In June of 2013, the U.S. Fish and Wildlife Service (FWS) proposed removing federal Endangered Species Act (ESA) protection for the gray wolf (Canis lupus, Linnaeus) throughout most of the lower 48 U.S. states, with the exception of the Mexican wolf subspecies (C.l. baileyi)  (78 Fed. Reg. 35,664).  In an article accepted for publication in the journal Conservation Letters, my coauthors and I detail flaws in the rationale provided by the FWS, and explain how this proposal could have far-reaching, deleterious consequences for the listing and recovery of threatened and endangered species.

The Proposed Rule

The FWS asserts that their obligation to conserve gray wolves has been met because (a) the population of gray wolves residing in the northern Rocky Mountains (NRM) is no longer threatened or endangered, (b) the population of gray wolves residing in the western Great Lakes (WGL) is no longer threatened or endangered, and (c) the remaining portions of gray wolves’ historic range are not significant portions of their range.  They defend this last point by asserting that the term “range” refers only to “the range in which a species currently exists” (78 Fed. Reg. 35,673), and anyway, these unoccupied portions of wolves’ historic range are “unsuitable” habitat because of human intolerance for wolves. The FWS also asserts that wolves in the northeastern U.S. belong to a different species (Canis lycaon); thus, gray wolves (Canis lupus) should not be listed in this region.

We describe four flaws with the FWS’s Proposed Rule, which are briefly discussed, below.

1.      The Proposed Rule depends upon an overly-narrow interpretation of endangerment.

The ESA defines an “endangered species” as one that is “in danger of extinction throughout all or a significant portion of its range” (SPR-phrase).  The proposed rule depends upon an extremely narrow interpretation of this SPR-phrase, asserting that unoccupied portions of wolves’ historic range are not significant portions because the term “range” refers to “the range in which a species currently exists” (78 Fed. Reg. 35,673).  The article points out that this interpretation of the term “range” is inconsistent with the FWS’s implementation of the ESA, inconsistent with prevailing precedent, and has been roundly criticized in the scholarly literature.  Indeed, interpreting “range” to mean “current range” is functionally equivalent to striking the SPR-phrase from the ESA entirely and narrowing the definition of endangerment to “in danger of extinction” (see Carroll et al. 2010; Defenders of Wildlife v. Norton, 258 F.3d 1136, 1141 (9th Cir. 2001)).  The FWS’s interpretation of the SPR-phrase would also create an incentive for people who dislike a species being considered for listing to kill or otherwise remove those animals from portions of their current range where they are unwanted.  If the species cannot be found in an area, then that area is not part of the species’ current range, and by the FWS’s logic, the species cannot be endangered in an area that is not part of a species’ current range.

2.      The assumption that delisting wolves will promote tolerance for wolves is not supported in the scientific literature.

The FWS argues that “the primary determinant of the long-term conservation of gray wolves will likely be human attitudes toward this predator.”  Following the ESA’s mandate, the FWS then attempts to analyze human intolerance as a potential threat to wolf populations. Throughout their analysis, the FWS conflates human intolerance for wolves with attitudes toward wolves.  The problem with equating these two is that wolves don’t need people to like them (i.e., to have positive attitudes toward wolves) in order to survive—dislike of wolves does not necessarily constitute a threat to wolf populations; rather, wolf populations are threatened by high rates of human-caused mortality perpetrated by a few people who both dislike wolves and have the skill and ability to find and dispatch them.  In the past, the threat posed by high rates of human-caused mortality was largely mitigated by protecting wolves under the ESA, which prohibited “take” (i.e., killing) of wolves under most circumstances.   The primary result of removing wolves from ESA protections will be the cessation of these mitigation measures—allowing for legal harvest of wolves in addition to ongoing illegal killing.

The FWS not only recognizes that delisting wolves will result increased human mortality in the form of legalized hunting and trapping, they argue that such legal harvest is critical for recovery because “keep[ing wolf] populations within the limits of human tolerance” requires that humans be allowed to hunt and trap wolves (78 Fed. Reg. 35,685).  But recall that we’re not talking about areas like the NRMs or WGLs where wolf populations are robust; rather, the proposed rule covers places like Utah, Colorado, Oregon and Washington, where wolf populations are either non-existent, or a handful of wolves exist in pockets.  The argument that the FWS makes—that hunting and trapping of wolves is necessary to promote human tolerance, even in areas with few to no wolves—is exactly opposite of the argument they made when they were attempting to recover wolves in the WGLs and NRMs.  Here wolves were protected from harvest (via the ESA’s prohibition on take), which resulted in population growth, range expansion, and ultimately, recovery of these populations.  In other words, human intolerance was successfully mitigated in both cases by the prohibition on killing wolves, a prohibition that the Service now argues is unnecessary.

Perhaps more importantly, the FWS cites not a single scientific study—including studies they commissioned—in its assessment of the threat posed by intolerance for wolves.  A brief literature review by the authors found exactly 100 peer-reviewed articles on this topic, including studies that found no support for the claim that rates of poaching changed with higher quotas of legal harvest (Andren et al. 2006; Treves 2009), as well as a recent longitudinal analysis that found attitudes toward wolves were more negative during a period of legal lethal control than when wolves were listed under the ESA (Treves et al. 2013).  In fact, preliminary results from a study commissioned by FWS to address this very question failed to support the idea that lethal control or public wolf hunting and trapping had raised tolerance for wolves (C. Browne-Nuῆez et al. unpublished data; Hogberg et al. unpublished data).  The ESA mandates that listing decisions be made based upon the best available science.  In this case, none of the available peer-reviewed literature appears in the FWS’s review, and the existing evidence fails to support the Service’s claims.

3.      The assertion that unoccupied historic range is unsuitable because of human intolerance contradicts the best available science.

Prior studies of habitat suitability have noted that suitable habitat for wolves exists in several western states (e.g., Colorado, Utah, California) that do not currently have wolf populations (Carroll et al. 2006; Switalski et al. 2002).   Interestingly, the FWS dismisses habitat in these states as “unsuitable” based upon the level of human tolerance:

“The areas that wolves currently occupy correspond to ‘suitable’ wolf habitat…wolves persist where ungulate populations are adequate to support them and conflict with humans and their livestock is low…[t]he areas considered ‘unsuitable’… are not occupied by wolves due to human and livestock presence and the associated lack of tolerance of wolves…” (78 Fed. Reg. 35,680).

They further conclude that those parts of wolves’ historic range that are currently unoccupied by wolves “have not repopulated due to continued lack of human tolerance to their presence” (78 Fed. Reg. 35,685).  Interestingly, rather than view this as a threat to wolf recovery, the FWS summarily dismisses these areas as “unsuitable”—meaning that wolf populations cannot persist in these areas because of a lack of human tolerance).  Again, the FWS cites no empirical evidence for such a claim, and again, the empirical evidence that does exist simply does not support this assertion.  Existing research indicates that (a) people who live in regions currently occupied by wolves tend to have more negative attitudes than those who live outside of wolf-occupied regions (Karlsson and Sjöström 2007; Treves and Martin 2011; Williams et al. 2002), and (b) several western states that currently do not have wolf populations have human populations that are generally supportive of wolf recovery (see, for examples: Bright and Manfredo 1996; Bruskotter et al. 2007; Meadow et al. 2005).  Thus, we conclude that a review of the best available science contradicts the conclusion that the areas where wolves do not currently exist are unsuitable because of human intolerance.

4.      The taxonomic status of wolves in the northeastern United States is uncertain.

The FWS’s proposal to delist wolves also claims the wolves that historically existed in the northeastern part of the US are a separate taxonomic entity—Canis lycaon (as opposed to Canis lupus).  We avoid making any judgment on the taxonomic status of wolves; rather, we note that the taxonomic status of wolves in this area is controversial among scientists.  Of course, uncertainty is not a reason to avoid action.  However, such uncertainty does call for an application of the precautionary principle.  In the case of listing status determinations, application of the precautionary principle would demand that when an activity potentially threatens the health or viability of a species or population, precautionary measures should be taken to reduce or avoid the potential threat—even when there is uncertainty about the extent of the threat (see: Kriebel et al. 2001).  In this case, a modest application calls for developing criteria for recovery that are robust to the uncertainty—that is, criteria that are sensible whether or not C. lycaon is taxonomically distinct from C. lupus.


The rationale provided by the FWS for removing federal protections for wolves undermines the purpose of the ESA—which is to mitigate threats to endangered species.  These rationale are flawed because (a) they rely upon an interpretation of the SPR-phrase that is inconsistent with the plain reading of the law, congressional intent, prior federal court decisions, and a variety of relevant scholarship (see Carroll et al. 2010; Bruskotter and Enzler 2009; Enzler and Bruskotter 2009; Vucetich et al. 2006); (b) the assumption that delisting of wolves and subsequent human harvest will improve tolerance for wolves is not supported in the scientific literature; and (c) the FWS’s assertion that portions of wolves’ historic range are made unsuitable by human intolerance for wolves directly contradicts the best available scientific evidence.  In sum:

“Concluding that wolves cannot be recovered because some people dislike wolves is unsupported by evidence; and concluding that wolves cannot be recovered because of human-caused mortality is to merely describe the potential threat to wolves. Congress enacted the ESA not to describe such threats, but to mitigate them. While human intolerance (in the form of legal and illegal killing) continues to threaten wolves in some geographic areas, the greater threat to wolf recovery is the lack of will on the part of the federal government to stay the course and endure political pressure from state governments and special interest groups who want wolf populations minimized or eliminated.”

Addendum: Speaking for myself…

I suspect that some will view this critique as advocating for a particular policy—i.e., the continued listing of wolves.  While the absence of wolves and continued presence of threats across much of the lower 48 suggests that listing may indeed be warranted, I believe that recovery could be achieved through a variety of routes.  Our article should not be read as an attempt to compel any particular policy outcome per se, but rather, as (a) an assessment of the FWS’s current interpretation of the ESA and what it requires for recovery, and (b) a review of the FWS’s analysis of the threat posed by human intolerance in light of the best available science.

Bruskotter, J., Vucetich, J., Enzler, S. Treves, A. and M.P. Nelson. (forthcoming). Removing protections for wolves and the future of the U.S. Endangered Species Act (1973).  Conservation Letters, DOI: 1111/conl.12081.

About The Author

Jeremy Bruskotter

Dr. Jeremy Bruskotter is an associate professor in the School of Environment and Natural Resources at the Ohio State University where his research interests are centered around the human dimensions” of wildlife conservation and management. Jeremy is passionate about wildlife–at one time or another, he has called himself hunter, angler, and wildlife photographer. Most of all, Jeremy is concerned with bringing the tools and techniques of the social sciences to bear on pressing issues in wildlife management.

64 Responses to Problems with the U.S. Fish and Wildlife Service’s Proposal to Remove Federal Protections for Gray Wolves

  1. Ida Lupine says:

    I suspect that some will view this critique as advocating for a particular policy—i.e., the continued listing of wolves.

    Absolutely not – it is a very fair and rational view. Thank you!

  2. Immer Treue says:

    “The assumption that delisting wolves will promote tolerance for wolves is not supported in the scientific literature.”

    A recent conversation with MN DNR wolf specialist supports this statement. On average, 10% of MN wolves are illegally killed each year. I firmly believe that the ethical MN hunter, who wants that one wolf, is not the problem. He/she is probably oblivious to most of the pro-wolf anti-wolf dialogue. The problems exists with the individual who shoots, just to kill, because the intolerance is conditioned into them. Nothing one can do about them other than hopefully catch them in the act, which is now, at least during the hunting season, next to impossible. that intolerance is not going to go away.

    • Mark L says:

      So wouldn’t ‘not mixing’ hunting seasons for wolves and deer be a positive step in the elimination of poaching?

      • Immer Treue says:


        In MN deer archery, rifle, and muzzleloading, with breaks extends from mid September to mid December. When would you suggest a wolf season? Even prior to wolf seasons in MN, 10% of wolves were killed illegally.

        • Mark L says:

          Archery and muzzleloading, would seems obvious to me. Neither seems to pattern well with a ‘typical wolf poacher’ (with a rifle?). I’d be curious how many wolves were taken with a bow or crossbow or muzzleloader as a percentage of whole population hunted.

          • Immer Treue says:

            Interesting. Won’t be in Archery/September October however as wolf coats still not quite prime.

            Also, won’t get many rifle hunters during muzzle loader season, as tree stand hunting due to weather would be curtailed. What you would get is trapping out the wazzoo.

            • Melody Scamman says:

              Immer Treue, my thoughts exactly. Trappers have no concience or ability to control what gets trapped… like the neighbor’s dog! And just because one can legally ‘take’ a wolf there are serious ethical concerns on many levels. Lobophobia and bloodlust are wiping out critically endangered Red and Mexican wolves, hundreds of miles from any legal wolf hunt! Human Psychology needs to be a part of any delisting, especially Abnormal Psychology.

  3. rork says:

    The parts of Maine I’ve visited seem very suitable – essentially without people – though prey densities might be lower than in MI, WI, MN. Will folks there shoot grey on sight, but not eastern? (Sorry to not use scientific names, but I want to avoid quibbling about what are right names.) Seems like some want to find a way to stop their return, and so select findings to make it so getting a return is very difficult.
    The news from Maine and other states strikes me as crazy talk sometimes, and I mean from biologists:
    I appreciate further education about that.

    Thanks so much for the article and paper.

    • Melody Scamman says:

      I live in Maine. It is prime wolf habitat in the western parts of the state that are wilderness. There are at least three wolf sanctuaries in Maine. I am not one, I just rescue, do not put wolves/wolfdogs on display. But I can say, you are correct that it is prime habitat. The same problem as other states have is here, too, where trophy hunting people get appointed to run governing boards and have no concept of animals as fellow beings sharing a beautiful place. Although hunting is a 20 million dollar industry in Maine and Gov. LePage is pro industry, I believe the lack of roads in the North Woods would make it a safer place for wolves. We do have more wolves here in the wild plus in sanctuary than in Yellowstone! But some are crossed with Malamutes. They and their ancestors were used as wheel dogs on sled teams before snowmobiles came into use. Our pure wolves come down the rivers following deer and moose from Canada. Others are brought here as pets. The Malamute/Mackenzie crosses are all over Maine. I really don’t think anyone should be overly concerned with pure local wolf genes because of the pet trade. Many pet wolfdogs got loose and it will probably be really hard if not impossible to find pure genes here?
      One thought on releasing wolves in Maine- perhaps the Penobscot Nation would agree to protect wolves on the rez in Alder Stream? Non- Native people are not allowed to hunt there, last I knew. It is patrolled on what few roads there are. And mostly uninhabited. It is full of moose there. Much damage has been done to the ecology of the North Woods from logging. Wolves would be a Godsend! Much education needs to be done in communities so they understand why wolves are important to the environment. Properly educated, the logging industry should want wolves, they keep the saplings from being eaten by moose and deer.
      Anyone who wants to legally reintroduce wolves to Maine should contact me. If enough people want to do this, educate politicians to the benefits of wolves, eco- tourism in a state that depends on tourist dollars, healthy trees in a state that has many logging jobs, and best of all, the wolves will love it here, it may save them?
      Actually, there is a large sanctuary with only one guy to do all the work, just over the NH border near North Conway, but in Maine. Beautiful place! They really need volunteers. I think there are about 65 wolves there. I won’t promote any one as I do not know the rules here on that but it is easy enough to find all three Wolf Sanctuaries in a web search. Thank you for making note of the habitat. Defender’s had a campaign to restore the wolf to the Northeast and Center for Biological Diversity has mapped Western Maine as prime Wolf Habitat. We can hope for a bolt of enlightenment to strike the politicians!

      • Ida Lupine says:

        Oh, if only!

      • Ida Lupine says:

        Ever since the first reintroduction, I’ve had it as a wish that we’d restore them back to remote places in Maine and/or Vermont too.

        • Melody Scamman says:

          Hi Ida, my dream too! We have all they need here to be free and wild wolves. Not as much meat on the hoof as Yellowstone but not as crowded for someplace that should be packed with tourists but the roads … well ya know I have to say it… ‘Ya can’t get there from here’. This is very real. Gotta wonder if FWS ever found a living wolf here or even looked outside to check? The dog catchers are the ones to ask, a few know how to tell a wolf from a malamute from a coyote. Or just check the classified ads, although selling wolves is illegal in Maine, it happens. If it didn’t, I wouldn’t have to rescue them. Mine are spayed and have some malamute in them. My husband calls them malamutts.
          Luckily, Maine has no crazy people breeding pitbulls to wolves like Florida has. Someone showed up in the Augusta area with one of those creatures last year but she was spayed. Someone, also in that area, had what appeared to be a very high content wolfdog or full wolf but she got loose, someone called the game wardens, well you know that didn’t come to a good end. The really stupid part is that first they took her into the shelter and tried to determine if she could be placed ‘but she was too shy’ so they stuck a needle in her leg instead of calling one of the sanctuaries. I do not ever assume shelter volunteers even know enough to water their dogs but it won’t stop them from making life and death decisions.
          Well, no matter what, a human will cause a wolf death far more often than a wolf dies on it’s own because it messed up. Still, with education and a ban on killing wolves, Maine could be a great place for them. Sure beats the heck out of Wyoming!

      • ernie meyer says:

        in response to melody…politicians need to be educated just like children; once they learn a concept they put their own spin on it just to woo the voters.

        • Melody Scamman says:

          Ernie, that is a fact, especially when their poll numbers make a flushing sound.

    • john Glowa says:

      The article cited is quite a few years old. The so-called deer biologist who worked for the state is also a trapper. He left state employment some years ago and now helps a Maine “sportsman’s” organization and speaks out against wolves on their behalf.

      • Melody Scamman says:

        John, good point! Angus King is a Senator now. It has been many years since he was the Governor of Maine. He’s not going to stick his political neck out for wolves, I think he is trying to leave a legacy of trying to fix issues of non-cooperation/communication between parties in DC? I have higher hopes for younger, rising State level reps to be sensitive toward ESA issues, including wolves.
        The sportsmen in Maine have their usual reasons for not wanting wolves but I have one nobody will ever study. ( warning, put down your coffee)
        There is an extreme shortage of dentists in rural areas of Maine! Deer hunters and the population in general, is ‘over the hill’ and can’t chew tough meat, can’t afford store-bought meat or to go to a dentist even if they have any teeth left or they could even find a dentist. I am not being disrespectful, this is a fact if anyone wants to check. Wolves keep deer herds on the move. Great for the saplings, not so good for hunters with bad teeth or no teeth. Just making connections most people would never think of as having an affect on predator populations or willingness to cooperate with the ESA. It may sound easy to fix this one with a food processor but some people have no income or very low income. When this group of people have such a hard time surviving anyway, fear drives decision-making. Not fear of wolves, fear of lack of food. An adult in Maine, with no dependents and no income, gets about $100 in food stamps, no cash and may or may not qualify for medical assistance. There is no dental help unless it requires emergency care like an abcessed tooth. It’s easy to pick on some filthy rich person from away who wants a dead wolf in his trophy room. It is very difficult to solve extreme poverty in rural areas within the elderly population. They don’t like to ask for help. This is the group that I honestly feel sorry for but not for the ESA issue. I think they need more help then they get. Meals on wheels is a great program for those in this type of situation and it needs more expansion and funding. The poor won’t fight the ESA issues or much of anything else in Maine but out of state money will pour into sportsmen’s group lobbiest’s pockets. It is a sad state of affairs when animals and poor folks lose to well-to-do trophy hunters and politicians only ever hear a small group of self-interested deer and moose hunters who don’t hunt for subsistance, but for bragging rites.

  4. Jon Way says:

    Well written JB!

    IT – I would suggest a short season from mid-Dec to mid-Jan where some hunting is allowed but a compromise between all parties is reached. Shorter season, not during deer season, but which does allow some # of wolves to be taken. Then wolves could be valued during their exclusive season. Seems to be a very common sense way to handle it without politics involved.

    • Ida Lupine says:

      I think people could live with something like this. It’s a very conservative approach which allows for other, unforeseen impacts to the wolf population such as disease, etc.? You can’t have the public make a mockery of the status change of wolves by having killing contests. I also think UP MI is laying the groundwork for trapping.

    • Immer Treue says:


      This won’t stop the 10% annual illegal take that has been documented, and known since radio collaring of wolves has been going on. What I would like to see is an end to hunting and trapping where wolves are not causing “problems”(other than the occasional dog) such as the BWCAW, and for that matter from Ely north and east.

      Politics of deer hunting and livestock lobbies won’t let you suggestion, or mine, happen.

  5. Ralph Maughan says:

    JB and all,

    Of course, I think this is an excellent analysis.

    I think one reason why the U.S. Fish and Wildlife Service makes these kinds of arguments — to reduce intolerance — is that they are frightened of the Tea Party, but here they make the same error. Backing away, improper delisting, and similar actions usually emboldens extreme political attacks.

    The wolves were reintroduced into three of the most intolerant states in terms of protecting rare species. Citation of human intolerance in other parts of the wolf’s historic range looks disingenuous to me.

  6. Larry says:

    I am alarmed with the precedent setting analysis of FWS redefining suitable habitat and how that could be forced upon species in the future. Perhaps even by a court. Ranchers do not like ferrets for instance and loggers don’t like spotted owls . . . . this list is long. If I have cut all the old growth and spotted owl habitat no longer exists (because we have to wait 200 years)then…

    This is absurd coming from an agency that is supposed to be the premier prowildlife agency on this planet. We then have no business telling Kenya how to manage elephants.

  7. Kirk Robinson says:

    Thanks Jeremy (and others). Your critique of the FWS’s rationale for gray wolf delisting is cogent. It is very disheartening to see an agency that has the power and the mandate to ensure the recovery of a listed species ignore common sense and the best available science, not to mention duty, because it fears the tantrums of the “outrage” crowd.

  8. “Human Intolerance” specific to Eurocentric settler colonial mentalities (special interests). The ESA and NEPA are charged in protecting culturally significant species on behalf of the Nation’s Tribes. This fact is being ignored on purpose by the Secretary of the Interior and the Director of the Fish and Wildlife Service. This de-listing is an attack to weaken the ESA, NEPA and the Tribes. Wolves were hunted for the same reason Native Americans were, White human intolerance.

    • Melody Scamman says:

      Hey Valerie, good to see I am not alone, howling in the woods! I was waiting to see if anyone dare argue that point because they would have gotten more argument than they could likely handle!

    • ramses09 says:

      Valerie – you are so right ~

  9. Montana Boy says:

    One of biggest problem with continued ESA coverage for the grey wolf is FWS does not have unlimited resources. So while you and others can continue to give a long list of reasons for continued listing, can you provide a list of reasons why FWS resources are better used for the wolf over other animals in need? How many species slip in decline while while you demand more acres for the wolf. How many species with slower reproduction rates need help while you demand protection for a high reproducer?

    • Kirk Robinson says:

      It’s a fair question, Montana boy; and while I will not presume to speak for Jeremy,in my opinion we (and FWS) should not surrender the anti-ESA tactic of “starving the beast.” Congress needs to allocate more funding for the ESA, otherwise it will soon be game over for species protection. So I think Dan Ashe and Sally Jewell and Barack Obama ought to insist on more funding for saving species and protecting habitat. And frankly, it there has to be a tradeoff, then I would favor reducing or eliminating the federal subsidies to ranchers and Wildlife Services, and instead use the money for implementing the ESA. Not possible? Why not?

      • Montana Boy says:

        Frankly it’s your dream who am I to tell you about possibilities. Seems your the one with doubts.

    • Ken Cole says:

      I think you have oversimplified this issue and you are just applying it to wolves. If this is allowed to go uncontested then this sets a precedent for those other species that need to have protection too. This isn’t so much about wolves as it is about the entire Endangered Species Act.

      • Donald J. Jackson says:


        I agree with you, unfortunately, there are few very prolific species that have been in the lime light and this has created a situation that hundreds of other species have suffered for.

      • ramses09 says:

        You are so right Ken. It will set a precedent for future delisting’s of any animal. That is the sad reality of this whole issue. I don’t see Obama setting aside $$ for ESA or anything that has to do with wildlife. He has been horrible as far as that goes … he’s worse than Bush was.

    • Ken has the right of it. The article isn’t about wolves per se, but what it means to be threatened, endangered or recovered. Perhaps more importantly, the underlying question here is whether there will be any standards for recovery that can be meaningfully enforced. If the federal government can simply claim a species is recovered without providing adequate rationale; if they can ‘re-write’ the ESA with internal policy each time they find the law has put them in a bind politically; if they can ignore scientific evidence despite the mandate of the law to use the best available science… well then, the law will have lost all of its teeth without Congress getting involved at all.

      I’m not sure what wolves’ fecundity has to do with the issue? Like all species, wolves’ reproductive capacity is a function of the environmental conditions that have shaped the species’ evolution (i.e., high rates of mortality demand high rates of reproduction).

      • Montana Boy says:

        It has every thing to do with the wolf because you have yet to make the same demands for grizzlies which once lived in much the same range as the wolf. Where is your letter making the same points for the grizzly? Why are you not demanding that grizzlies live in California, Utah and Colorado?

        • Larry says:

          ouch! I don’t like your point, it may have legs.

        • JB says:

          As yet, there is no proposed rule on which to comment. We cannot critique a rule that does not exist.

          • Montana Boy says:

            Perhaps a link to your objections to the last proposed rule on the grizzly.

            • JB says:

              My comments on the prior proposed rule were submitted directly to the USFWS. We also had a manuscript under preparation, but the prior rule was invalidated before the manuscript was ready for submission.

              If you are really interested in how the policies being promulgated by the FWS adversely affect other species, I would point you toward the following two publications, both of which discuss a variety of species (e.g., the flat-tailed horned lizard, grey wolf, Canada lynx). Our article in the Virginia Environmental Law Journal discusses the grizzly bear and woodland caribou as two species potentially impacted by the FWS’s change in policy. If you don’t have academic access to these articles, email me directly and I will send you a copy.

              Bruskotter, Jeremy T., and Sherry A. Enzler. 2009. Narrowing the Definition of Endangered Species: Implications of the U.S. Government’s Interpretation of the Phrase “A Significant Portion of its Range” Under the Endangered Species Act of 1973. Human Dimensions of Wildlife 14 (2):73 – 88.

              Enzler, Sherry A., and J. T. Bruskotter. 2009. Contested Definitions of Endangered Species: The Controversy Regarding How to Interpret the Phrase “A Significant Portion a Species’ Range”. Virginia Environmental Law Journal 27 (1):1-65.

              • Montana Boy says:

                Time dictates I do my homework later, I trust what you say is true. All the while FWS only has so much time and energy. I look forward to reading your paper calling for grizzlies in California.

    • Melody Scamman says:

      Montana Boy, have you looked at real numbers for wolves? Now look at the numbers of range maggots taking up habitat. Maybe you might get this if you do? By the way, wolves only breed once a year, have small litters, and the alphas mate for life, unless one dies or is killed. Usually, only the alphas of the family will produce young. One broken bone or twisted gut can kill a wolf. They don’t have magic, mystical self-healing powers, if they did, they would be in medicine jars in China with the last of the Black Rhinos! Myths, movies and tv shows have a hard time telling fact from fiction. Sadly, the general public has no idea wolves don’t have blue eyes, siberian huskies do. Although wolves do have bluish eyes when they are born, as do many animals, it is highly unusual to ever see them because they don’t come out of the den for that time and a while afterward. People are equally as ignorant of the political slaughter of wolves unless they happen upon a wolf education sight or something far more deadly than wolves… humans hunting/trapping/snaring/poisoning or shooting them with arrows!
      And as much as I have written on wolves, they are just the first domino in the ESA test case game to fall, humans being humans and all things considered, we don’t learn well enough from history, even if it happens twice in our own lifetimes.

      • jeannine contou says:

        I totally agree with you. Respect towards animals must be used

      • Montana Boy says:

        I know the wolf numbers.Not sure where you get you information, and litter size is relative. So let me post this research page 5 is interesting in that 72% of breeding age females are pregnant. Litters ranged from 1-9.

        Also I suggest you read the spring post hear from Kathleen, I believe, about Yellowstone wolf breeding season, eye opening.
        Also I know a bit about humans killing wolves back as far as Native Americans using whale bone.

        • Melody Scamman says:

          Hey, Montana Boy, you want me to give you the Native perspective on that dated research? Pregnant wolves run slower. 🙂

      • ramses09 says:

        Melody – I love your spirit – you go girlfriend!! You took the words right out of my brain & mouth!

  10. john Glowa says:

    The USFWS is waiting for an eastern wolf assessment to have been completed by Canadians months ago. The USFWS position on eastern wolves is laughable. They based their conclusion that the northeast U.S. did not have gray wolves on two wolf specimens taken in the 19th century, one from New York and the other from Maine. They completely ignore the fact that northern New England and the Adirondacks were a wolf/moose/caribou ecosystem. They completely ignore the fact that gray wolves are found within 75 miles of Maine in the Laurentide Reserve. They completely ingnore the fact that both gray wolves and gray/eastern hybrids have found their way into the northeast for the past several decades. To say that gray wolves did not live here is pure nonsense. Science means nothing in this debate. Politics means everything.

    • Melody Scamman says:

      John, exactly true! Also, there have been stories of a thriving trade between tribes in Canada and as far south as most of New England and New York. River and ocean routes plus on extensive trail routes. Domesticated Wolves have been heard of as the being traded, possibly before there ever were dogs other than Northern Breeds in Eastern North America? That would probably make more sense in Abenaki, pre-contact version. 🙂 Sorry, I am freezing, here, it is minus something outside, -12 with a 30 mph wind, whatever that is, at some point it doesn’t matter once the brain gets cold enough, it is the thawing out that really hurts, especially after a few rounds of frostbite over the years. My friend Don froze to death, not two Winter’s ago, I tried to heat him up by the woods stove but his heart gave out. I’m not that frozen but I am not going outside again tonight! My hand froze to the door knob. It does get cold here. I’m guessing you know by your sense of local geography, wolf genetics and relating it by using mountain ranges?
      Anyway, my point being with all the trade routes, some being k-9 powered, wolves overlapping territories, there probably hasn’t been any guaranty of ‘genetic purity’ just different ‘village dogs’ of wolf at least since humans ran out of land to go east on, here? If USFWS doesn’t do something about getting some Wolves in Northern Northeast habitat, nothing else will stop coyotes from getting physically bigger and bigger.

  11. CodyCoyote says:

    Earthjustice ( formerly the Sierra Club Legal Defense Fund way back when ) is pleading the case against Grey Wolf delisting and Wyoming management on behalf of environmental groups this week December 17 in U.S. District Court in Washington D.C.

    • Melody Scamman says:

      Thanks, I knew that case was soon but gee, that’s really soon! Wyoming’s behavior left nothing to the imagination, and none of it good intentioned toward wolves.

    • WM says:

      Here is the legal complaint which serves as the basis of the claim (I do not believe it has been amended, but if I recall correctly there was a second suit filed in Cheyenne, which may have been consolidated with this one). Within, there is a very good summary of the chronology from the 1995 reintroduction of the NRM non-essential experimental population (a term which Earthjustice seems to strategically avoid) to the time the complaint was filed in 2012. And, of course, there is no reference to the FWS national blanket delisting because it was not proposed at that time. FWS will make the most of both of those points in defense of their WY delisting rule:

      So, the fate of the WY delisting rule is in the hands of a federal judge in DC, who will look at the law and only the law as applied to the WY delisting challenge. Whatever happens in the trial court and appeals, it would not be surprising to see WY just thumb their nose at the federal government as they seek resolution that puts them on par with the rest of the NRM delisting.

  12. matt says:

    In all honesty, move them but keep their protective laws. To hell with politics.

  13. Melody Scamman says:

    Re: Wyo. Wolf issue… the wolves will never be safe in Wyoming in our lifetimes. If it were up to me, and it never will be so Wyoming is safe from my thoughts, but if I could, I would remove every wolf from Wyoming and put them back in Yellowstone and raise money to fence in Yellowstone by recycling closed military facility chainlink fence and an army of volunteers. Wyoming doesn’t deserve any predators, or any federal funds, either. They don’t like to play by the rules, so see how much they enjoy it when the DC money runs out and the federal jobs dry up! I used to love Wyoming when I was a kid. I almost went to University there. Luckily, UNH was closer. All those fracking chemicals must cause brain damage? They can make the water catch fire, but hey, that’s the price they pay. Ignorance is bliss in Wyoming, now the kids have more to light on fire than bean farts at frat parties.

    • SaveBears says:

      Boy, it just keeps getting weirder and weirder around here.. Fence Yellowstone????

      • Melody Scamman says:

        SaveBears, yeah, it can’t get any weirder or violent than the militant crazies who butcher wolves in the most painful ways and speak of nailing wolf pups to trees alive and screaming in fear and pain so they can slaughter the whole pack when they come to the aid of the captive victim! I couldn’t make this stuff up.
        So sorry if I dream psychopaths could be kept out of Yellowstone, I know it won’t happen but there must be some way to keep such politicized animals as wolves and bears safe and those who care for them, too? I have heard of wolf biologists who have been refused service in public restaurants and stores, now that’s crazy! I’ve been rescuing 20 years and oh, yeah, it just keeps getting weirder and weirder! I long of those days of joyous wolf reintroductions. But then this is not just about wolves. It is all about the use of best available science vs. politics as usual.

        • SaveBears says:


          I am not against wolves by any means, but if you believe that the re-introductions were joyous, then you are not living in real world, the controversy has been here for a long time now. The nailing the pups to the tree thing is a new one, I have not heard that one before.

    • topher says:

      Fencing a national park seems a little short sighted.

    • ramses09 says:

      And all the states that hunt the wolf. Those would be – ID.,MT.,MN.,WI.,& the government who did NOT listen to the folks who actually live in Michigan “Only 15 people wrote to support the wolf hunt, compared to 4882 who opposed the hunt. – See more at:
      If you ask me – predators don’t deserve the treatment that they get – none of the above mentioned states deserve predators. But, thats life – & anti-wolf haters can’t put that into their tiny brains.
      ID. is just as bad as any of them – & I would go so far as to say – they are worse – imho

  14. Melody Scamman says:

    SaveBears, joyous and hopeful to watch wolves carefully come out of the crates and then bolt off onto the snowy woods. Totally sick of the politics.
    As for the pups nailed to trees, evidently, the twenty-something psychos were chatting on a wolf haters blog and one guy said something about if he couldn’t get real wolf pups, he gets free puppies off craigslist, nails their paws to the tree and the screams and cries bring wolves, which he mows down with his assault rifle. Normally, the bs detector would go off but for one small detail… it really isn’t public knowledge that wolf pups actually do scream. It is far more horrible than I could ever discribe, nor will I try. I’ve only heard it once and I have been rescuing for 20 years. And the one I heard was only frightened by being cornered by her siblings, she was the runt. I grabbed her up and out and she had peed on herself and was shaking for about five minutes. I wrapped her tightly in my sweater, head first. She is fine now. She lives with an elderly man who travels around in a camper, there is much love for little Alfalfa. I can not imagine how those psychos online knew wolf pups would have a vocal scream unless they actually did something horrible to one? So my friend who runs a rescue for dogs in NH told me these guy’s get their female relatives to go get puppies off craigslist, even bring kids along and act like a normal family who wants a puppy. Those puppies end up as bait for dog fighting rings. My friend says they are all psychos, no matter if it is a wolf pup or dog pup, the people are sick who use them for bait! Nailing to a tree was a first for me, too, and I thought I had heard it all. I also heard the bear and wolf hounders will put a baby bear or wolf or coyote in a rabbit wire barrel cage and set their hounds loose to chase it for however long it takes to train the hounds then they take the baby out and let the hounds tear it apart. Not a day goes by that I don’t hear of some horrible act of animal cruelty. The worst acts are those that pretend to be something they are not, and get stuffed into must-pass legislation right before some random date of a budget or social security, military pay, etc expires. The lives lost and the damage done to research, school children who followed wolf blogs and had favorite wolves… now trust is lost, years of research is lost. For what good reason? To what end? You guy’s can laugh about me wishing I could put a barrier between wolves and people that want to kill them but really, if someone invented something more on the techie end that was invisable but made a sound that wolves and other creatures found annoying enough to turn them around and back into the parks on Federal land by picking up on a subdermal chip, would you still think I’m dreaming? Not a bad idea if your research subject doesn’t end up in a fur auction? We can’t use best available science unless we have it. I’d rather fence out the crazies like I do here on the mountain but they know they are going to prison if they get caught poaching in Yellowstone. They do talk about it on their blogs, especially killing female wolves that are pregnant.
    I used to work on a S.A.C. Base, if the government wants to protect the wolves still in Yellowstone, they have the means without using a physical fence. Ideally, it would be a sound outside the human hearing range but very annoying to wolves, enough to make them stay inside the boundaries until it is safe to let them leave. A few wolves might have to be spayed and males neutered before there are too many unless they could go to other parks as intact family groups?

    • Donald J. Jackson says:

      Well if you were at the release, then we crossed paths, because I was there as well. I also spent time on a few S.A.C. bases while in the military.

      They might talk a lot, but so do the wolf supporters and I have found that many, the majority are full of crap and are doing just that, talking.

      • Melody Scamman says:

        Donald, I was at PAFB, C.E.S., Snow Barn. 3 yrs.
        Maybe our paths did cross? I was there until 89 when my house burned down. The BRAC orders were on the wall and I needed to rebuild my house. That took a few years and during that period, I rescued my first wolfdog. A sad case, they always are, but we all fell in love with him and he stayed to his dying day. I moved to Maine for him when NH took a very dark turn on wolves and wolfdogs. Now I have 5 wolfdogs and one dog. I also rescue dogs of veterans going into hospice who have nobody to take their dog. Dogs can be rehomed, wolfdogs stay forever unless it’s some special circumstance. We also have a cat my grandaughter dumped here after rescuing it from the streets when the college kids left the kitten behind. Long story short, I don’t leave the farm much anymore. I’m allowed 6 dogs so the rescue is full. I don’t exhibit animals to the public, they are just here on 68 acres on the side of a small mountain and all the females are spayed so no puppies. I will still aid in any rescues locally if necessary but at this point, I only can rehome any new dogs. There isn’t a wolfdog puppy mill crisis in Maine anymore so things are pretty much set. It’s private and it’s not open to view animals.
        I’m sorry if I sounded like I was at the original release of wolves, actually a friend sent me a video, but I wish that I could have been! I’d be thrilled if you could talk about your experience there! I’m joined at the hip to this place, the tablet is my way to ‘travel’ and learn.
        I agree with you about a lot of people being full of crap, which I thought the wolf haters were but then how would they know that a wolf puppy could scream and be able to describe the sound? I’ve seen too much evil in humans. I am deeply concerned about the ultimate fate of any animal people think they are in a competition for food or water with.

  15. CodyCoyote says:

    December 19-
    Does anyone have insight on how the oral arguments before the District Court in Washington DC went Tuesday 12/17 regarding the challenge to Wyoming’s wolf plan and USFWS blanket delisting?

    Earthjustice pleaded the case on behalf of Biodiversity Alliance, Sierra Club , and Defenders of Wildlife ( I hope I got that right ) and when might a ruling might be expected ?

  16. Ralph Maughan says:

    Dec. 30, 2013. And here is the news release on “Removing protections for wolves and the future of the U.S. Endangered Species Act.” in Conservation Letters and referenced at the bottom of the story above.

    In my opinion, this is the article of the year published on the Endangered Species Act.

  17. Louise Kane says:

    Ralph thanks for posting and JB thanks for writing this excellent critique.

    could you please provide the link to the whole article


December 2013


‎"At some point we must draw a line across the ground of our home and our being, drive a spear into the land and say to the bulldozers, earthmovers, government and corporations, “thus far and no further.” If we do not, we shall later feel, instead of pride, the regret of Thoreau, that good but overly-bookish man, who wrote, near the end of his life, “If I repent of anything it is likely to be my good behaviour."

~ Edward Abbey