USFWS Contnues Their Delisting Lunacy

by Bill Chamberlain

The recent U.S. Fish & Wildlife Service's (USFWS) proposal to remove the wolf from the list of endangered species has shown to contain specific violations of the Endangered Species Act and the science on which it is based is severely flawed. It is a complicated proposal that contains 3 separate unrelated issues that complicates the public's ability to simply support or oppose it in its entirety. It is felt by many that this was a deliberate and devious tactic by USFWS to confuse the issues. I know many people that work for USFWS who have said publicly in their uniforms that they oppose the removing of the wolf from the Endangered Species List and agreed that the science on which it is based does not justify it. Wolf recovery is far from complete in that its population in the continental U.S. is less than 5% of its historical numbers, and it occupies less than 5% of its historic range. This proposal also wants to reclassify the Mexican gray wolf known as Canis lupus baileyi from an experimental non-essential population to an endangered subspecies. I strongly support this portion of the proposal. Additionally it proposes to classify Canis lupus lycaon as a separate species known as Canis lycaon. In 2011 the USFWS acknowledged and stated that there is significant conflicting data and debate as to whether there is a scientific basis for recognizing Canis lycaon as a distinct species. Historically this wolf has been considered a subspecies of Canis lupus known as Canis lupus lycaon. The new findings relevant to this are not sufficient to support recognizing it as a separate species.

It is felt by many the motivating factors behind this proposal are politics, special interests and the money derived from both. The proposal is 58 pages of biological "bull." The scientific rhetoric will never stand up in a court with an ethical, just and unbiased judge.

The Federal process requires that this proposal have no less than 3 public hearings where the public is afforded the opportunity to comment on this proposal. They were scheduled in Washington, DC on Sept.30 - Sacramento, CA on Oct. 2 - Albuquerque, NM on Oct. 4. I was to speak at each of these. Due to the government shutdown the Sacramento and Albuquerque hearings were canceled but not until the day of the Sacramento hearing. After the government shutdown was in effect, they scheduled another hearing for Denver, CO on Oct. 17. I traveled to Denver to speak at that hearing only to find that it had been canceled that day. These cancellations were done with little or no public notification. The money wasted on the travel expenses to these canceled hearings has devastated the USWR budget. Any funding support is appreciated beyond words.

The behavior of USFWS 1) in making this proposal, 2) their initial refusal to conduct the peer-review process as required by the ESA, 3) their rejection of a letter of scientific opposition to this proposal by 16 of the world's most renown wolf biologists, 3) and the making of attendance at the public hearings a difficult endeavor all indicate a level of ethics, integrity, and credibility that America must not tolerate.

The following Wolf Delisting Comment Letter link takes you to the text of my comment letter submitted to USFWS regarding this proposal. . Use it as a guide to create your letter. It must be mailed to the following address and received before 11:59pm on October 28.

PUBIC COMMENT PROCESSING
Att: FWS HQ ES 2013 0073
Division of Policy and Directives Management
U.S. Fish and Wildlife Service
4401 N. Fairfax Drive MS 2042 PDM
Arlington, VA 22203