The Honorable Sally Jewell
Secretary U.S. Department of the Interior
1849 C Street, N.W.
Washington, D.C. 20240
Dear Secretary Jewell:
Last week the National Center for Ecological Analysis and Synthesis (NCEAS) released its peer review report for the U.S. Fish and Wildlife Service's (Service) proposed rule to remove Endangered Species Act (ESA) protection for all gray wolves other than a small experimental population of Mexican wolves being reintroduced in Arizona and New Mexico. The findings of this independent scientific review validate concerns raised by Congress and the scientific community over the Service's failure to use the best available science to support the gray wolf delisting proposal. Specifically, the expert panelists noted explicitly that the rule does not currently represent the best available science, that there is not currently sufficient scientific basis for recognizing a separate "eastern wolf" as asserted in the rule, and that the rule presents no evidence excluding the gray wolf from an historic range in the eastern United States.
The Service's claim in the proposed rule that the gray wolf has recovered and should no longer be listed as endangered hinged on the purported existence of a distinct eastern wolf. The peer review report found that the existing scientific literature provides absolutely no basis for this conclusion. Therefore, we are again asking you to direct the Service to rescind the proposed rule. As you said when speaking at the Children, Conservation, and the Future of the Great Outdoors event last June, deciding whether or not to remove ESA protection from the gray wolf "is about science, and you do what the science says."
While we are troubled by the certainty with which the Service proceeded in this instance, even in the face of clear scientific disagreement, we are pleased that the agency finally heeded our calls for an independent peer review of the rule. Still, we have serious concerns regarding the initial attempts to exclude top wolf experts from this process, and the resurrection of a long-dormant government journal to "publish" the study (written by four FWS employees) used to justify the rule. These actions cast doubt on Service Director Dan Ashe's recent statement that his agency has no "desire to wring our hands and walk away from wolves."
Because it is not based on the best available science, the proposed rule undermines decades of conservation work done to protect the gray wolf, and sets a bad precedent for future ESA delistings. Further, it would stifle gray wolf recovery at a time when conservation gains are only nascent in the Pacific Northwest, and recovery has yet to begin in California, Colorado, Utah, and the Northeast, where scientists have identified a significant amount of suitable habitat that would support wolf populations.
The ESA does not charge the Service with restoring only as much of the endangered species as it deems politically convenient. In fact, the purposes of the Act "are to provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved [and] to provide a program for the conservation of such endangered species and threatened species." The Service should rescind the proposed rule immediately, and continue to review the taxonomic history of wolves in the eastern United States, and other factors related to the status of endangered gray wolf populations and their associated ecosystems before removing federal protection.