SCB Policy Blog

The Fish and Wildlife Service has proposed removing gray wolves in Wyoming from the list of threatened species and returning them to state management. The state of Wyoming has proposed a management plan that divides the state into three zones: 1) a Wolf Trophy Game Management Area (WTGMA) where wolf hunting is seasonally permitted, 2) the remainder of the state where a designation of the species as a ‘predator’ allows year-round unrestricted hunting and other forms of lethal control, and 3) seasonal expansion of the WTGMA by 80 km southward for 4.5 months during peak wolf dispersal season. While in some respects the Wyoming wolf population is healthy and may merit delisting, SCB-North America Section is concerned that a problematic precedent for connectivity is being proposed in this management plan. The plan envisions that artificial translocation (e.g., movement of wolves in trucks) is adequate for recovery in place of allowing natural dispersal between wolf populations.

SCB-North America Section commented:
The proposed rule’s reliance on artificial translocation to achieve population connectivity has broad significance for recovery of wolves and other species because it attempts to substitute a “museum-piece” interpretation of recovery of species to highly managed conditions resembling outdoor zoos in place of the Endangered Species Act’s clear mandate to restore self-sustaining wild populations of species and the ecosystems on which such species depend (ESA, Section 2(b) Purposes).

Unless there is some clear physical barrier to natural genetic exchange (such as a large urban area), the goal of a recovery plan should be natural connectivity rather than artificial translocation, if it is to be consistent with the requirement for use of best available scientific data in listing and delisting decisions (ESA Section 4(b)(1)(A)). If the Service opts to depend on artificial translocation for recovery of the wolf, perhaps the most vagile terrestrial mammal, it will establish an impermissibly minimal standard for connectivity criteria in recovery plans. If the proposed rule is implemented without modification, it will represent a dangerous fork in the road for interpretation of the nation’s premier species protection statute.

Achieving natural population connectivity for wolves in the NRM region does not require expensive habitat restoration measures, but only that humans do not indiscriminately kill dispersing wolves. The proposed rule does not ensure this. We request that the rule be revised to include

1) An objective and measurable criterion for natural dispersal between (from and to) the Wyoming population and other NRM wolf populations;
2) Post-delisting management actions that will ensure that this natural dispersal criterion is met. These include spatial and temporal expansion of proposed ‘trophy game management’ areas (i.e., expansion of ‘trophy game management’ areas to include a greater proportion of potential dispersal zones, coupled with expansion of the period of seasonal ‘trophy game management’ in areas with such seasonal restrictions);
3) Specific commitments in state law and/or binding management plans to ensure monitoring of effective dispersal sufficient to detect whether the above criterion is being met by the current management protocol; and
4) A commitment to relisting wolf populations within a specified period of time if the above natural dispersal criterion is no longer met.

The full comments are here.