TALKING POINTS for the August 11 and 13 hearings on the U.S. Fish and Wildlife
Service’s (Service) proposed rule revising the federal Mexican gray wolf management program
and the draft environmental impact statement analyzing the proposed rule and various
alternatives. The Service is collecting public comments at the hearings, online, and by mail
through September 23. Visit http://www.wildearthguardians.org/stand4wolves for details on the
hearings and how to comment.
1) The reintroduced wild population of THE MEXICAN GRAY WOLF IS
ESSENTIAL to the species’ survival and needs full protection under the Endangered Species Act (ESA) to
recover. When the Service listed Mexican gray wolves under the ESA and reintroduced them to the wild, it
classified them as an “experimental non-essential” population, which affords the wolves fewer protections
under the law. Ask the government how the only wild population of a species can be non-essential to the species’
survival. The only wild population of the most critically endangered mammal in North America is absolutely
essential. The Service should reclassify Mexican gray wolves as an essential experimental population and afford the
species increased protections.
2) The reintroduced wild population of THE MEXICAN GRAY WOLF NEEDS ROOM TO
ROAM throughout its entire historic range. The Service’s proposal to expand and revise the designated
Mexican gray wolf reintroduction area—allowing more opportunity for releases, relocations, and dispersal of
wolves—is a good start. However, it does not go nearly far enough. The Service’s own scientists and impartial
expert scientific peer reviewers agree the Mexican gray wolf’s current available territory and proposed
expanded territory are both insufficient to achieve recovery and removal from the list of endangered species.
The Mexican gray wolf must be able to reestablish itself in northern Arizona’s Grand Canyon area, southern
Utah, and southern Colorado, and disperse across the U.S.-Mexican border. Without a more genetically
diverse population of Mexican gray wolves spanning the Southwest, the species cannot recover. The
proposed artificial boundary of Interstate 40 has no basis in biology and should be replaced with sciencebased habitat boundaries.
3) THE MEXICAN GRAY WOLF NEEDS ROBUST PROTECTION FROM SHOOTING
AND TRAPPING. Poaching—illegal killing of Mexican gray wolves—is already the leading cause of
mortality in the U.S. Permitted “lethal control” or “take”—legal killing of Mexican gray wolves allowed
because of their less-protected status under the ESA—is already the second leading cause of mortality in the
U.S. The Service proposes to expand legal lethal control, arguing doing so will decrease poaching. Trading
one major cause of mortality for another would not help recover the Mexican gray wolf. Full ESA protection
and enforcement of the prohibition on killing wolves will. The Service should reject all alternatives that
liberalize permitted lethal control. Alternative 3 does not include this provision, and is the best Alternative
offered.
4) The Service must FINALIZE THE 2012 DRAFT MEXICAN GRAY WOLF RECOVERY
PLAN with measurable benchmarks and a clear, science-based path to recovery. The Service added the
Mexican gray wolf to the endangered species list in 1976. It did not finalize the species’ Recovery Plan until
1982. The 1982 plan did not meet the ESA’s legal requirement of including a recovery goal. Instead it set a
weaker interim goal of establishing a viable self-sustaining wild population of one hundred Mexican gray
wolves. The Service did not begin reintroducing wolves to the wild until 1998. In 2012, the Service nearly
completed, but then shelved a revised Recovery Plan that called for a larger recovery area, among other
management improvements. The 2013 official wild population count was 83 wolves. The Service has yet to
achieve even the modest 1982 interim goal of 100 wild wolves. The Service must finalize the updated
Recovery Plan.