Peer Review Panel: USFWS Didn’t Use the “Best Available Science” in Proposed Rule to Delist Wolves

Today the US Fish and Wildlife Service released the Peer Review of the proposed rule to delist wolves nationwide and its findings were pretty damning.  The proposed rule relied heavily on the findings of one paper, Chambers et al., which reclassified wolves and recognized the eastern wolf as a new species Canis lycaon.  The peer review panel disagreed with the findings of this paper and did not believe that the USFWS used the best available science as they are required to do under the Endangered Species Act when they proposed to delist the gray wolf.

The peer review lists these key findings:

  • There was unanimity among the panelists that, although there was much good scientific work in the Proposed Rule, the rule is heavily dependent upon the analysis of Chambers et al.
  • Some reviewers also noted a lack of appropriate use of the literature on species level taxonomy
  • There was unanimity among the panelists that Chambers et al was not universally accepted and that the issue was ‘not settled’. The issues raised by Chambers et al could be definitively answered relatively soon.
  • There was unanimity among the panel that the rule does not currently represent the ‘best available science’
  • Neither the panel as a whole, not any of its members in their individual reviews, made any management or policy recommendations

One reviewer, Dr. William Murdoch, noted that “Chambers et al. is written by four [U.S. Fish and Wildlife] Service scientists and was published in a Service publication. This seems a less than optimal way of establishing the best scientific statement on a controversial issue. A more standard, and I believe preferable, approach would be to convene broadly-acknowledged experts covering different viewpoints, and to produce a paper that would be published in a recognized peer-reviewed journal.”

The panel also discussed the likelihood that wolves in the Pacific Northwest constitute a distinct population segment.  Wolves have begun to reestablish populations in northwest Washington state from populations to the north in British Columbia.

Based on these findings it is difficult to see how the USFWS could rationalize delisting wolves nationwide but, because of the intense political climate, it is likely they will proceed anyway.

Because the process is fatally flawed, many groups have seized upon today’s report to ask the USFWS to stop this process now and continue to protect the grey wolf in areas where it is found outside of the Northern Rockies, Great Lakes states, and Mexican Wolf Recovery area.



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  1. JB Avatar

    People should also be aware that the FWS specifically restricted the peer reviewers to the science concerning the taxonomic status of wolves. Yet the purpose of a listing status determination is for the FWS to analyze the THREATS to a species using the best available science–and previous peer reviews have included FWS’s analysis of threats. So understand that the FWS restricted peer reviewers from commenting on any of the controversial claims made by FWS regarding threats to wolves.

    1. Ralph Maughan Avatar
      Ralph Maughan


      Thanks for reminding folks about this.

      It is too bad that the question of the actual management of wolves going on right now could not be considered, and done so by a panel of social scientists.

      1. JB Avatar


        That would be interesting, indeed! 🙂 I want to point folks toward this issue of what is being reviewable, because I think what was done here is pretty remarkable, and quite a turn for the Service (from prior rules).

        Consider the instructions–or “rules”–that were given to peer reviewers:


        This is a scientific review. It is science-based exercise. We are not trying to understand, comment on policy. We are tasked with helping to understand what science says, avoid discussions of policy and not second guessing the decision the Service will make. USFWS is tasked with the decision about saving species. They will factor in science and other issues such as the adequacy of existing regulations and protections (not a science issue). The Service will weigh many factors, but the decision is their decision” (emphasis, mine).

        I would point out here that whether existing regulations and protections are adequate is a scientific question. All one needs is a standard to define “adequacy”, population viability, for example, and a model that predicts how populations will respond. Outside of defining adequacy, this is wholly a scientific endeavor.

        1. Ralph Maughan Avatar
          Ralph Maughan

          JB, I too am very pleased that the peer reviewers actually performed a scientific review. This is because I strongly suspect USFWS/DOI higher offices want the appearance of scientific review so to perform a bureaucratic ritual serving only to create the appearance of an open process following the regulations and the law. Meanwhile, many others would have political expedience prevail.

        2. Ken Cole Avatar

          JB, I think this should be the headline of the article.

      2. Louise Kane Avatar
        Louise Kane

        perhaps JB or others can answer your question/statement Ralph…why is the current hostile management of wolves not considered especially in light of a recovery plan that is decades old and consisting of the determination that 150 animals per state constitutes a sufficient population.
        to think that 150 animals in any state would not raise red flags and alarms is truly amazing.

  2. Yvette Avatar

    I read they will also reopen the public comment period for 45 days. Are they bound by law to do this or could they make a decision without further public?

    If they keep ESA protection in the lower 48 will that have any effect on reestablishing ESA protection in the six states where they lost protection? Maybe a slight crack in the door? If that is an impossibility maybe there needs to be a change in the law regarding management of highly controversial species….a new type of management law where the neither the state nor the feds have 100% authority over the law. State fish and game dept. want money for hunting, so that puts too much bias on the management decisions they make. It seems to me that the bias surrounding wolf management needs to be better controlled. It’s obvious that states like ID and WI haven’t done that.

    I’ll hold my excitement until I see how FWS responds. I do not think I’ve ever seen anything as wacky as the decisions, management, and people’s responses as I’ve seen with the wolf issue.

  3. Jeff N. Avatar
    Jeff N.

    I really don’t think this article will add much to the conversation, but I’m curious as to what is meant by the administration “backs away” from its plan. Are they really backing away/backing off?

    1. Barb Rupers Avatar
      Barb Rupers

      The article suggests that reopening the comment period is s sign that the administration is backing off.

      This could be productive because Peter DeFazio is a ranking Democrat of the House Natural Resources Committee. He thinks the delisting is premature; “Continued protection… is the only way that gray wolves will ever return to a significant portion of their range and reclaim their place as a keystone species of American landscapes.”

  4. Ida Lupines Avatar
    Ida Lupines

    Thank you, Rep. DeFazio!

  5. CodyCoyote Avatar

    There may be something to the notion that the Eastern Wolf is indeed a separate species from the Grey Wolf.

    A central premise of the documentary film ” Meet the Coywolf” that aired on PBS Nature recently is that the wolf-coyote hybrid appearing in eastern North America is the product only of breedings between eastern wolves and coyotes. The western Grey wolf and coyotes cannot produce viable offspring, says the scientists in the Coywolf documentary.

    The Coywolves being seen in the eastern states all the way from Chicago to the mouth of the St. Lawrence River first appeared in Algonquin Provincial Park in Canada and spread outward from there. The Coywolves are intermediate in size and conformity between coyotes and wolves.

    That documentary can be viewed at :
    (53 minutes long)

    – just adding this to the conversational mix. Anuone ever seen or know of a Coyote-Grey Wolf hybrid out West ? Not I….

    I think most of us ehre are confident in saying the US Fisha and Wildlife Service allowed politics to trumps cience with wolf delisting ( and grizzlies IMHO ) to save face; save their jobs; and capitulate to hopefully stave off the groundswell among conservative western Congressional reps to totally re-write the Endangered Species Act. If USFWS were to take the pure science road and maintain its integrity on that point above all when doing its lawful duty , Congress would have their heads on platters.

    Their choices are stark.

    1. Leslie Avatar

      I just finished a class with mammalogist Jim Halfpenny and although the class was not about wolves, the subject always comes up. Jim said the Canadians have done the definitive study on the red wolf and that there is no such species. Jim drew us a timeline of the North American evolution of wolves. Canis lycaon according to the Canadian study and this genetic timeline is the only species that can interbreed either with coyotes or gray wolves.

      I tried to read the paper linked to above and got muddled down in the extensive genetic science. USF&W seems to fixate on this to fit their hunger to delist. There are other policy issues than the genetic history of Canis lycaon and the red wolf issue. Is this just a smokescreen?

    2. Ken Cole Avatar


      What is important here is not that there may be an eastern wolf but that grey wolves also inhabited the east. Take a look at the report. That is one of the issues that seems to come up a few times.

      1. Ida Lupines Avatar
        Ida Lupines

        Yes, it doesn’t mean the grey wolf didn’t coexist! The other thing is the Eastern wolf isn’t being returned or protected either.

        The coywolves are a relatively recent evolution, and I wonder if wolves were to become much lower in number in the West, that we might see them there too.

    3. Nancy Avatar

      Thanks for the link CC. No TV so glad I could watch it on the computer.

      Got to wonder if the eastern wolf (who’s population ranged from Canada down the eastern coast, many years ago) met up with the red wolf (who ranged as far west as Texas and further south) Toss coyote in here and there and presto! You have Coywolves. Possible they were here long before anyone started studies on them?

      I can recall my brother while living in Illinois, talking about a huge coyote hanging around his backyard (which was on the edge of a cornfield) Saw it a couple of times and said it wasn’t a wolf but it looked too big to be a coyote.

      1. Gabino Arizola Avatar
        Gabino Arizola

        If I may intercede here for a moment. I live in Cedar Hill, TX just outside of Dallas which is part of the original Ft. Worth Trail way back when. Native Tribes of Kiowa lived along the creek bottoms here until the 1950’s-60’s and to this day that land is sacred untouched undeveloped on orders of the land owner Dr. Phillips who took the Native people and allowed them to stay on this land. We have seen such an Animal that is the size of a Grey Wolf but lanky body and thin like the Coyote. With a reddish hue to its fur. Have contacted FWS to investigate and no response. So I called Jaimie,@ DOW and Sent her Photos of these Wolves. Which I feel are the Renowned Mexican Red Wolf. The person w/ the photos has gotten video of them clearing a 6′ fence trying to get into and out of his back yard! Trying to get a copy to post. These are like nothing Ive ever seen. I was part of the Team that first helped introduce the Grey’s to Idaho. It was My people that Donated the Land to host the project since Idaho Fish & Game wouldn’t give up land nor would BLM. That’s when Gov. Otter “stated he would Gladly host this project and would be the first in line to purchase a permit and kill the first Wolf that was seen out of the Range.” Gov. Otter has Been against this from the start, until he saw the almighty $$$ that he would profit by letting the Nez Perce/ Lemhi Nation do all the work then make sure that the F&WS did they’re part in separating and hunting down collared Wolves, taking the collars and dumping them as to make it seem that the Wolf was still roaming. When the biologist seen that the beacon was not in its same usual range, trackers were sent to find a location from last known position to new beacon site. In lies the work of DF&G and (DFWS)suddenly would show up and want to help since this was a protected Animal. Then The Collar would be found along with the Carcass of Deceased Wolf. Seems to coincidental well it happened way to many times. Then caught on tape one of the same F&G officers was “talking about how they were killing Wolves cutting the collars and for weeks nobody even knew that the Animal was dead.” All on orders from a higher up! No names were mentioned but the internal Affairs Started an Investigation and the ISF&G lost funding and rights to be a part of any ongoings with Wolves. Them It was given to USFS Even worse. They were in with Gov. Otter and his so called “Kill Squad””To rid Idaho of All Wolves” That was His New Mission! More later off to PT of My Knee! Lenos!

  6. Ralph Maughan Avatar
    Ralph Maughan

    I think the Reuters news story is a bit more accurate than the other news service stories on this.

  7. Ida Lupines Avatar
    Ida Lupines

    Eastern Wolves are Hybrids with Coyotes: Study

    Our terrible behavior when settling this country has had severe repercussions for wildlife.

    1. Ida Lupines Avatar
      Ida Lupines

      oops, I should point out that this study showed that the subspecies of Eastern wolf is a hybrid of the grey wolf and coyote, not a separate species. There were grey wolves in the East also. I thought all canids could produce offspring.

  8. BobMc Avatar

    I believe the USFWS has to reopen the comment period to accept the peer-review, and to allow the public to comment as there is a change in the basis of decision making. While I agree with the original post, and the comments I have seen so far, in addition to being tasked to only consider the science, I see a red flag in task three:
    Task 3. Does the proposed rule draw reasonable and scientifically sound conclusions from Chambers et al., 2012?
    In the statement of work we see:
    (3) The Service determined that the synthesis and conclusions of Chambers et al. (2012. North American Fauna 77:1-67) reflect the best available scientific information regarding taxonomy of wolves in North America. In doing so, does the proposed rule draw reasonable and scientifically sound conclusions concerning the taxonomy of the eastern wolf, Canis lycaon? (We are not requesting information on the status of C. lycaon because we are conducting a status review for this species and peer review of that document will occur separately.)

    Perhaps I’m too literal, but I see this as asking whether “Given X, is Y consistent?” “Given that moose can fly, are inflight collisions between aircraft and moose a possibility around rural airports?” This seems a different question than “Is X true or factual?” I believe the group was clear that Chambers does not reflect best science, but the USFWS decides what it accepts, or does not. So, USFWS can reject the peer-group premise that Chambers is not the best science, and accept the conclusion that the USFWS rule follows scientifically from Chambers, as expressed by the peer group.

  9. Ida Lupines Avatar
    Ida Lupines

    USFWS decides what it accepts, or does not.

    They and everyone else has been trumpeting that the best available science should prevail, so now they are saying something different?

  10. Ida Lupines Avatar
    Ida Lupines

    If there is still debate on the taxonomy, the door should be left open for further study. Why the rush to preemptively shut the door on it? Because that’s not the issue – politics and special interest are.

  11. Ida Lupines Avatar
    Ida Lupines

    Then there’s that pesky ESA detail:

    First, the Endangered Species Act mandates that decisions to list and delist species under the Act shall be made “soley on the basis of the best scientific and commercial data available,” so the fact an independent panel of experts commissioned by the Service has now concluded that the best science wasn’t used is incredibly important.

    Just as my own personal feelings, it is important to me that we right the wrongs of the past, and the current course by the USFWS just doesn’t do that to the best extent they can when there is still suitable habitat that doesn’t interfere with human needs.

  12. Gary Humbard Avatar
    Gary Humbard

    I believe one of the FWS’s rationale on why wolves should be de-listed is to show the ESA is a “success” and the agency was directly responsible for this accomplishment. They have hundreds of species on the threatened and endangered list to manage with only so much money.

    The northern spotted owl has had numerous listings and de-listings and recovery plans along with salmonids. Wolves will also have years of debate, but I think the ultimate solution will be educating ranchers, hunters and the general public that there is no “big bad wolf” and that we can and should co-exist with them.

    1. Ida Lupines Avatar
      Ida Lupines

      Yes – the response to the delisting in the Western and Great Lakes states shows that we’re not anywhere near there yet. 🙂

  13. Immer Treue Avatar
    Immer Treue

    What concerns me, is with liberal hunting/trapping seasons in the Western states, and the somewhat more conservative seasons in the Great Lakes states, the hunters and trappers have gotten what they wanted. Yet, we find in the Western States, it ain’t good enough. And on too of that, illegal kills are frequent (10% MN wolf kills).

    Many of us understand that wolf hunting and trapping will not go away. My big wish is that during the off season, people would just leave them alone.

    1. Louise Kane Avatar
      Louise Kane

      it might take some work and enlightenment but if any form of killing wolves will be successfully attacked it will be trapping and snaring.

  14. Ida Lupines Avatar
    Ida Lupines

    It’s hard to say, for me. The coyotes I see on occasion, without making a side-by-side comparison to the Western. I love the coywolves, but I am always painfully reminded of mankind’s ignorance in deliberately trying exterminate the wolf when I hear about them. When I see them, they are sadly ‘on the run’. Although one was just trotting in the yard looking ahead and concentrating on something.

    I do love a coyote call, and they carry a long way, so I think of what the area must have been like before it became fragmented and intersected by roads, homes, etc. I heard a yip around my back porch one night and I was thrilled.

    I love PBS Nature programs, but they are not a scientific authority and do not claim to be.

  15. Ida Lupines Avatar
    Ida Lupines

    Wolf or Coyote Spotted in Moraga, CA

    I don’t see how anything more than speculative claims can be made after the mass extinction attempt, nearly successful, made by humans on wolves? The East is part of the Gray Wolf’s historic range.

  16. Ida Lupines Avatar
    Ida Lupines

    In other words, range is where an animal lives at the particular moment the Fish and Wildlife Service decides to list it, not where it used to live before it was widely persecuted.

    Whaaaaa? More creative definitions from the USF&W:

    It Depends On What The Meaning of the Word ‘Range’ Is

    The rationale for delisting also rests on a taxonomical revision — that is, it reconceives what is meant when we say “American gray wolf.” Using a scientific paper co-authored by four of its own scientists and published in its own journal without peer-review, the Fish and Wildlife Service claims that, historically, the United States was home to another wolf species (Canis lycaon), which would mean that the “historic range” of our modern wolves (Canis lupus) didn’t actually include most of the eastern half of the country. That’s a complex point, but perhaps the most important thing to take away is the fact that the Fish and Wildlife Service previously rejected this paper in 2011 as representing “neither a scientific consensus nor the majority opinion of researchers on the taxonomy of wolves.” In other words, most experts didn’t agree with it. And they still don’t, according to the new independent review released this month, which focuses specifically on taxonomy.

    1. JB Avatar

      “He said the ESA’s real objective is “to bring species to the point where they are no longer at risk of extinction throughout all or a significant portion of their range.” Range, in his explanation, is “the range at the time at which we’re making a determination of whether a species is threatened or endangered.”

      Well that’s convenient. Now all we need to do is wait until a species is virtually eliminated, then protect the population of remaining animals. And folks wonder why it is hard to get species off the ESA… sheesh.


Ken Cole is a 5th generation Idahoan, an avid fly fisherman, wildlife enthusiast, and photographer. He is the interim Idaho Director for Western Watersheds Project.

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