Wolf Ranch Foundation
Comments on Proposal to Delist the Western Great Lakes DPS Wolves

March 22nd, 2006

Prepared by Michael Wolf
Director, Wolf Ranch Foundation



Summary:

The proposal to delist wolves in the Western Great Lakes Distinct Population Segment suffers from a fatal flaw: that wolves are recovered according to FWS and their interpretation of the ESA. Yet wolves rely on habitat, which is not considered in FWS management of wolves. Without this protection, wolves are in danger of extinction due to loss of habitat to development. As such, this proposal should not proceed.


Background:

Wolves have survived in portions of the Western Great Lakes region quite well since before America was a nation. Yet the habitat has steadily shrunk from complete coverage of the region, to mere isolated pockets of wolf population. The Endangered Species Act does not merely stipulate that a species exist in some portion of their original habitat, but was designed with the idea in mind that habitat protection be the ultimate means of protecting a species.


Detailed Comments on Proposal:

The Fish and Wildlife Service, in managing wolves, has failed in their primary mission. They have failed to ensure that wolves can survive outside of pockets of isolation. They have also failed to address the root cause of the steady reduction of wolf population over a larger time scale: the continued loss of habitat.

In managine wolves, they have set their sites on the short term, managing an existing population, in an existing habitat. The reality is that wolves are extremely sensitive to habitat and while habitat is not shrinking at any of the rates of development found in other parts of the nation, it is only a matter of time before land values become high enough to warrant development in the areas where wolves currently reside, and we are faced with shrinking wolf habitat and shrinking wolf populations.

It is no coincidence that wolves are called by many an umbrella species. The protection of wolves means the protection of all other species that live with wolves; the entire ecosystem in fact. This necessitates the protection of habitat. It is well known that wolves are sensitive to habitat. David Mech and many others have stated this in paper after paper, so much that is should be common knowledge. Yet nowhere is there a habitat management plan in place. Not in the Western Great Lakes DPS, not in the Western DPS, and not in the Eastern DPS.

It is the opinion of Wolf Ranch Foundation that habitat management and protection are paramount to wolf and associated species protection. More than maintaining current habitat, we submit that expanding habitat is necessary. This means a fundamental alteration of development practices in the United States, as well as alteration of current developments already in place. We believe these changes are necessary to ensure that America doesn't become one big suburban, paved in every township, and devoid of wolves and other wildlife with habitat needs incompatible with human development.

Fish and Wildlife must address the issue of habitat before considering delisting. Wolf Ranch Foundation submits that if habitat is not considered as part of management of wolves, that habitat will continue to shrink, and wolves will be in danger of extinction once that habitat is gone. That is the entire point of the Endangered Species Act; to address the threat (threatened status) or danger (endangered status) of extinction of wildlife. Without addressing the primary cause, the threat and danger to wolves still exists and Fish and Wildlife Service cannot therefore delist.


Conclusions:

The proposal to delist wolves in the Western Great Lakes DPS fails to recognize that the ESA's primary mission has not been addressed; that habitat protection, the main cause of wolf population decline, has not been considered by the Fish and Wildlife Service in the long term survival of wolves. Habitat will continue to shrink, and as such, wolves will always be threatened and in danger of extinction until habitat protection is put in place.

It is the opinion of Wolf Ranch Foundation, therefore, that delisting the Western Great Lakes DPS should not proceed.