ASI submits comments on gray wolf delisting
The American Sheep Industry Association joined with the Public Lands Council, the National Cattlemen’s Beef Association and a number of state livestock associations this week in submitting comments on the proposed delisting of the gray wolf.
The livestock associations have been involved with the agency’s actions with regard to gray wolves at every step of the way and feel that delisting should occur. At this point, the requirements for delisting have been met for many years and the best available science overwhelmingly indicates that this is an appropriate action. The livestock associations offer comments on the following points:
The current listing of the gray wolf (C. lupus) is unlawful, as the entity is neither a valid “species” nor “endangered” under the ESA.
While uncertainties in taxonomy persist, the best available science indicates the existing populations within the gray wolf entity should be treated as a whole; due to its prior extirpation and practical concerns, FWS should continue to treat the Mexican wolf as non-essential experimental population.
The wolf has exceeded recovery criteria outlined in the gray wolf Recovery Plans, as evidenced by wolf population estimates and expansion of its range. The ESA does not require expansion into “historical” range to achieve recovery.
The livestock associations feel that management at state level is appropriate.
In sum, numbers and range occupancy have been stable or increasing for the better part of the last decade or more. Gray wolves are recovered within the meaning of the ESA. While differences of opinion may persist, the best available science indicates wolves have surpassed measurable objectives laid out in the recovery plans and state management plans, and expanded into all or significant portions of current available range, and in some cases, into portions of “historic” range. The species’ status thus exceeds what is necessary to be considered recovered consistent with FWS’s recovery criteria.