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 Views of wolf scientists on the delisting/downlisting of wolves (with an emphasis on the Rocky Mountains)

August 24, 2002

One of the things that must been done before a species can be downlisted or removed from the endangered or threatened species list is peer review. Peer review is a review of the proposed action by scientific experts in the specific species. Peer review for the wolf in the Rocky Mountains was done in late 2000 along with the general public comments on the delisted of the wolf, which could occur as early as next year.

The summary below of the comments of the 11 peer reviewers (most of whose names you will recognize) was done by Dave Gaillard of the Predator Conservation Alliance.

Thanks Dave!   . . .Ralph Maughan

Hi folks,

I [David Gaillard] finally got around to reviewing some of the comments submitted in November 2000 to the U.S. Fish and Wildlife Service in response to its draft wolf
reclassification rule (65 Fed Reg 43450). The Service put all comments received onto two CD's, and I can send a copy to anyone who wants the complete record. I reviewed in detail eleven comments labeled, "Peer Reviewers." I summarize the results are as follows.

. Two of the reviewers offered little to no substantive comments (Jay Gore, William Paul).
. Six of the reviewers called for either a separate Distinct Population Segment (DPS) for the Southern Rockies, or expanding the Southwestern DPS north to include Colorado and Utah (Mike Phillips, Dan Pletscher, Rolf Peterson, Doug Smith, David Mech, Curt Mack).
. Three of the reviewers are concerned with either downlisting or delisting the Northern Rockies DPS by "lumping" the 10-10-10 breeding pairs targets to 20 pairs for downlisting or 30 pairs for delisting (Dan Pletscher, Doug Smith, Curt Mack).
. Two reviewers question the assertion that wolves never lived in California (Lu Carbyn, David Mech).
. None of the reviewers opposed downlisting wolves in the Northeast from Endangered to Threatened, and several make a point of supporting it (Mike Phillips, Dan Pletscher, Rolf Peterson, Doug Smith).
. Regarding lethal control of wolves, one reviewer is opposed to lethal control on public land (Mike Phillips), two reviewers said lethal control helps wolf recovery and should be increased (Lu Carbyn, David Mech), and one reviewer said that lethal control has harmed wolf recovery in Northwest Montana and Central Idaho (Curt Mack).
. One of these reviewers stated that wolves are not connected across the Northern Rockies populations (Doug Smith), and one said that they are, but still believes that the 10-10-10 recovery goals should not be "lumped" (Curt Mack).

Specific excerpts from the eleven "peer review" responses-

Lu Carbyn, Research Scientist, Canadian Wildlife Service, Edmonton, Alberta

-Supports the proposed rule overall.
 -Questions assertion that wolves never lived in CA. Supports downlisting, more flexible management, "[says] it is very important that the management authorities liberalize the regulations regarding private landowners and allowing them greater flexibility to protect their livestock.
-Anything you can do to reduce the actual or perceived conflicts of wolf predation losses (economic implications) should be encouraged. This means killing wolves quickly in areas of conflicts"
-"Using non-lethal harassment techniques of wolves are useful (if they work)
and should be identified in this document"
"-Thought should be given to establishing zones of wolf control on public lands, along fringe areas with private lands, that have large cattle operations. That way more wolves could be protected in the long run by preventing regular movements of wolves from public to private lands."
-"I disagree with the statement, 'on rare occasions that wolf predation may significantly affect wild ungulate populations'-this is often not the case in northern areas, and other places as well, where it has been shown that wolf predation can have great impacts on ungulate numbers and that competition with hunters is often significant, reducing packs by only 30% is not likely going to have much impact on reducing kill rates on ungulates. There is much in the literature on this."
-"[says] arbitrary numbers of packs are chosen to warrant management actions. Wolf
populations should find their own 'ecological densities' and be managed

Jay Gore, U.S. Forest Service, Missoula, Montana
Two sentence review, "I have no substantive comments and support the delisting in the many states listed."

Mark McNay, Furbearer Biologist, Alaska Department of Fish and Game, Fairbanks
-Proposes delisting wolves in North and South Dakota, where wolf recovery is not needed or feasible
-Proposes lowering wolf recovery goals in northwestern Montana "given available wolf habitat and wolf-prey interactions"
-Proposes no additional reintroductions in the southern Rockies "until the northern Rocky Mountain wolf is delisted and has survived a period of successful state management"
-Proposes removing the experimental non-essential designation from Yellowstone and Idaho and reclassifying the entire Western DPS as threatened with the proposed section 4(d) special regulation, to provide greater flexibility.

Mike Phillips, Turner Endangered Species Fund, Bozeman, Montana
-Principle concern is "minimalist targets for wolf recovery in the western U.S. instead of relevant standards from law and science"
-Specifically opposed to applying delisting criteria from the 3 states in the northern Rockies to the much larger 9-state Western DPS, "entirely unwarranted and has no basis in either biology or law"
-Proposes a Western DPS that includes WY, MT, ID, NV and eastern OR and WA; a Northwestern DPS that includes CA and western OR and WA; either a Southern Rockies DPS that includes CO, UT, and northern AZ and NM, or an expanded Southwestern DPS that includes the same.
-Reintroducing wolves to the Southern Rockies should be the Service's top priority - Mexican wolves to the south, Gray wolves to the north of this DPS  is necessary to restore wolf metapopulation from Mexico to the Arctic.
-Proposes only non-lethal control of wolves that conflict with livestock on public land.

Dan Pletscher, Wildlife Biology Professor, University of Montana, Missoula
-Line between western and southwestern DPS's should be moved north to northern borders of Utah and Colorado; reintroduce Mexican wolves into CO and UT.
-Does not think that wolves can be self-sustaining in western WA and OR, such as the Olympic Peninsula.
-Supports "Threatened" status in the Northeast.
-Supports downlisting to Threatened in the northern Rockies, but does not support delisting in the northern Rockies until all three populations exceed ten breeding pairs; NW Montana is "most important because it provides connectivity with larger wolf populations in Canada"

Rolf Peterson, Michigan Technological University, Houghton
-Believes the recovery goal of 10 breeding packs is adequate for the Northern Rockies, but "I don't believe there is an adequate basis for greatly enlarging the spatial scale for this Plan without a more thorough consideration of both spatial and numerical criteria."
-"I don't see a rationale for excluding CA and NV from DPS designation."
-"I think more consideration should be given to extending the northern boundary of this [Southwestern] DPS northward into CO and UT, or establishing an additional DPS there that would also include NV and perhaps CA.

Nancy Thomas, Endangered Species Disease Specialist, USGS, Madison, Wisconsin.
-Focused her comments on her area of expertise, disease and predation
-Monitoring of health and mortality causes will be important
-Diseases that may be potential problems include: canine heartworm, rabies, bovine tuberculosis, canine parvovirus

Doug Smith, Yellowstone Wolf Project Leader, Yellowstone Park, Wyoming
-The two areas most appropriate for wolf recovery are the Northeast and the Southern Rockies; current plan is adequate for the Northeast; current plan is inadequate for the Southern Rockies, answer is to unhook them from the northern Rockies and create a southern Rockies DPS
-The rule states that the Northern Rockies populations will begin to overlap creating one metapopulation, "This has not happened and there are not data to support that this will happen. This situation is not likely to change and wolves will continue to have difficulty surviving outside core recovery areas."
-Changing wolves to threatened is not in conflict with a conservation strategy, but closer adherence to the original 10-10-10 would be, but not necessarily a requirement."

David Mech, USGS, St. Paul, Minnesota
-Initial wolf recovery plans "went through extensive peer and public review. "I
know of no peer-reviewed scientific article that has supported any valid criticisms of them"
-"After poisoning was eliminated, every wolf population I know of has increased and expanded its range, despite illegal taking and concerted livestock depredation control."
-Population viability analyses have strong limitations and are of "minimal value, or even misleading, as predictors of population trends"
-Unlikely that wolves never lived in California; there are areas beyond the scope of current recovery programs suitable for wolf recovery, but wolf recovery is not necessary in those areas
-Wolves in the Western Great Lakes DPS should be delisted, not downlisted, despite the lack of a wolf management plan in Minnesota; wolves could survive year-round hunting and trapping if it came to that.
-Proposes expanding the Southwestern DPS northward to include CO and UT; such a change is "reasonable" and would facilitate connecting wolves between Mexico and the Arctic, "It would be difficult to overestimate the biological and conservation value of this achievement."

Curt Mack, Gray Wolf Project Leader, Nez Perce Tribe, McCall, Idaho
-Should use the term "breeding pairs" - rather than "packs" and other terms, to be consistent and clear.
-Downlisting wolves in the northern Rockies because 20 pairs have been achieved is inconsistent with the 1987 Rocky Mountain Wolf Recovery Plan, which requires a minimum of ten breeding pairs in each of two recovery areas. "If the Service is interested in changing the existing reclassification goals as stated in the 1987 Rocky Mountain Plan, they should make that clear in this Proposed Rule and allow the public to comment"
-The earliest possible time frame for achieving the existing recovery goals is 2003 and this would happen only if each of the three (3) recovery areas were able to maintain 10 breeding pairs for 3 successive years starting in 2001. northwest Montana is probably at least two (2) years away from being able to support 10 breeding pairs for the first year"
-"There have been many documented instances were [sic] wolves have have dispersed out of experimental areas into neighboring recovery areas (interchange between recovery areas) and adjacent states outside current recovery areas. [describes several of these] dispersal movements of wolves has already demonstrated that interchange between recovery areas and movements into states adjacent to recovery areas has already happened and will continue"
-Disagrees with the assertion in the rule that wolf control does not harm wolf recovery, "In northwestern Montana it has been demonstrated that, under certain conditions, wolf control can suppress wolf population expansion and recovery.
-In Idaho during late 1999 and 2000 control actions disturbed the integrity of four (4) of the then documented 10 (40%) breeding pairs in the state"
-Disagrees with the proposed Western DPS, "excluding wolves in California and Nevada as well as other states, may be justifiably perceived as arbitrary and capricious. These proposed actions may not comply with provisions of the ESA and Service policy, and are not justified or supported by the 'best scientific and commercial data available'."

William Paul, USDA Wildlife Services, Grand Rapids, Michigan
-Agrees with all aspects of the proposed rule.


About a year-and-half has passed since these comments were made. It is possible that some of these views have also changed since then.

. . . Ralph Maughan

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Copyright 2002 Ralph Maughan

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