Thursday, July 10, 2014

Mexican wolf reintroduction

Dear Sirs,

    Recently the U.S. Fish and Wildlife Service (USFWS) proposed one very good and many very bad changes to the rules governing the Mexican wolf reintroduction.

    The proposal is very important to the future of Mexican wolves in the wild, who numbered only 83 at the last official count.

    I ask you to influence USFWS to make the changes to help the lobos thrive are included and the changes that would push them closer to extinction are discarded.

    These are the reasons why :

1. I support direct releases of Mexican wolves throughout the Blue Range Wolf Recovery Area, the one critical change included in the proposed rule.

    This change has been recommended by experts for over 10 years and needs to be implemented immediately.  Currently, new releases are hindered because they can only happen in part of Arizona.

2. The proposed rule prevents wolves returning to northern New Mexico and southern Colorado or to the Grand Canyon region, including northern Arizona and southern Utah. The USFWS should eliminate boundaries to the wolves’ movement.

    Preventing movement into northern New Mexico and southern Colorado and the Grand Canyon region, including northern Arizona and southern Utah, contradicts the best available science, which confirms that those areas are essential for Mexican wolf recovery.

    Additional populations of Mexican wolves are necessary to their recovery and genetic health, as is the ability for wolves to move between populations.

    The proposal to capture and remove wolves who roam outside of the Mexican Wolf Experimental Population Area will result in more captures that can result in death or trauma to the wolves.
We can’t afford to lose rare Mexican wolves just because they crossed an arbitrary, scientifically unsupported boundary.  There should be no restrictions on the movements of Mexican wolves.

3. The USFWS should designate Mexican gray wolves as essential.

The current labeling all of the wild wolves as “nonessential” ignores science and the reality of 15 years of experience with reintroducing wolves.

    The USFWS claims that even if all of the 83 wolves in the wild are wiped out this is not “likely to appreciably reduce the likelihood” of recovery of Mexican wolves in the wild is unsupported by science or common sense.

    The 83 wolves in the wild have up to four generations of experience in establishing packs and raising pups and are over 22% of all of the Mexican wolves in the world.

    After multiple generations of captive breeding with few releases, scientists warn that there may be serious genetic problems making captive wolves less able to thrive in the wild.

    The fourth generation wild lobos are not expendable and are essential to recovering this unique subspecies of wolf.

4. The USFWS needs to quit stalling and complete a comprehensive recovery plan at the same time as or before changing the current rule.

    USFWS admits that their present, typewritten, 1982 recovery plan is not scientifically sound and does not meet current legal requirements – yet in its proposed rule USFWS continues to emphasize a woefully inadequate population of only 100 wolves in the wild. 
Instead of following the best available science on recovery, the Service is chasing after what a 31-year-old inadequate plan suggested as a good first step.

    Current proposals should contain no provisions that would preclude future recovery options.

5. The proposed rule must not include expanded provisions for “take” of these critically endangered wolves.

    Science-based program reviews have shown, and the USFWS has acknowledged, that the killing and permanent removal of wolves by agency managers to resolve “conflicts” has been a major cause of failing to meet the reintroduction objective.

    The proposed rule changes offer additional excuses for removing wolves. 
USFWS needs to tighten restrictions for “take” of Mexican wolves, not loosen them.



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