is the FWS news release
                http://www.fws.gov/...

                And like any propaganda, they begin with a diversion on the protection of the Mexican wolf. They had to do that because there are people in CA that will sue their asses if they don't. But I have read that they cannot protect only one small number of wolves because there are not enough of them for biodiversity. It won't work. Gray wolves will migrate to protected areas.

                I don't see why we need their announcement in a diary to protect wolves. Short version, they want to delist wolves in 48 states.

                If I wanted to use emotion over reason on this issue I would have posted the torture of wolves that I have run up against in my research. Like the trapped wolf in Idaho, where the FS employee called his friends to come and shoot at it while it was in the trap, not shoot to kill, shoot to torture. But I believe in reason over emotion so I don't use that kind of animal cruelty to sway peoples' opinions.

                I am not unreasonable about hunting as a profession by people who respect animals especially when it comes to the exploding deer population. Maybe if we didn't kill so many of the deer predators, we wouldn't have that exploding deer population.

                I'm afraid that the rush to slaughter wolves is all about protecting livestock for ranchers and game for hunters. FWS is bound to protect the interests of the group that supports them financially. The service should be paid from general tax to keep it objective.

                You are welcome to contribute any diary on the protection of animals in the wild to our group. The group profile precludes any videos or images  of animals being killed or who are trapped, suffering or dead, and photos of hunters with trophy animals.

                I respect your knowledge of animals and your concern for endangered and threatened wildlife.

                To thine ownself be true

                by Agathena on Tue Jun 18, 2013 at 03:34:43 PM PDT

                [ Parent ]

                •  actually 42 states (0+ / 0-)

                  I dont' think you or any of your fellow commenters realize they are already delisted in the 6 states they occur in the lower 48 plus E Oregon and E Washington.

                  FWS is funded from the general fund. They receive no support financially from hunters or ranchers other than the taxes all citizens pay.

                  I thought the diary was about delisting. There are currently no wolves in the places to be delisted. Maybe you mean it's a diary about protecting future wolves?

                  I believe the accuracy and being factual are very important even if people disagree.

                  I'll probably try to post a basic reference for anyone to use who wishes to understand the reasons or background for delisting. I realize that most already have an opinion, but I think it would be helpful if everyone at least knew what states and what wolves are being considered.

                  “Conservation… is a positive exercise of skill and insight, not merely a negative exercise of abstinence and caution…” Aldo Leopold

                  by ban nock on Tue Jun 18, 2013 at 04:54:48 PM PDT

                  [ Parent ]

    •  Borrowed a bit, gracias. eom (1+ / 0-)
      Recommended by:
      Agathena

      "You are not even aware of what is possible. The extent of their capabilities is horrifying."Edward Snowden -6.62, -6.92

      by CanyonWren on Mon Jun 17, 2013 at 01:08:52 PM PDT

      [ Parent ]

  •  Wildlife, Threatened and Endangered (2+ / 0-)

    I started a new group if anyone is interested in joining, you are more than welcome.

    http://www.dailykos.com/...

    To thine ownself be true

    by Agathena on Mon Jun 17, 2013 at 08:04:11 AM PDT

  •  Gracias Agathena--one suggestion: please put link (2+ / 0-)
    Recommended by:
    Agathena, ZenTrainer

    to comment toward the top--I nearly missed it at its present location.

    "You are not even aware of what is possible. The extent of their capabilities is horrifying."Edward Snowden -6.62, -6.92

    by CanyonWren on Mon Jun 17, 2013 at 08:17:34 AM PDT

  •  Here is my letter: feel free to borrow and tweak (4+ / 0-)
    Hello,

    I am writing about the delisting of western wolves from the Endangered Species Act, and the proposed rule to halt protection altogether.  Under the ESA, in order to delist an animal from protection, these things must take place1) threats to the species are no longer present, 2) regulatory mechanisms be adequate for protection (state game laws are utterly inadequate), and 3) and decision is based on the "best scientific and commercial data available" which is being challenged by scientists as I write.  See the Endangered Species Act, 16 USC s 1533.

    This is no longer an issue about the best available science catching up with monied interests, since science has continually shown us that wolves play a crucial role in their habitat due to their keystone species presence. This is now, it seems, just a power play in order to appease ranching and hunting operations, and not a real effort to help restore the country's proper ecological balance by saving threatened and endangered animals, according to the Endangered Species Act.

    Since this is the case, the government should stop hiding behind false claims of scientifically-based game management, and instead call a spade a spade: the government's main purpose in delisting wolves and ending federal protection is a measure proposed in order to give ranching and hunting interests what they want, which translates to more money.

    Thanks again, Agathena!

    "You are not even aware of what is possible. The extent of their capabilities is horrifying."Edward Snowden -6.62, -6.92

    by CanyonWren on Mon Jun 17, 2013 at 08:36:26 AM PDT

  •  ...thanks Agathena... (1+ / 0-)
    Recommended by:
    Agathena

    Ignorance is bliss only for the ignorant. The rest of us must suffer the consequences.

    by paradise50 on Mon Jun 17, 2013 at 09:48:54 AM PDT

  •  Concord, NC (1+ / 0-)
    Recommended by:
    Agathena

    I'm 99% sure I saw a gray wolf on the street I work on a few years ago. it was about 7:30 am when the wolf ran across the road in front of me.
    about 6 weeks ago I saw one on the side of the road that had been hit by a car. that animal was about a 1/2 mile from where I saw the one run across the road.
    There is a reservoir here also. Lots of wooded land too.

    •  That's one reason not to delist wolves, they are (0+ / 0-)

      getting killed by cars all the time, especially around Yellowstone National Park. They are losing habitat and they have to contend with climate change.

      To thine ownself be true

      by Agathena on Mon Jun 17, 2013 at 11:27:09 AM PDT

      [ Parent ]

  •  Wolf protection (1+ / 0-)
    Recommended by:
    Agathena

    Thank you for this article and I sent my rather lengthy comment on the site you provided. I live in Wyoming and have fought for wolves as much as I can. It is a disgrace that we cater to the ranchers who graze their stinking cattle on our public lands and the hunters who do not want to compete with the predators who might kill "their elk" just to survive. I wonder how many of these "hunters" do not survive if they do not kill an elk? Probably a lot fewer than the wolves and other predators that rely on these game animals for survival. Not everyone in these states that have wolves wants to see them destroyed as they are being now.

    •  Great to hear from someone in Wyoming (0+ / 0-)

      the state that has no rules when it comes to wolves, open season, shoot on sight, no bag limit, no license required. They are asking for a slaughter.

      "Hunters" are having more success with traps so trapping is outpacing shooting now. Wolves can outwit a hunter with a gun, but they fall into the traps. In most states that have delisted the wolves, there are rules about checking the traps every 72 hours. That's a long time for a wolf (or whatever other animal gets caught) to suffer.

      Thanks for sending your letter!

      To thine ownself be true

      by Agathena on Mon Jun 17, 2013 at 03:04:44 PM PDT

      [ Parent ]

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