July 15, 2015

An Open Letter to Members of Congress

from Scientists on Federal Wolf Delisting
We, the undersigned scientists, are writing to express opposition to the prospect that Congress
might act to delist gray wolves (Canis lupus) and Mexican gray wolves (Canis lupus baileyi) from the
Endangered Species Act (ESA). This action would run counter to the letter and spirit of the ESA,
which requires that such decisions be made according to the best available science, and it would
ignore the preferences of the public majority.
Gray wolves in the lower 48 still need federal protection, and there is no reputable scientist who
can deny that the Mexican gray wolf is critically endangered. Science-based implementation of the
ESA has saved over 200 species from extinctioni and includes an on-target recovery rate for 90% of
the nearly 1,500 species that have been listed.ii
Congress has a duty to protect wolves for the public under the public trust doctrine,iii given the
emerging science about their important role in ecosystems and the fact that they are still in the
early stages of recovery from near extinction in the lower 48 states. Moreover, a gamut of studies
indicate that the vast majority of the American public, regardless of political affiliation, view wolves
as iconic, and worthy of protection.iv Even in the states where wolves are present, state surveys
demonstrate that the greatest numbers of residents and voters want wolves conserved as they
should bewith sound science and ethics.

Michigan:
As part of a statewide survey of 973 Michiganders, researchers found that an overwhelming
majority, 82% of the respondents, valued wolves, only a fraction favored wolf hunting or
trapping, and most were committed to using sound science to manage wolves.v Following their
federal delisting, Michigan legislators passed laws to allow the trophy hunt of wolves, but were
resoundingly nullified in the November 2014 election.vi
Minnesota:
A survey by Kellert (1999) found that: Minnesotans clearly value wolves, viewing the animal as
ecologically important, scientifically fascinating, aesthetically attractive, recreationally
appealing, and significant for future generations. Only a small minority fears and dislikes wolves
or believes Minnesota would be a more desirable place without [them]. . . . a substantial
proportion (a majority of non-northern residents and nearly 50 percent of northern residents)
remain ethically opposed to harvesting wolves for fur or sport, and fear a legal harvest would
result in excessive and unsustainable numbers of wolves being killed.vii
When the Minnesota Department of Natural Resources conducted a 2012 wolf attitude survey,
7,351 residents responded; 79% did not support wolf hunting or trapping.viii In a 2013 survey of
Minnesota voters, two thirds did not support a recreational hunt or trapping of wolves because
Minnesota permits the legal killing of wolves that threaten people, livestock or property.ix
Wisconsin:
In a 2013 poll of Wisconsin voters, 79% believed that Wisconsins wolves are an asset that
should be protected for future generations; 81% opposed the trophy hunting of wolves; and
87% believed that trapping, baiting, and hounding wolves is unfair.x A Wisconsin Department of
Natural Resources 2014 survey of 8,750 Wisconsin residents (which was heavily weighted

toward rural residents who live in the wolf range) found vast majorities agreed with the
statement that wolves are important members of the ecological community; and the majority
of residents disagreed with statements that wolves should be hunted or trapped. xi Many felt
that wolves: have a right to exist; are an important member of the ecological community;
help keep deer in balance with their habitat; and so future generations can enjoy them.xii
Mexican Wolves:
A 2013 poll of Arizona and New Mexico voters showed 87% believe that Mexican wolves are a
vital part to Americas wilderness and natural heritage and that the government should
prevent their extinction and return them to suitable, historic habitats.xiii
Using the Best Available Science in Wolf-Management Decisions:
The ESA requires the U.S. Fish and Wildlife Service (FWS) to base all listing decisions solely on the
basis of the best scientific and commercial data available and that a species must be considered
endangered if it is at risk of extinction throughout all or a significant portion of its range (Sections
3 and 4 of the ESA). A species is recovered when it no longer fits that definition and is unlikely to fit
that definition in the foreseeable future. The best available science clearly indicates that wolves do
not meet that standardthey occupy only a small portion of their former rangeand that the
species could occupy much more of its former range if the threats (primarily, human-caused
mortality and inadequate regulatory mechanisms) were properly mitigated.
Recently, the FWS has ignored this scientific data and repeatedly removed federal ESA protections
from wolves. It did so by distorting the plain meaning of the phrase, significant portion of its
range, an important component of the ESA. Those distorted interpretations of the ESA are
antithetical to what Congress intended when it enacted the ESA.xiv Those distorted interpretations
were also rejected by numerous federal courts that have ordered the FWS to restore federal
protections to wolves, including the two 2014 federal court rulings.xv
Wolf Persecution:
Currently, gray wolves are absent from most of the United States, with potentially secure
populations in only a handful of states (Idaho, Montana, Wyoming, Wisconsin, Minnesota and
Michigan). Yet, in those same states, the loss of federal protections resulted in state-sanctioned
seasons on wolves at levels designed to reduce their populations to arbitrary goals, which were
based on politics but not the best available science.xvi For instance, since delisting, in Minnesota, the
population has been reduced by 20 percent, and in Wisconsin, by at least 15 percent, but likely by
more.xvii Before a federal court intervened, the Wyoming Legislature ordered that 80 percent of the
state be open to unlimited wolf killing. Killing of wolves in Montana and Wyoming has even
included wolves that should enjoy protections in Yellowstone and Teton national parksxviii the
place where thousands of tourists go annually just to see wolves and support rural economies.
Mexican wolves, the smallest, rarest and genetically distinct subspecies of wolves once ranged by
the thousands across the desert Southwest (portions of Arizona, New Mexico and Texas) and
Republic of Mexico. Eradicated in the United States by 1970, they have made a modest comeback
to Arizona and New Mexico where they number about 100 wild members.xix Mexican wolves, even
under federal listing, have been systematically persecuted through illegal poaching actions and
heavy-handed agency removals,xx which has contributed to depleted genetic variation and thus
reduced viability of this small population.xxi
What gray wolves and Mexican gray wolves need the most are greater conservation measures.

Protecting Livestock:
In rare circumstances, individual livestock owners suffer from wolves killing their livestock.xxii
Assisting those livestock owners is both appropriate and readily accomplished through
implementing non-lethal methods.xxiii Added to this, livestock growers benefit by managing wolves
as threatened under the ESA, which permits lethal management under a Section 4(d) rule,
allowing agencies to use lethal control of wolves to resolve wolf-livestock conflicts.
Wolves Benefit Ungulate Herds:
Studies show that wolves are actually beneficial to herds of native ungulates such as deer and elk as
they remove the least viable members leaving forage for the strongest members; they rarely prey
upon the prime-age breeding animals favored by hunters.xxiv A myriad of factors including habitat
loss or fragmentation, changes in forage quality, competition with other ungulates, predation,
disease, increased hunting, poaching, stochastic weather events, fire suppression, noxious weeds,
overgrazing by livestock, energy development, and changes in hydrology affect ungulate
populations.xxv Simply killing wolves and other native carnivores will not bring back the ungulate
herds.xxvi
Human Safety:
Finally, some have expressed their concern for human safety, but such fears should not be an
obstacle to recovery. While there has never been a record of a healthy wild wolf attacking a human
in the lower 48 states, the ESA listing still allows lethal removal of wolves for human safety reasons.
The best available science indicates that both the gray wolf and Mexican gray wolf occupy a mere
fraction of their historic rangesxxvii and therefore have not yet recovered from centuries of
systematic persecution.xxviii For this reason, and in recognition of the ecological services wolves
provide,xxix millions of tourism dollars to local economies,xxx and abundant knowledge from scientific
study, we ask Congress to act to conserve these species for future generations.
We urge Congress to oppose any legislation to remove the gray wolf (Canis lupus) and/or Mexican
gray wolf (Canis lupus baileyi) from protections under the ESA. Wolves are an enormous asset to
the biological diversity of our country and are well tolerated by the American public. After decades
of making excellent progress toward recovery, it would be a shame to stop before the final goal is
accomplished.
Signed:

Marc Bekoff, Ph.D.

Professor emeritus Ecology and Evolutionary
Biology
University of Colorado, Boulder
Boulder, Colorado 80309

Bradley J. Bergstrom, Ph.D.

Professor of Biology
Valdosta State University
Chair, Conservation Committee,
American Society of Mammalogists
Valdosta, Georgia
Goran E. D. Blomberg, Ph.D.
Wildlife Ecology, Retired
Michigan State University
Lansing, Michigan

Anthony J. Giordano, Ph.D.

Executive Director
S.P.E.C.I.E.S.
Ventura, California
Bob Gillespie, Ph.D.
Coordinator
Agriculture and Natural Resources
Wenatchee Valley College
Wenatchee, Washington
Phil Hedrick
Ullman Professor of Conservation Biology
Arizona State University
Tempe, Arizona
Rodney Honeycutt, Ph.D.
University Professor
Pepperdine University
Malibu, California
Glennis A. Kaufman, Ph.D.
Research Assistant Professor
Kansas State University
Manhattan, Kansas
Ken Keefover-Ring, Ph.D.
Assistant Scientist
Department of Entomology
University of Wisconsin
Madison, Wisconsin
Ralph Lampman, M.S.
Lamprey Research Biologist
Yakama Nation Natural Resource Department
Toppenish, Washington

James M. Le Moine, M.S.

Research Associate
University of Michigan
Ann Arbor, Michigan
Jennifer Leonard, Ph.D.
Tenured Researcher
Department of Integrative Ecology
Estacin Biolgica de Doana, CSIC
Seville, Spain

Malcolm R. MacPherson, Ph.D.

Scientist
Santa Fe, New Mexico
Jason P. Martina, Ph.D.
Assistant Professor of Biology
Department of Mathematics and Sciences
Our Lady of the Lake University
San Antonio, Texas

Michael Paul Nelson, Ph.D.

Ruth H. Spaniol Chair of Renewable Resources
and
Professor of Environmental Philosophy and
Ethics
Lead-PI, HJ Andrews LTER Program
Department of Forest Ecosystems and Society
Oregon State University
Corvallis, Oregon
Rich Reading, Ph.D.
Associate Research Professor
University of Denver
Denver, Colorado
Steve Sheffield, Ph.D.
Adjunct Professor
College
of
Natural
Resources
Environment
Virginia Tech
Falls Church, Virginia, and
Associate Professor
Department of Natural Sciences
Bowie State University, Maryland

and

Winston P. Smith, Ph.D.

Principal Research Scientist
Institute of Arctic Biology
University of Alaska - Fairbanks
Juneau, Alaska
John M. Stewart, Ph.D.
Professor Emeritus & Director, Wolf Research
Team
Northland College
Ashland, Wisconsin

Heather Stricker, M.S.

Certified Wildlife Biologist, retired
Rhinelander, Wisconsin
Nathan S. Upham, PhD
NSF Postdoctoral Associate
Dept. of Ecology and Evolutionary Biology
Yale University
New Haven, Connecticut
Bridgett vonHoldt, Ph.D.
Assistant Professor
Ecology & Evolutionary Biology
Princeton University
Princeton, New Jersey

John Vucetich, Ph.D.

Associate Professor
School of Forest Resources and
Environmental Science
Michigan Technological University
Houghton, Michigan
Jonathan Way, Ph.D.
Founder, Eastern Coyote/Coywolf Research
Research Scientist, Marsh Institute, Clark
University
Osterville, Massachusetts

Sources:
i

Scott, J.M., D.D. Goble, L.K. Svancana, and A. Pidgorna. 2006. By the numbers. In D. Goble, M.J. Scott, and F. W.
Davis, editors. The Endangered Species Act 1 at Thirty: Renewing the Conservation Commitment. Island Press,
Washington, D.C.
ii
Kieran Suckling et al. 2012. On Target: How the Endangered Species Act is Saving Americas Wildlife.
http://www.esasuccess.org/pdfs/110_REPORT.pdf
iii
Susan Morath Horner, "Embryo, Not Fossil: Breathing Life into the Public Trust in Wildlife," Land and Water
Review 35, no. 1 (2000); Michael P. Nelson et al., "An Inadequate Construct? North American Model: What's
Missing, What's Needed," The Wildlife Professional, no. Summer 2011 (2011); Cynthia Jacobson et al., "A
Conservation Institution for the 21st Century: Implications for State Wildlife Agencies," Journal of Wildlife
Management 74, no. 2 (2010).
iv
Jeremy T. Bruskotter, Robert H. Schmidt, and Tara L. Teel, "Are Attitudes toward Wolves Changing? A Case Study
in Utah," Biological Conservation 139, no. 1 (2007); Melanie Houston, Jeremy Bruskotter, and David Fan, "Attitudes
toward Wolves in the United States and Canada: A Content Analysis of the Print News Media, 1999-2008," Human
Dimensions of Wildlife 15, no. 5 (2010); John W. Duffield, Chris J. Neher, and David A. Patterson, "Wolf Recovery in
Yellowstone: Park Visitor Attitudes, Expenditures, and Economic Impacts," Yellowstone Science 16, no. 1 (2008); R.
Meadow et al., "The Influence of Persuasive Argument of Public Attitudes toward a Proposed Wolf Restoration in
the Southern Rockies," Wildlife Society Bulletin 33, no. 1 (2005).
v
Michele L. Lute et al., "Toward Improving the Effectiveness of Wolf Management Approached in Michigan: Insight
from a 2010 Statewide Survey," Michigan State University and Michigian Technological University (2012).
vi
Voters defeated Proposals 1 (naming wolves as a game species) and 2 (giving political appointees the power to
designate game species) by 55% and 64%, respectively.
vii
http://www.wolf.org/wow/united-states/minnesota/attitudes-and-issues-7/; See also the DNRs website:
http://www.dnr.state.mn.us/mammals/wolves/mgmt.html
viii
Wolf 2012 Public Comment.
ix
http://www.howlingforwolves.org/sites/default/files/WolfPoll.pdf
x
http://www.humanesociety.org/news/press_releases/2013/06/wisconsin-voters-support-protecting-wolves061913.html
xi
Robert Holsman, Natalie Kaner, and Jordan Petchenik, "Public Attitudes Towards Wolves and Wolf Management
in Wisconsin," Wisconsin Department of Natural Resources Bureau of Science Services (2014).
xii
Ibid.
xiii
http://www.defenders.org/publications/defenders-of-wildlife-mexican-gray-wolves-public-memonew_poll_finds_strong-support-for-wolf-protection-in-southwestern-border-states.pdf
xiv
J. T. Bruskotter et al., "Removing Protections for Wolves and the Future of the Us Endangered Species Act
(1973)," Conservation Letters 7, no. 4 (2014).

xv

See: Wyoming: Defenders of Wildlife v. Jewell, --- F.Supp.3d ----, 2014 WL 4714847 (D.D.C., Sept. 23, 2014); and
Great Lakes: Humane Society of the United States v. Jewell, --- F.Supp.3d ----, 2014 WL 7237702 (D.D.C., Dec. 19,
2014).
xvi
Bradley J. Bergstrom et al., "The Northern Rocky Mountain Gray Wolf Is Not yet Recovered," BioScience 59, no.
11 (2009). Even light persecution of wolves harms their populations. See: Scott Creel and Jay Rotella, "MetaAnalysis of Relationships between Human Offtake, Total Mortality and Population Dynamics of Gray Wolves (Canis
Lupus)," PLoS ONE 5, no. 9 (2010). Heather M. Bryan et al., "Heavily Hunted Wolves Have Higher Stress and
Reproductive Steroids Than Wolves with Lower Hunting Pressure," Functional Ecology (2014).
xvii
Wisconsin changed its protocols in counting wolves, and may be over-counting them significantly. See:
http://faculty.nelson.wisc.edu/treves/. Wisconsin admitted that 17 packs disappeared in one hunting season alone.
xviii
The death of a famous Yellowstone wolf, 832F, was reported widely in the U.S. and in Europe. See:
http://www.nytimes.com/2012/12/09/science/earth/famous-wolf-is-killed-outside-yellowstone.html?_r=0; see
also, scientists warning to the FWS about the lack of buffer zones around national parks: Atkins, "United States Fish
and Wildlife Service, Final Peer Review of Four Documents Amending and Clarifying the Wyoming Gray Wolf
Management Plan," Atkins Project No: 1000023591 (2012).
xix
http://www.fws.gov/southwest/es/mexicanwolf/pdf/MW_popcount_web.pdf
xx
More than one-half of Mexican wolves released into the wild have been killed by poachers, in part, because the
Department of Justices McKittrick Policy, which stops the persecution of poachers who claim they mistakenly
killed a look alike species. http://articles.latimes.com/2013/may/29/local/la-me-0530-endangered-species-lawsuit20130530. By 2014, agencies removed 175 Mexican wolves from the wild.
http://www.fws.gov/southwest/es/mexicanwolf/pdf/MW_removal_outcomes_web.pdf.
xxi
Hedrick, P.W. and R. Fredrickson. 2010. Genetic rescue guidelines with examples from Mexican wolves and
Florida panthers. Conservation Genetics 11:615-626.
xxii
T. B. Muhly and M. Musiani, "Livestock Depredation by Wolves and the Ranching Economy in the Northwestern
U.S.," Ecological Economics 68, no. 8-9 (2009). Wolf persecution can have the unintended consequence of creating
more wolf and livestock conflicts. RB Wielgus and KA Peebles, "Effects of Wolf Mortality on Livestock
Depredations," PLoS ONE 9, no. 12 (2014).
xxiii
Adrian Treves et al., "Forecasting Environmental Hazards and the Application of Risk Maps to Predator Attacks
on Livestock," BioScience 61, no. 6 (2011); A. Treves and K. U. Karanth, "Human-Carnivore Conflict and
Perspectives on Carnivore Management Worldwide," Conservation Biology 17, no. 6 (2003).
xxiv
Vucetich, Smith, and Stahler, "Influence of Harvest, Climate and Wolf Predation on Yellowstone Elk, 1961-2004;
Wright et al., "Selection of Northern Yellowstone Elk by Gray Wolves and Hunters."
xxv
T. D. Forrester and H. U. Wittmer, "A Review of the Population Dynamics of Mule Deer and Black-Tailed Deer
Odocoileus Hemionus in North America," Mammal Review 43, no. 4 (2013); K. L. Monteith et al., "Life-History
Characteristics of Mule Deer: Effects of Nutrition in a Variable Environment," Wildlife Monographs 186, no. 1
(2014).
xxvi
M. A. Hurley et al., "Demographic Response of Mule Deer to Experimental Reduction of Coyotes and Mountain
Lions in Southeastern Idaho," ibid., no. 178 (2011).
xxvii
C. Carroll et al., "Defining Recovery Goals and Strategies for Endangered Species: The Wolf as a Case Study,"
BioScience 56, no. 1 (2006).
xxviii
M.J. Robinson, Predatory Bureaucracy: The Extermination of Wolves and Transformation of the West (Boulder:
University Press of Colorado, 2005); Bradley J. Bergstrom, "Endangered Wolves Fall Prey to Politics," Science
333(2011); J. T. Bruskotter, S. A. Enzler, and A. Treves, "Rescuing Wolves from Politics: Wildlife as a Public Trust
Resource," ibid., no. 6051.
xxix
J. A. Estes et al., "Trophic Downgrading of Planet Earth," ibid., no. 6040; W. Ripple and R.L. Beschta, "Trophic
Cascades in Yellowstone: The First 15 Years after Wolf Reintroduction," Biological Conservation 145(2012); G. J.
Wright et al., "Selection of Northern Yellowstone Elk by Gray Wolves and Hunters," Journal of Wildlife
Management 70, no. 4 (2006); J. A. Vucetich, D. W. Smith, and D. R. Stahler, "Influence of Harvest, Climate and
Wolf Predation on Yellowstone Elk, 1961-2004," Oikos 111, no. 2 (2005); R. Callan et al., "Recolonizing Wolves
Trigger a Trophic Cascade in Wisconsin (USA)," Journal of Ecology 101, no. 4 (2013).
xxx
Duffield, Neher, and Patterson, "Wolf Recovery in Yellowstone: Park Visitor Attitudes, Expenditures, and
Economic Impacts."