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21–616 PDF 2017

THE STATUS OF THE FEDERAL 

GOVERNMENT’S MANAGEMENT OF 

WOLVES 

OVERSIGHT HEARING 

BEFORE THE

SUBCOMMITTEE ON OVERSIGHT AND 

INVESTIGATIONS 

OF THE

COMMITTEE ON NATURAL RESOURCES 

U.S. HOUSE OF REPRESENTATIVES 

ONE HUNDRED FOURTEENTH CONGRESS 

SECOND SESSION 

Wednesday, September 21, 2016 

Serial No. 114–53 

Printed for the use of the Committee on Natural Resources 

( 

Available via the World Wide Web: http://www.fdsys.gov 

or 

Committee address: http://naturalresources.house.gov 

(II) 

COMMITTEE ON NATURAL RESOURCES 

ROB BISHOP, UT, Chairman 

RAU ́ L M. GRIJALVA, AZ, Ranking Democratic Member 

Don Young, AK 

Louie Gohmert, TX 

Doug Lamborn, CO 

Robert J. Wittman, VA 

John Fleming, LA 

Tom McClintock, CA 

Glenn Thompson, PA 

Cynthia M. Lummis, WY 

Dan Benishek, MI 

Jeff Duncan, SC 

Paul A. Gosar, AZ 

Rau ́l R. Labrador, ID 

Doug LaMalfa, CA 

Jeff Denham, CA 

Paul Cook, CA 

Bruce Westerman, AR 

Garret Graves, LA 

Dan Newhouse, WA 

Ryan K. Zinke, MT 

Jody B. Hice, GA 

Aumua Amata Coleman Radewagen, AS 

Thomas MacArthur, NJ 

Alexander X. Mooney, WV 

Cresent Hardy, NV 

Darin LaHood, IL 

Grace F. Napolitano, CA 

Madeleine Z. Bordallo, GU 

Jim Costa, CA 

Gregorio Kilili Camacho Sablan, CNMI 

Niki Tsongas, MA 

Pedro R. Pierluisi, PR 

Jared Huffman, CA 

Raul Ruiz, CA 

Alan S. Lowenthal, CA 

Donald S. Beyer, Jr., VA 

Norma J. Torres, CA 

Debbie Dingell, MI 

Ruben Gallego, AZ 

Lois Capps, CA 

Jared Polis, CO 

Wm. Lacy Clay, MO 

Vacancy 

Jason Knox, Chief of Staff 

Lisa Pittman, Chief Counsel 

David Watkins, Democratic Staff Director 

Sarah Lim, Democratic Chief Counsel 

SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS 

LOUIE GOHMERT, TX, Chairman 

DEBBIE DINGELL, MI, Ranking Democratic Member 

Doug Lamborn, CO 

Rau ́l R. Labrador, ID 

Bruce Westerman, AR 

Jody B. Hice, GA 

Aumua Amata Coleman Radewagen, AS 

Alexander X. Mooney, WV 

Darin LaHood, IL 

Rob Bishop, UT, ex officio 

Jared Huffman, CA 

Ruben Gallego, AZ 

Jared Polis, CO 

Wm. Lacy Clay, MO 

Vacancy 

Rau ́l M. Grijalva, AZ, ex officio 

(III) 

CONTENTS 

Page 

Hearing held on Wednesday, September 21, 2016 ................................................ 1 

Statement of Members: 

Dingell, Hon. Debbie, a Representative in Congress from the State of 

Michigan ........................................................................................................ 4 

Prepared statement of ............................................................................... 5 

Gohmert, Hon. Louie, a Representative in Congress from the State of 

Texas .............................................................................................................. 2 

Prepared statement of ............................................................................... 3 

Statement of Witnesses: 

Bean, Brian, Owner, Lava Lake Land & Livestock LLC and Lava Lake 

Lamb, Hailey, Idaho ..................................................................................... 72 

Prepared statement of ............................................................................... 74 

Guertin, Steve, Deputy Director for Policy, U.S. Fish and Wildlife Service, 

U.S. Department of the Interior, Washington, DC .................................... 8 

Prepared statement of ............................................................................... 10 

Questions submitted for the record ......................................................... 17 

Moore, Virgil, Director, Idaho Department of Fish and Game, 

Boise, Idaho .................................................................................................. 34 

Prepared statement of ............................................................................... 36 

Questions submitted for the record ......................................................... 39 

Myers, Gordon, Executive Director, North Carolina Wildlife Resources 

Commission, Raleigh, North Carolina ......................................................... 28 

Prepared statement of ............................................................................... 30 

Questions submitted for the record ......................................................... 33 

Paterson, Tom, Owner, Spur Ranch Cattle Company LLC, Luna, 

New Mexico ................................................................................................... 78 

Prepared statement of ............................................................................... 79 

Sandoval, Alexandra, Director, New Mexico Department of Game & Fish, 

Santa Fe, New Mexico .................................................................................. 63 

Prepared statement of ............................................................................... 65 

Vucetich, John, Associate Professor, School of Forest Resources and 

Environmental Science, Michigan Technological University, Houghton, 

Michigan ........................................................................................................ 40 

Prepared statement of ............................................................................... 41 

Questions submitted for the record ......................................................... 55 

Additional Materials Submitted for the Record: 

Association of Fish & Wildlife Agencies, September 27, 2016 Letter to 

Chairman Louie Gohmert and Ranking Member Debbie Dingell ............ 103 

List of documents submitted for the record retained in the Committee’s 

official files .................................................................................................... 104 

(1) 

OVERSIGHT HEARING ON THE STATUS OF 

THE FEDERAL GOVERNMENT’S MANAGEMENT OF WOLVES 

Wednesday, September 21, 2016 

U.S. House of Representatives 

Subcommittee on Oversight and Investigations 

Committee on Natural Resources 

Washington, DC 

The subcommittee met, pursuant to notice, at 3:12 p.m., in room 

1334, Longworth House Office Building, Hon. Louie Gohmert 

[Chairman of the Subcommittee] presiding. 

Present: Representatives Gohmert, Labrador, Westerman, 

Radewagen, Bishop; Dingell, Huffman, Polis, and Grijalva. 

Also present: Senator Tillis, and Representatives Pearce, 

Lummis, Benishek, Duncan, LaMalfa, and Newhouse. 

Mr. GOHMERT. The Subcommittee on Oversight and Investigations will come to order. The subcommittee is meeting today to 

hear testimony on the status of the Federal Government’s management of wolves. Under Committee Rule 4(f), any oral opening statements at hearings are limited to the Chairman and the Ranking 

Minority Member. Therefore, I would ask unanimous consent that 

all other Members’ opening statements be made part of the hearing 

record if they are submitted to the Subcommittee Clerk by 5:00 

p.m. today. 

Hearing no objection, so ordered. 

Also, while I recognize that many people in attendance are very 

passionate about this issue, I must remind members of the audience that we will conduct this hearing in a professional and courteous manner. That means that only members of the committee 

and our witnesses will be speaking. That will minimize the distractions and allow us to have a proper evidentiary hearing. Any disruptive audience members will be removed immediately, not 

merely from the room, but from the building. 

I ask unanimous consent that the Senator from North Carolina, 

Mr. Tillis; the gentlelady from Wyoming, Mrs. Lummis; the gentleman from Michigan, Mr. Benishek; the gentleman from South 

Carolina, Mr. Duncan; the gentleman from Arizona, Dr. Gosar; the 

gentleman from California, Mr. LaMalfa; the gentleman from 

Washington, Mr. Newhouse; the gentleman from Montana, Mr. 

Zinke; the gentleman from Virginia, Mr. Beyer; and the gentleman 

from New Mexico, Mr. Pearce be allowed to sit with the 

subcommittee and participate, if there is no objection. 

Hearing none, that will be so ordered. 

I now recognize myself for 5 minutes for an opening statement. 

2 

STATEMENT OF THE HON. LOUIE GOHMERT, A 

REPRESENTATIVE IN CONGRESS FROM THE STATE OF TEXAS 

Mr. GOHMERT. For decades, ineffective, and sometimes destructive, Federal management of wolves has negatively impacted communities, economies, livestock, family businesses, recreationists, 

and even family pets in vast swaths of our Nation. While some wolf 

populations have increased to the point where they should have 

been delisted long ago, other efforts have failed miserably. 

While it is mandated by law that our public lands must be managed to allow for multiple uses ranging from ranching and recreation, to timber harvesting and conservation, the U.S. Fish and 

Wildlife Service has not worked effectively with stakeholders that 

use our Nation’s public lands, nor has it worked effectively with 

landowners or states in its recovery efforts. 

Mismanagement on the part of the Fish and Wildlife Service, as 

identified by the Office of Inspector General, has raised even more 

concerns about wolf recovery efforts across the board. 

For example, just last week, the Service announced that the 30- 

year red wolf recovery program in North Carolina is, for all intents 

and purposes, a failure. This announcement came after the Wildlife 

Management Institute and the OIG found that the Service violated 

its own rule by releasing 132 red wolves when it had only planned 

to release 12, underestimated the habitat required to recover the 

wolves at a sustainable level, could not effectively prevent wolfcoyote hybridization, and released wolves on private property without the landowner’s consent. 

However, instead of canceling the failed red wolf program, the 

Service is instead planning to nearly double the size of its captive 

breeding population, with the aim of eventually expanding the 

program to locations that could be anywhere between Texas, 

Pennsylvania, and the Atlantic Coast. 

The Service is pursuing this course, even while admitting that 

there are substantial questions about wolf genetics and a lack of 

scientific consensus about whether the red wolf should even be regulated under the Endangered Species Act. 

The Mexican wolf recovery program is similarly troubled. In 

July, the OIG found that Fish and Wildlife employees deliberately 

interfered in livestock depredation investigations, wolf nuisance 

complaints, and DNA sampling. One employee even went so far as 

to try to convince U.S. Department of Agriculture investigators to 

change their livestock depredation findings from clear wolf kills to 

coyote kills. And, even when ranchers are able to prove, without 

meddling from Fish and Wildlife, that a wolf killed their livestock, 

they are often under-compensated for their losses by livestock depredation reimbursement programs. 

Furthermore, the Service is not upholding its responsibility to 

work with states. A Federal judge recently ruled that the Service 

failed to obtain the proper permissions from New Mexico to release 

even more wolves into that state. Yet, in spite of these problems, 

the Service has expanded the reintroduction area in Arizona and 

New Mexico, and there is talk of expanding the program to Utah 

and Colorado, despite the objections from those states. 

Then there are the gray wolves located in the Northwest, 

California, and the Western Great Lakes. Management responsiVerDate Mar 15 2010 10:21 Feb 03, 2017 Jkt 000000 PO 00000 Frm 00006 Fmt 6633 Sfmt 6633 J:\114TH CONGRESS\OVERSIGHT & INVESTIGATIONS\09-21-16\21616.TXT DARLEN
3 

bility for recovered wildlife is a right reserved to the states, and 

the Endangered Species Act is very clear about congressional intent in that regard. The recovered gray wolf, however, is a prime 

example of how constant litigation is used as a tool to indefinitely 

prevent states from managing recovered species. 

For years, Idaho and Montana have shown that states can and 

do successfully and responsibly manage their wolves, and there is 

absolutely no reason why Wyoming, Minnesota, Michigan, 

Wisconsin, Utah, Oregon, Washington, and California should not 

be allowed to manage all of their wolves, as well. 

Today we will hear a broad range of testimony from a variety of 

witnesses, including state fish and wildlife directors, ranchers for 

whom wolves are a daily concern, and from the Fish and Wildlife 

Service itself. We thank the witnesses for being here today, and 

look forward to your testimony. 

[The prepared statement of Mr. Gohmert follows:] 

PREPARED STATEMENT OF THE HON. LOUIE GOHMERT, CHAIRMAN, SUBCOMMITTEE ON

OVERSIGHT AND INVESTIGATIONS

For decades, ineffective and sometimes destructive Federal management of wolves 

has negatively impacted communities, economies, livestock, family businesses, 

recreationists, and even family pets in vast swaths of our Nation. While some wolf 

populations have increased to the point where they should have been delisted long 

ago, other efforts have failed miserably. 

While it is mandated by law that our public lands must be managed to allow for 

multiple uses ranging from ranching and recreation, to timber harvesting and 

conservation, the U.S. Fish and Wildlife Service has not worked effectively with 

stakeholders that use our Nation’s public lands, nor has it worked effectively with 

landowners or states in its recovery efforts. 

Mismanagement on the part of the Fish and Wildlife Service as identified by the 

Office of Inspector General has raised even more concerns about wolf recovery 

efforts across the board. 

For example, just last week the Service announced that the 30 year red wolf 

recovery program in North Carolina is, for all intents and purposes, a failure. 

This announcement came after the Wildlife Management Institute and the OIG 

found that the Service violated its own rule by releasing 132 red wolves when it 

had only planned to release 12, underestimated the habitat required to recover the 

wolves at a sustainable level, could not effectively prevent wolf-coyote hybridization, 

and released wolves on private property without the landowners’ permission. 

However, instead of canceling the failed red wolf program, the Service is instead 

planning to nearly double the size of its captive breeding population with the aim 

of eventually expanding this program to locations that could be anywhere between 

Texas, Pennsylvania, and the Atlantic Coast. 

And the Service is pursuing this course even while admitting that there are substantial questions about wolf genetics and a lack of scientific consensus about 

whether the red wolf should even be regulated under the Endangered Species Act. 

The Mexican wolf recovery program is similarly troubled. In July, the OIG found 

that Fish and Wildlife employees deliberately interfered in livestock depredation investigations, wolf nuisance complaints, and DNA sampling. One employee even went 

so far as to try to convince U.S. Department of Agriculture investigators to change 

their livestock depredation findings from clear wolf kills to coyote kills. And, even 

when ranchers are able to prove, without meddling from Fish and Wildlife, that a 

wolf killed their livestock, they are often under compensated for their losses by livestock depredation reimbursement programs. 

Furthermore, the Service is not upholding its responsibility to work with states. 

A Federal judge recently ruled that the Service failed to obtain the proper permissions from New Mexico to release even more wolves into the state. 

And yet, in spite of these problems, the Service has expanded the reintroduction 

area in Arizona and New Mexico and there is talk of expanding the program to 

Utah and Colorado despite objections from those states. 

Then there are gray wolves located in the Northwest, California, and the Western 

Great Lakes. Management responsibility for recovered wildlife is a right reserved 

to the states, and the ESA is clear about congressional intent in that regard. The 

4 

recovered gray wolf, however, is a prime example of how constant litigation is used 

as a tool to indefinitely prevent states from managing recovered species. 

For years, Idaho and Montana have shown that states can and do successfully, 

and responsibly, manage their wolves, and there is absolutely no reason why 

Wyoming, Minnesota, Michigan, Wisconsin, Utah, Oregon, Washington, and 

California should not be allowed to manage all of their wolves too. 

Today we will hear a broad range of testimony from a variety of witnesses, including state fish and wildlife directors, ranchers for whom wolves are a daily concern, 

and from the Fish and Wildlife Service itself. I thank our witnesses for being here 

today and I look forward to your testimony. 

Mr. GOHMERT. I also want to thank you for your patience. We 

had no control over when votes were called on the Floor, and it 

interfered, obviously, with our starting time; thank you for your 

patience. 

With that, I will recognize Mrs. Dingell for an opening 

statement. 

STATEMENT OF THE HON. DEBBIE DINGELL, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF MICHIGAN 

Mrs. DINGELL. Thank you, Mr. Chairman. More than perhaps 

any other animal, wolves provoke humankind’s strongest emotional 

reactions. Look how many Members are here today; it is the largest 

attendance we have had in an O&I hearing. 

Some see the wolf as a symbol of wildness, an indicator of balance and healthy nature in a world dominated by man and his 

machines—this should say men and women and their machines. 

Others see the wolf as a nuisance, as an impediment to economic 

security and progress that never should have been allowed to return to its native lands. Still others see the wolf as a spiritual 

being, a powerful and noble teacher to be revered and protected. 

Regardless of the different feelings the wolf invokes, as a practical matter, what the wolf is in most parts of the United States 

is a threatened or endangered species listed under the Endangered 

Species Act. That reality is the reason for today’s hearing, and I 

hope that we can all keep in mind that the science and the law are 

in clear agreement that removing ESA protections for wolves where 

they are currently listed is not appropriate. I understand that it is 

a source of frustration for some people, but their numbers pale in 

comparison to the vast majority of Americans who support the return of wolves to the landscape. 

In spite of Congress’ ill-advised action to delist gray wolves in 

parts of the Northern Rocky Mountains in 2011, the progress made 

toward actual recovery of the species has put us on the cusp of 

being able to claim a significant Endangered Species Act success. 

However, the work is not finished. Gray wolves have only started 

to return to their old haunts in the Pacific Northwest and 

California, and vast tracts of suitable habitat once occupied by 

wolves still exist in New York, Maine, and the Central Rockies. 

In the American Southwest, the Fish and Wildlife Service has 

made significant progress toward restoring Mexican gray wolves to 

parts of Arizona and New Mexico. Unfortunately, this progress has 

stalled because of recent poor oversight of the program and a 

failure to develop a scientifically valid recovery plan to guide restoration of the species. Misinformation campaigns started and 

5 

perpetuated by landowners, state government officials, and others 

opposed to wolf reintroduction have not helped matters, and have 

only served to slow down the pace of recovery—an outcome that 

benefits no one. 

On the East Coast, efforts to recover the red wolf in North 

Carolina were showing incredible success until 3 years ago. 

Unfortunately, despite polls showing that 80 percent of North 

Carolina voters, including 60 percent living in the red wolf recovery 

area, support red wolf recovery, the North Carolina Wildlife 

Resources Commission has pulled its support for the program. I am 

disappointed in the Fish and Wildlife Service’s decision to abandon 

red wolf recovery efforts in North Carolina, and we all hope we can 

learn more today about how the Service should approach bringing 

this critically endangered species back from the brink of extinction. 

I am afraid that, in addition to discussing the practical concerns, 

we will spend some time today rehashing many of the myths we 

keep hearing. So I would like to offer a few facts before we get 

started. 

First, gray wolves, Mexican wolves, and red wolves are all native 

to the United States and the areas where they have been reintroduced. The science is clear that these species are not foreign 

imports or hybrids. They are American. 

Second, wolves are not a major source of livestock mortality, 

particularly cattle. While wolves do pick off the occasional sheep or 

cow, their impact pales in comparison to that of disease and 

weather. That fact is illustrated in this graphic developed by a report from the U.S. Department of Agriculture. Already low predation by wolves can be driven even lower through nonlethal conflict 

reduction methods. 

Third, wolves are not depleting populations of other wildlife to 

dangerously low levels. Wolves do, and should, eat elk, deer, moose, 

and other ungulates; but data published by states, including those 

represented at today’s hearing, show that hunters continue to enjoy 

increased harvests of game animals, even with wolves on the 

landscape. 

Finally, wolves are not a public hazard. Bees, domestic dogs, and 

deer kill far more people each year than the zero killed by wolves. 

With that, I look forward to hearing from our witnesses today, 

and I yield back my 2 seconds. 

[The prepared statement of Mrs. Dingell follows:] 

PREPARED STATEMENT OF THE HON. DEBBIE DINGELL, RANKING MEMBER, 

SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS

Thank you, Mr. Chairman. 

More than perhaps any other animal, wolves provoke humankind’s strongest emotional reactions. Some see the wolf as a symbol of symbol of wildness—an indicator 

of balance and healthy nature in a world dominated by man and his machines. 

Others see the wolf as nuisance—an impediment to economic security and progress 

that never should have been allowed to return to its native lands. Still others see 

the wolf as a spiritual being—a powerful and noble teacher to be revered and 

protected. 

Regardless of the different feelings the wolf invokes, as a practical matter what 

the wolf is in most parts of the United States is a threatened or endangered species 

listed under the Endangered Species Act (ESA). That reality is the reason for today’s hearing and I hope that we can all keep in mind that the science and the law 

are in clear agreement that removing ESA protections for wolves where they are 

currently listed is not appropriate. I understand that is a source of frustration for 

6 

some people but their numbers pale in comparison to the vast majority of Americans 

who support the return of wolves to the landscape. 

In spite of Congress’ ill-advised action to delist gray wolves in parts of the 

Northern Rocky Mountains in 2011, the progress made toward actual recovery of 

the species has put us on the cusp of being able to claim a significant ESA success. 

However, the work is not finished yet. Gray wolves have only started to return to 

their old haunts in the Pacific Northwest and California, and vast tracts of suitable 

habitat once occupied by wolves still exist in New York, Maine, and the Central 

Rockies. 

In the American Southwest, the Fish and Wildlife Service has made significant 

progress toward restoring Mexican gray wolves to parts of Arizona and New Mexico. 

Unfortunately, this progress has stalled because of recent poor oversight of the program and a failure to develop a scientifically valid recovery plan to guide restoration 

of the species. Misinformation campaigns started and perpetuated by landowners, 

state government officials, and Members of Congress opposed to wolf reintroduction 

have not helped matters and have only served to slow down the pace of recovery— 

an outcome that benefits no one. 

On the East Coast, efforts to recover the red wolf in North Carolina were showing 

incredible success until 3 years ago. Unfortunately, and despite polls showing that 

80 percent of North Carolina voters—including 60 percent living in the red wolf recovery area—support red wolf recovery, the North Carolina Wildlife Resources 

Commission has pulled its support for the program. I am disappointed in the Fish 

and Wildlife Service’s decision to abandon red wolf recovery efforts in North 

Carolina, and I hope we can learn more today about how the Service should approach bringing this critically endangered species back from the brink of extinction. 

I am afraid that in addition to discussing the practical concerns, however, we will 

also spend time today rehashing the same tired old myths that wolf opponents have 

continued using for decades, even after they have been soundly debunked. Therefore, I would like to offer a few facts before we get started. 

First, gray wolves, Mexican wolves, and red wolves are all native to the United 

States and the areas where they have been reintroduced. The science is clear that 

these species are not foreign imports or hybrids. They are as American as mom and 

apple pie. 

Second, wolves are not a major source of livestock mortality, particularly cattle. 

While wolves do pick off the occasional sheep or cow, their impact pales in comparison to that of disease and weather. That fact is illustrated in this graphic developed 

from a report by the U.S. Department of Agriculture. Already low predation by 

wolves can be driven even lower through nonlethal conflict reduction methods. 

Third, wolves are not depleting populations of other wildlife to dangerously low 

levels. Wolves do—and should—eat elk, deer, moose, and other ungulates, but data 

published by states including those represented at today’s hearing show that hunters continue to enjoy increased harvests of game animals even with wolves on the 

landscape. 

Finally, wolves are not a public safety hazard. Bees, domestic dogs, and deer kill 

far more people each year than the zero killed by wolves. 

With that, I look forward to hearing from our witnesses today, and I yield back. 

Mr. GOHMERT. Thank you. I will now introduce our first two 

witnesses from our right. 

Mr. Steve Guertin is the Deputy Director for Policy at the U.S. 

Fish and Wildlife Service. And then, Mr. Gordon Myers is the 

Director of the North Carolina Wildlife Resources Commission. 

Next, I recognize the gentleman from Idaho, Mr. Labrador, for 

our next witness. 

Mr. LABRADOR. Thank you, Mr. Chairman. It is my pleasure to 

introduce Director Virgil Moore this afternoon, and to welcome him 

to our subcommittee. Director Moore has served as the Director of 

the Idaho Department of Fish and Game since 2011. He received 

his M.S. from Idaho State University in zoology, and has over 40 

years of professional experience in fish and wildlife management. 

He has served in many positions for Idaho Fish and Game, including Deputy Director for Field Operations, Fishery Bureau 

7 

Chief, Information and Education Bureau Chief, Fisheries 

Research Manager, and various other field management positions 

as a fishery scientist. 

He is directly involved with grizzly bear, gray wolf, sage grouse, 

wolverine, lynx, cutthroat trout, gold trout, steelhead, and salmon. 

As Vice President of the Association of Fish and Wildlife 

Agencies, Virgil represents North America’s fish and wildlife agencies to advance science-based management and conservation of fish 

and wildlife and their habitats in the public interest. 

Thank you, Mr. Chairman. I also have another Idaho witness. 

Should I wait? 

Mr. GOHMERT. Let me recognize the Ranking Member to 

introduce our next witness. 

Mrs. DINGELL. I would also like to introduce Professor John 

Vucetich. He is a professor at Michigan Technological University, 

where he teaches population ecology and environmental ethics. He 

is the lead researcher on the wolves and moose of Isle Royale 

National Park at Lake Superior, Michigan. It is the longest study 

of any predator-prey system in the world. 

He has authored more than 80 scholarly papers on wolf prey 

ecology, population genetics, extinction risk, and environmental 

ethics. He was on the Mexican wolf recovery team for almost 15 

years, and was a peer reviewer of Wyoming’s wolf management 

plan for the FWS. 

He has also advised Members of Congress on wolf-related policy 

issues. 

I am pleased to welcome a fellow Michigander to this panel 

today. Thank you for your time and service. 

Mr. GOHMERT. Thank you. At this time we will recognize the 

gentleman from New Mexico, Mr. Pearce, to introduce our next 

witness. 

Mr. PEARCE. Thank you, Mr. Chairman. It is my pleasure to introduce Alexandra Sandoval. She is the Director of the New Mexico 

Game and Fish Department, a position she has held since May of 

2014. She is absolutely no stranger to the issues surrounding the 

Mexican gray wolf recovery program. 

Director Sandoval, thank you for being here today. 

Mr. GOHMERT. Thank you. I recognize the gentleman from Idaho 

to introduce our next witness. 

Mr. LABRADOR. Thank you, Mr. Chairman. It is also my pleasure 

to introduce Brian Bean today. Brian is the co-founder of the Lava 

Lake Institute, and co-owner of Lava Lake Land & Livestock, and 

Lava Lake Lamb in south central Idaho—I am a little bit hungry 

now, after saying all that. 

[Laughter.] 

Mr. LABRADOR. Brian is a magna cum laude, Phi Beta Kappa 

graduate of Pomona College, where he was a dual major in biology 

and zoology. Brian and his wife Kathleen founded Lava Lake 

Ranch in 1999, with the intention of producing and marketing 100 

percent grass-fed and finished lamb, while protecting the natural 

characteristics of the landscape. 

In 2004, the Beans established the Lava Lake Institute for 

Science and Conservation. The Institute is a non-profit that 

8 

supports conservation research efforts. The Institute serves as the 

fiscal sponsor for the Wood River Wolf Project. 

Welcome. 

Mr. GOHMERT. And to introduce our last witness, Mr. Pearce, the 

gentleman from New Mexico. 

Mr. PEARCE. Thanks again, Mr. Chairman. And I would like to 

say thanks to Tom Paterson from Luna, New Mexico. Tom runs the 

Spur Ranch Cattle Company in Luna with his wife, Callie, and his 

daughters, Lindsay and Caroline. 

His boots-on-the-ground experience dealing with wolf depredation 

on the cattle at the Spur Ranch, and with Fish and Wildlife Service 

wolf management, sheds insight into what New Mexican ranchers 

are dealing with. I am confident that his experiences reflect that 

of the ranchers throughout our Nation who must conduct their 

operations in wolf reintroduction areas. 

Mr. Paterson, thanks for traveling all the way to DC for this 

hearing. 

Mr. GOHMERT. Thank you. Let me remind the witnesses that, 

under our Committee Rules, oral statements must be limited to 5 

minutes. Your written statements will be part of the Committee 

hearing records, but the witness oral statement is limited to 

5 minutes. 

You will note your time is on the little indicator there. When you 

begin, the light on the witness table will be green. When there is 

1 minute remaining, it turns yellow. Then, when the time is up it 

turns red, and that is when you need to finish up so I don’t have 

to for you. 

At this time the Chair would now recognize Mr. Guertin for his 

testimony. 

You are recognized for 5 minutes, Mr. Guertin. 

STATEMENT OF STEVE GUERTIN, DEPUTY DIRECTOR FOR 

POLICY, U.S. FISH AND WILDLIFE SERVICE, U.S. DEPARTMENT OF THE INTERIOR, WASHINGTON, DC 

Mr. GUERTIN. Good afternoon, Mr. Chairman, Ranking Member 

Dingell, and members of the subcommittee. Thank you for the opportunity to testify today with the views of the Fish and Wildlife 

Service and our report on our work to recover wolves across the 

lower 48 United States and Mexico. It is a great recovery program 

and management endeavor of our time. Our work over decades has 

led to successes, but also demonstrates the hard challenges that lie 

ahead. 

In 1974, when wolves first received the protections of the modern-day Endangered Species Act, there were no wolves in the wild 

in the lower 48 states, except in northern Minnesota; elsewhere 

they had been eliminated after years of control programs, reductions of prey, and habitat degradation. Like most species protected 

by the ESA, the conditions that wolves faced as a species in the 

Lower 48 were dire when it was listed. And, similar to other 

species, restoring wolves at the landscape requires many years of 

sustained work among many partners. 

Our primary goal, consistent with our legal mandates, is to prevent extinction of wolves, address threats to their long-term 

survival, recover wolves, and restore management of wolves to the 

9 

states. We are proud of the long-term collaboration among service 

field biologists and poly-professionals with Federal and state agencies, tribes, and non-governmental entities. This collaboration has 

enabled the gray wolf to make a markable recovery in much of the 

lower 48 states. 

Wolves are now re-established in the Western Great Lakes and 

the Northern Rockies, large landscapes where only decades ago 

they had been exterminated. They have recently expanded at the 

Pacific Northwest and Northern California, and we believe the 

range will continue to grow under the capable management of our 

state wildlife agency partners. Wolf recovery in the Western Great 

Lakes and Northern Rocky Mountains has been an impressive success, due to both resiliency of wolves and the cooperative efforts of 

the Service’s many and varied partners. 

Success in these areas led the Service to determine that those 

gray wolf populations are biologically recovered, and no longer warrant listing under the Endangered Species Act. We proposed and 

finalized rules to reflect our science-based determinations of recovery under the ESA. Judicial review overturned our delisting for 

wolves in Wyoming and the Western Great Lakes, but we are appealing those decisions, and hearings are scheduled over the next 

month. 

As we move forward with our mandate to recover wolves, the 

Service’s focus now is on recovery of Mexican wolves in the 

Southwest and the red wolf in the Southeast, both of which were 

eliminated from the wild and are endangered under the ESA. The 

Service remains committed to the recovery of these wolves. Their 

recovery is dependent on captive breeding programs, reintroduction 

of captive wolves into the wild, and managing for secure, selfsustaining wolf populations. 

These starkly different circumstances refer both to the successes 

and the challenges associated with restoring this large predator to 

the landscape. The successes we have achieved and the challenges 

remaining underscore the importance of strengthening and expanding partner and community support for wolf recovery. 

Recovery efforts involving reintroduction of large carnivores are 

inherently controversial, especially to local communities. Social tolerance for the presence of wolves is vital for success. Gaining social 

tolerance requires us to engage local communities and landowners 

to address their concerns. 

Building social tolerance requires us to manage conflicts with 

wolves in ways that strengthen community support. That means 

providing states and landowners with the tools and expertise to 

prevent wolf-livestock conflicts, and, in some cases, removing problem wolves and compensating landowners and lease holders for 

their losses when they occur. 

It will take continued collaboration between the Service and our 

state, tribal, and community partners to bring these populations off 

of the Federal list of threatened and endangered species, and return management to the states. 

I would like to recognize the contributions of my colleagues on 

this panel. The work of our state agency partners and private landowners to conserve and co-exist with wolves is critical to their 

10 

recovery and subsequent return to state management. I look 

forward to hearing their perspectives on this complex issue. 

The Service will continue to implement the mandates of the 

Endangered Species Act and keep working toward the long-term 

recovery of wolves in the Lower 48 and Mexico. If we are successful 

in engaging the support of our partners and stakeholders, we are 

confident we will be successful. 

Thank you for the opportunity to testify today. 

[The prepared statement of Mr. Guertin follows:] 

PREPARED STATEMENT OF STEPHEN GUERTIN, DEPUTY DIRECTOR FOR POLICY, U.S. 

FISH AND WILDLIFE SERVICE, U.S. DEPARTMENT OF THE INTERIOR

Chairman Gohmert, Ranking Member Dingell, and members of the subcommittee, 

thank you for the opportunity to appear before you today to testify on the U.S. Fish 

and Wildlife Service’s (Service) work to recover wolves across the Lower 48 United 

States. My name is Stephen Guertin and I am the Deputy Director for Policy for 

the Service. 

The wolf is an iconic yet controversial example of the Endangered Species Act’s 

(ESA) success in preventing extinction and promoting recovery. Because of years of 

sustained and cooperative efforts of Federal and state agencies, tribes, and nongovernmental entities, wolves have made an impressive recovery in the Western 

Great Lakes (WGL) and the Northern Rocky Mountains (NRM). They are reestablished in large landscapes where only decades ago they had been effectively 

exterminated, and have recently expanded their range into the Pacific Northwest 

and Northern California. In the Southwest and Southeast, however, wolves exist in 

the wild only as reintroduced experimental populations and continue to be highly 

endangered. These starkly different circumstances reflect both the successes and the 

challenges associated with restoring a charismatic large predator to the landscape. 

Our goal, consistent with our legal mandates, is to recover wolves—so that they are 

no longer threatened or endangered—and return management of those recovered 

wolves to the States. 

BACKGROUND ON WOLVES AND ESA PROTECTION

The ESA is one of the Nation’s most important conservation laws. It is implemented jointly by the Service and the National Marine Fisheries Service. The law’s 

stated purpose is to provide a program and means for the conservation of threatened 

and endangered species and the ecosystems upon which they depend. The ESA 

provides a safety net for species that are at risk of going extinct. The Service uses 

the best available scientific and commercial information to determine whether 

species need to be listed, to identify and address the threats to the species, and to 

facilitate the recovery of the species. When a species is designated as threatened or 

endangered—or ‘‘listed’’ under the ESA—it is in dire need of help. 

Throughout their range, wolves are keystone predators and have a profound effect 

on the ecosystems they inhabit. The wide range of habitats in which wolves can 

thrive reflects their adaptability as a species. In his essay titled, ‘‘Thinking Like a 

Mountain,’’ the great American conservationist Aldo Leopold described the cascading 

effects of losing wolves in a forested mountain ecosystem—the resulting increase of 

deer, followed by overgrazing, deforestation and erosion, and then the collapse of 

deer after having eaten themselves out of house and home. 

Wolves were once found across the northern hemisphere of the planet, including 

most of North America. When Europeans began to colonize America in the 1600s, 

wolves were widely distributed and could be found in each of what are now the 

lower 48 states. As human populations across America grew so did fears of wolves 

and other predators and the perceived risks they posed to personal safety, livestock, 

pets, and game species. Extensive predator control programs, magnified by the use 

of bounties, and combined with habitat degradation and a declining prey base, resulted in the extirpation of wolves from most of the lower 48 states early in the 20th 

century, with the exception of only a few hundred remaining wolves in northern 

Minnesota and Isle Royale in Michigan. No wolves persisted in vast wild areas such 

as the NRM and the desert southwest. 

Wolves were among the first species added to the list of endangered species, 

starting with the red wolf (Canis rufus) and subspecies of the gray wolf (Canis 

lupus) in 1967 and 1973 under precursors to the ESA—the Endangered Species 

Preservation Act of 1966 and the Endangered Species Act of 1969. Both red wolves 

and gray wolves were listed as separate species under the modern ESA in 1974 and 

11 

the Mexican gray wolf subspecies was listed as endangered in 1976. By 1978, all 

gray wolves were listed as an endangered population at the species level throughout 

the contiguous United States and Mexico, except for those wolves in Minnesota, 

which were classified as threatened. 

In 1988, Congressman John Dingell, a sponsor of the original ESA, wrote the 

following about the passage of the law in 1973, ‘‘The goal Congress set then was 

unparalleled in all of history. Our country resolved to put an end to the decades— 

indeed, centuries—of neglect that had resulted in the extinction of the passenger 

pigeon and the Carolina parakeet, and the near extinction of the bison and many 

other species with which we share this great land. If it were possible to avoid causing the extinction of another species, we resolved to do exactly that . . . When 

Congress passed the Endangered Species Act, it set a clear public policy that we 

would not be indifferent to the destruction of nature’s bounty.’’ 

The ESA has been successful in its essential goal to conserve listed species, which 

effectively protects the Nation’s biological diversity heritage for the benefit of future 

generations of Americans. Since it was enacted by Congress in 1973, the ESA has 

successfully prevented the extinction of more than 99 percent of the over 1,500 

species it protects. Recovering species to the point where they are ready for delisting 

and no longer need the protections of the ESA often requires focused conservation 

efforts over many years, often decades, to implement recovery actions. In the last 

8 years, 19 species have been delisted due to recovery and returned to the state 

management. Recently delisted species include the Louisiana black bear, Oregon 

chub, Delmarva fox squirrel, Virginia northern flying squirrel, Modoc sucker, island 

night lizard, and brown pelican. 

The ESA has been successful for wolves. Extinction in the lower 48 states was 

averted and the long, sustained work of recovery—along with state, local, tribal, and 

other Federal partners—has produced thrilling successes. The ESA provides the 

Service with management flexibilities that have proven vital in furthering the recovery of wolves, including the designation of nonessential experimental populations 

under section 10(j) of the law. With a nonessential experimental population, the 

Service is able to introduce a population with flexible management options available 

that are tailored to the needs and concerns of particular area of introduction as well 

as the species’ needs. Probably the best-known wolf recovery effort was the reintroduction of gray wolves into Yellowstone National Park in 1995. Some studies indicate that in relatively pristine areas such as Yellowstone, the establishment of 

healthy wolf packs has had a positive cascading effect on the ecosystem. These effects to relatively pristine areas, which may still be unfolding and are being studied, 

appear to include keeping elk from overgrazing along exposed river banks where 

they are vulnerable to wolf predation, leading to regrowth of riparian vegetation, an 

increase in beaver colonies, and the resulting positive habitat changes that beaver 

dams provide to a host of wildlife species. While these effects may occur at varying 

degrees elsewhere, they are increasingly modified and subtle the more an area is 

affected by humans. 

As with our conservation work for any listed species, recovery of wolves is not 

something the Service can or has achieved alone. Throughout the wolf recovery process, the Service has worked in close partnership with Federal and state agencies, 

tribes, private landowners, and other stakeholders. Wolf recovery in the WGL and 

the NRM has been an amazing success due to both the resiliency of wolves and the 

cooperative efforts of the Service’s many and varied partners. 

Bolstered by reintroductions and the conservation and management as species 

protected by the ESA, wolves have repopulated portions of their historical range in 

the lower 48 states. Restoration throughout the species’ entire historical range in 

the United States is not required for recovery under the ESA, nor is it a reasonable 

expectation for species such as wolves given the expansion of human populations 

and resultant habitat degradation. In the NRM and WGL the success of recovery 

efforts has been remarkable. These animals are resilient and their range is naturally expanding. The success in these areas led the Service to determine that gray 

wolves are biologically recovered under the requirements of the ESA, with the exception of Mexican gray wolves, which remain endangered. We have proposed and 

finalized a number of rules to reflect our science-based determination of recovery 

under the ESA; courts have overturned some of those delisting rules, as judicial review remains an important part of the ESA. The red wolf remains a separately 

listed entity. 

12 

STATUS OF WOLVES IN THE LOWER 48 UNITED STATES

Gray Wolves 

Gray wolf recovery efforts have long focused on three recovery areas—the NRM, 

the eastern United States, and the Southwest. Recovery plans were developed in 

each of these areas to establish and prioritize recovery criteria and actions appropriate to the unique local circumstances of the gray wolf. 

Wolves in the Northern Rocky Mountains 

At the time of listing, wolves in the NRM region were completely extirpated. In 

1982, a wolf pack from Canada began to occupy Glacier National Park along the 

U.S.-Canada border and a few years later, the first litter of pups documented in 

over 50 years was born in the Park. This natural recolonization was the beginning 

of wolf recovery in the NRM. Under the protections of the ESA, wolf populations 

in the NRM have rebounded thanks to natural dispersion and successful reintroduction efforts in Yellowstone National Park and central Idaho. Since delisting, under 

state management, the wolf population in this region continues to hold steady. As 

of December 31, 2015, there were at least 1,704 wolves in 282 packs in Montana, 

Idaho and Wyoming. An additional 200 wolves in 34 packs were estimated in 

Oregon and Washington. 

By the mid 2000s, wolves in the NRM had met the Service’s recovery goals under 

the ESA, prompting the Service to delist the gray wolf distinct population segment 

in this region in 2008 due to recovery. Following that initial delisting, NRM wolves 

have had a litigious history, with several court challenges filed against the Service’s 

decisions. Ultimately, the Congress directed the Service to reinstate our delisting 

rule and shielded it from further legal challenge. Today, wolves in Idaho, Montana, 

eastern Oregon, eastern Washington, and north-central Utah are no longer listed 

under the ESA and are being successfully managed by the states. Both Idaho and 

Montana manage wolves in accordance with state management plans, under which 

their wolf populations have remained secure and well above recovery objectives. 

Similarly, the Service’s delisting of wolves in the state of Wyoming in 2012 drew 

a legal challenge. That delisting was vacated by a court decision in 2014 and the 

Service currently manages wolves in Wyoming as a nonessential experimental population under the ESA in accordance with that ruling. The Federal Government has 

appealed this ruling, and oral arguments in this appeal are scheduled for this 

Friday, September 23, 2016. 

Wolves in the Western Great Lakes 

Unlike the NRM region, wolves were never completely extirpated from the WGL 

region; it is estimated that the Minnesota wolf population was comprised of a few 

hundred individuals at the time of listing. Under the protections of the ESA, this 

population naturally expanded its range into Wisconsin and Michigan. The current 

population of wolves in the WGL region is derived from expansion of this remnant 

population in northeastern Minnesota, supplemented by possible contributions from 

wolves from southern Ontario. Like the wolves in the NRM region, WGL wolves 

have exceeded the recovery goals that the Service set, with more than 3,600 wolves 

estimated in Minnesota, Michigan, and Wisconsin. The Service first delisted these 

wolves in 2007, though today they remain listed under the ESA due to ongoing litigation through which a court vacated our final delisting rule in 2014. The Federal 

Government is appealing the court’s decision to reinstate ESA-protections for WGL 

wolves; oral arguments in this appeal are scheduled for mid-October. 

Mexican Gray Wolves 

The Mexican gray wolf is the rarest subspecies of gray wolf in North America. 

Once common throughout portions of the southwestern United States, the Mexican 

wolf was all but eliminated from the wild by the 1970s due to extensive predator 

control initiatives. Recovery efforts for the Mexican wolf began when the subspecies 

was listed as endangered in 1976. 

Following the capture of some of the last remaining Mexican wolves in the wild 

in Mexico, the Service and Mexico collaborated to establish a binational breeding 

program with seven founding wolves. Today, the approximately 50 captive breeding 

facilities in the two countries house 240 to 300 Mexican wolves, which are managed 

under the Mexican Wolf Species Survival Plan. Wolves from the captive breeding 

program are used for reintroduction in the United States and Mexico. The Service 

established a nonessential experimental population of the Mexican gray wolf in 

Arizona and New Mexico in 1998, and the first Mexican wolves were released to the 

wild in the Blue Range Wolf Recovery Area within the Mexican Wolf Experimental 

Population Area (MWEPA) in 1998. 

13 

In January 2015, the Service published the Revision to Regulations for the 

Nonessential Experimental Population of the Mexican Wolf (80 FR 2512–2567, 

January 16, 2015). This 2015 rule under section 10(j) of the ESA provides an expansion of the area where Mexican wolves may occur and where Mexican wolves can 

initially be released from captivity compared to the previous 1998 10(j) rule. The 

2015 rule also provides a population objective of 300 to 325 wolves in the MWEPA. 

Also in January 2015, the Service also issued a final rule listing the Mexican wolf 

as an endangered subspecies. It is now a separately listed entity under the ESA, 

whereas it had previously been protected under the more generic listing for the gray 

wolf (Canis lupus) species in the lower 48 states and Mexico. 

The experimental population of Mexican wolves peaked at 110 wolves in the wild 

in 2014, but declined to 97 wolves in 2015, principally due to reduced pup survival 

in 2015 relative to 2014. Since 1998, more than half of the documented Mexican 

wolf deaths are due to illegal killing. The release of Mexican wolves from the more 

genetically diverse captive population remains critical to improving the genetic 

health of the experimental population and moving the Mexican wolf toward 

recovery. 

The Service reinitiated the process to revise the 1982 Mexican Gray Wolf 

Recovery Plan in December 2015. The Service is working with participants from the 

New Mexico Department of Game and Fish, Arizona Game and Fish Department, 

Utah Division of Wildlife Resources, Colorado Parks and Wildlife, Federal agencies 

in Mexico, and independent scientists from the United States and Mexico to assist 

us in gathering and assessing scientific information pertinent to our development 

of a revised recovery plan. The revised recovery plan will provide measurable and 

objective criteria which, when met, will enable us to remove the Mexican wolf from 

the list of endangered species and turn its management over to the states. The 

Service expects to publish a final recovery plan by the end of November 2017. 

Gray Wolves Across the Remainder of the Lower 48 States 

For nearly four decades, the Service has consistently taken a regional approach 

to gray wolf recovery in the lower 48 states and Mexico. In other words, we have 

considered recovery to entail establishment of secure, healthy and stable populations of gray wolves in the WGL, the NRM, and the Southwest. We have achieved 

that goal for gray wolves in the WGL and the NRM, and today we continue to stand 

by our 2009, 2011, and 2012 final delisting rules. 

Under state management gray wolves have expanded their range and now are becoming re-established in western Oregon and Washington, and are also beginning 

to move into Northern California. Because the 1978 listing encompassed gray wolves 

in the lower 48 states and Mexico, those wolves in western Washington, western 

Oregon, and northern California, i.e., outside of the delisted NRM distinct population segment, remain fully protected under the ESA as an endangered species. 

Accordingly, in June 2013, the Service issued a proposed rule to delist the gray wolf 

throughout the remaining conterminous United States, exclusive of the now separately listed Mexican gray wolf in the Southwest. That proposed rule was dependent 

upon the gray wolf populations in the NRM and the WGL being recovered and off 

the list. However, as noted above, our delisting decisions for gray wolves in 

Wyoming and the WGL were challenged and vacated. Our ability to move forward 

with the 2013 proposal is dependent upon the Federal Government prevailing on appeal of those cases. It remains our science-based view today that the gray wolf is 

recovered in the lower 48 states, outside of the Southwest, and we should be focusing our recovery efforts on the endangered Mexican gray wolves. 

Red Wolves 

The red wolf is one of the world’s most endangered wolf species. Once common 

throughout the eastern and south-central United States, red wolf populations were 

decimated by the early part of the 20th century and reduced to coastal areas of 

Texas and Louisiana. 

When the red wolf was designated as an endangered species in 1967, the Service 

initiated efforts to conserve and recover the species. The Service began to locate and 

capture as many red wolves as possible for the purposes of establishing a program 

to breed the species in captivity and one day reintroduce the red wolf into a portion 

of its former range. From this effort, 14 red wolves became the founding members 

of the captive-breeding program and the ancestors of all red wolves existing today. 

Within a few years 12 of these red wolves were successfully reproducing in captivity, 

allowing the Service to consider reintroducing the species in the wild as a nonessential experimental population (NEP). In 1987, the Service released four malefemale pairs of red wolves to establish an experimental, nonessential population at 

Alligator River National Wildlife Refuge in the Albemarle-Pamlico Peninsula of 

14 

North Carolina. A NEP of red wolves also was established at Great Smoky 

Mountains National Park in 1991, but the Service ended that project in 1998 due 

the lack of adequate food sources for the wolves. Today, approximately 45 red 

wolves roam their native habitats in a five-county NEP area in northeastern North 

Carolina, and nearly 200 red wolves, including 29 breeding pairs, are maintained 

in over 40 captive breeding facilities throughout the United States. 

In 2013, the Service and North Carolina Wildlife Resources Commission entered 

into broad agreement acknowledging growing concerns from private landowners regarding management of red wolves and coyotes. Both agencies recognized steps were 

needed to improve management of the nonessential, experimental red wolf population, which included the need to conduct an evaluation of the Red Wolf Recovery 

Program and the implementation of its recovery actions in five counties in northeastern North Carolina. 

On September 12, 2016, the Service announced significant changes for red wolf 

recovery after a 2-year, two-step review of the entire Red Wolf Recovery Program, 

including the evaluation of the captive population and the nonessential, experimental population in North Carolina. The review began in 2014 with an independent, peer-reviewed program assessment by the Wildlife Management Institute 

and was expanded in June 2015 to include the recommendations of a red wolf recovery team that examined feasibility of recovery in the wild, population viability, red 

wolf taxonomy, the historical range, and human dimensions. 

Science and solid professional management decisions are driving future actions. 

We are pursuing recovery. One of the most significant findings of the Service’s review was that the captive population is not secure. With no changes to current management, the red wolf species will likely be lost within the next decade. More 

animals are needed in captivity to secure the species’ survival and to support any 

wild population, including the current NEP in North Carolina. 

The red wolf is a conservation-reliant species that requires intensive management. As such, the Service will implement a series of actions to secure the captive 

and wild red wolf populations. To secure the captive population, the Service will 

work with its partners to increase capacity and reach the biological goal of at least 

of 400 animals with 52 breeding pairs. Additionally, all red wolves will be managed 

as a single meta-population with occasional movement of animals between captivity 

and the wild. The Service also will be proposing to reduce the scope of the NEP to 

Federal lands within Dare County only. Focusing efforts to Federal lands is necessary to re-establish management control over the wild population by removing isolated wolf packs from lands where the Service lacks access, incorporating these 

animals into the captive population as appropriate, and managing the remaining 

animals in accessible areas to minimize and manage risks of hybridization. This will 

result, in the near term, in a smaller nonessential, experimental population in terms 

of population size, the number of packs/breeding pairs, and the area occupied, and 

a larger, more secure and genetically robust population in captivity to provide a 

solid foundation for recovery of the species. 

Recovery efforts involving reintroduction of large carnivores are inherently controversial, especially to local communities. The fact that red wolf conservation inevitably means reintroducing a large carnivore onto a landscape dominated by private 

lands (90 percent of the Southeast) makes red wolf conservation uniquely challenging. Without private landowner support, the Service will not be able to recover 

the red wolf. 

The future path for red wolf recovery announced last week reaffirms our commitment to work closely with landowners as we recover the species. The Service will 

continue its efforts to remove red wolves from private lands when requested to do 

so by the landowner. We also will continue to seek written agreements with willing 

landowners to facilitate management of the wild wolves. The Service also recognizes 

that fundamental changes are needed in the way private landowners and other 

stakeholders engage in management of wild red wolves. As such, we are working 

with the North Carolina Wildlife Resources Commission on a substantial human dimensions project that will be completed in 2017. This work is crucial to a better 

understanding and greater clarity about the different opinions and attitudes of our 

citizens. 

The complexity and scale of proposed changes for red wolf recovery will require 

more resources than what the Service and its partners have available. Therefore, 

the Service will continue to seek the support and input of private landowners as 

well as state partners, conservation groups and others when implementing the actions that will safeguard the species and eventually achieve recovery of the red wolf. 

15 

LEVERAGING PARTNERSHIPS TO FURTHER RECOVERY

Across the Service’s work on threatened and endangered species, we are actively 

engaged with conservation partners and the public in the search for improved and 

innovative ways to conserve and recover imperiled species. This is particularly true 

in our efforts to recover wolves. The Service works closely with our state, local, 

tribal, and private partners to achieve the recovery of gray wolves in the lower 48 

states and the re-establishment of Mexican and red wolves. 

Tribal Partners 

Since the NRM wolf program’s inception in the 1980s, the Blackfeet Tribe has 

been a strong supporter of and collaborator with the Service, furthering the return 

of this culturally important iconic animal to tribal lands. The tribe came to the discussion table in the early development of the recovery goals, and consistently supported those goals through several legal challenges. With financial and technical 

support from the Service, a tribal biologist worked closely with the Service on the 

ground, coordinating trapping and monitoring efforts with the Montana Department 

of Fish Wildlife and Parks and Wyoming Game and Fish Department and facilitating access to tribal lands for control actions associated with livestock depredation 

actions. This collaboration allowed the incorporation of Blackfeet culture and traditions into the management of wolves on the reservation and supported tribal 

autonomy within the bounds provided by the ESA. The strong, positive working relationship between the Service and the Blackfeet Tribe has helped the NRM wolf 

recovery program to succeed in Montana. 

The White Mountain Apache Tribe (WMAT) has been an active partner in 

Mexican wolf recovery for almost 15 years. The Service provides annual funding for 

the tribe’s Mexican wolf management and monitoring program, in accordance with 

a Service-approved management plan. The tribe’s support has been extremely beneficial to the Service due to the geographic location of their tribal land within our 

experimental population area. In addition, they have demonstrated tremendous 

leadership communicating the benefits and impacts of tribal wolf management to 

other tribes in the region. 

The Service hosts a Mexican wolf Tribal Working Group to provide opportunities 

to discuss wolf-related issues that may interest or impact the almost three dozen 

tribes in the Southwest. The Tribal Working Group contributed substantially to the 

revision of the Mexican Wolf Experimental Population rule and associated Environmental Impact Statement and is currently engaged in the development of the revised recovery plan. Through this partnership, the working group is able to advocate 

for the cultural, social, logistical, economic, and biological significance of Mexican 

wolves to the tribes. The ongoing work of the Mexican wolf Tribal Working Group 

is a particularly strong example of the Service’s focus on developing and maintaining relationships with the tribes. 

State Partners 

State fish and wildlife agencies are essential partners in implementing the ESA 

to protect our most at-risk species across the country. The state of Wisconsin first 

protected the gray wolf in 1957, 17 years prior to the wolf’s listing under the ESA. 

After the wolf was listed as federally endangered, wolves began returning, dispersing from Minnesota. The Wisconsin Departments of Natural Resources (DNR) 

started monitoring wolves in 1979 by radio-collaring and tracking wolves, surveying 

for winter tracks, and conducting summer howling surveys. State biologists such as 

those in Wisconsin are essential to monitoring efforts, as the Service typically does 

not have the personnel available to adequately collect monitoring data, trap and collar animals, and conduct other on-the-ground management activities. Despite limited personnel, the Service provides financial resources and technical expertise to 

equip states and local communities to engage in wolf monitoring and recovery. 

State agencies such as the Wisconsin DNR play an important role in fostering 

public awareness and social tolerance for wolves. State agencies are often embedded 

in the local communities and their partnership enhances the Service’s public outreach, improves citizen understanding of wolves, and increases involvement in wolf 

management. One outstanding example is Wisconsin DNR biologist Adrian 

Wydeven, who received the Service’s annual Recovery Champion reward in 2013 for 

his efforts to recover wolves in the state. Of particular note were Mr. Wydeven’s 

efforts engaging with multiple stakeholders, interest groups, and members of the 

public to create an environment in which Wisconsin’s wolf population was allowed 

to grow. 

Section 6 of the ESA directs the Service to cooperate with states to the maximum 

extent practicable to achieve recovery, and authorizes the Service to enter into 

cooperative management agreements with states. The California Department of Fish 

16 

and Wildlife (CDFW) currently has a Section 6 agreement with the Service that provides CDFW the authority to manage for the conservation of endangered or threatened species within the state, including wolves. If the Service is able to move 

forward with its 2013 proposed rule, the management of the gray wolf in California 

will be returned to the state. In anticipation of this possibility, the CDFW is initiating development of a state wolf conservation and management framework in advance of an implementable management plan. This framework, through the state’s 

Section 6 agreement with the Service, will allow CDFW to lead several aspects of 

wolf management, including investigating reports of situations involving wolves, 

monitoring wolf activity through capture and radio-collaring, and coordinating with 

other state and local entities. 

The Service works closely with the Arizona Game and Fish Department in the 

management of the Mexican wolf. This collaboration is conducted under the framework of a Memorandum of Understanding with the state and other Federal and 

state agencies, counties, and tribes. Arizona Game and Fish Department is a key 

partner in the day-to-day management of Mexican wolves in Arizona, providing education, and the development of relationships with local communities, landowners 

and livestock permittees. The Service provides annual funding to Arizona Game and 

Fish Department for assistance in managing Mexican wolves in Arizona. 

Ranchers and Livestock Producers 

Reintroduction of a top predator such as the wolf is highly complex and often controversial; the Service recognizes that there can be real economic consequences to 

livestock producers who co-exist with wolves. The Service has long held that social 

acceptance of wolves by landowners, particularly ranchers, in wolf country is an essential ingredient for wolf recovery. To encourage social acceptance, the Service has 

aggressively managed wolves that consistently prey on livestock and supports compensation to ranchers for documented livestock losses through programs such as the 

Federal Wolf-Livestock Demonstration Project, USDA’s Livestock Indemnity 

Program, and the Mexican Wolf/Livestock Council. 

In an effort to incorporate divergent views on the Mexican wolf reintroduction, the 

Service appointed an 11 member Mexican Wolf/Livestock Council in 2011, a volunteer group composed of livestock producers, tribes, environmental groups, and 

county representatives. The Council developed a strategic plan to address Mexican 

wolf-livestock conflicts. The Strategic Plan is comprised of three core strategies: payments for wolf presence, funding for conflict avoidance measures, and funding for 

depredation compensation. 

From 2011 to 2015, a total of $594,000 has been granted from the Wolf-Livestock 

Demonstration Project to Arizona Game and Fish Department and the New Mexico 

Department of Agriculture, which in turn provide the funding for allocation by the 

Mexican Wolf/Livestock Council. This funding is administered by the National Fish 

and Wildlife Foundation through Memoranda of Agreement with the states, and is 

disbursed at the direction of the Council. These Federal grants are matched with 

non-Federal funding provided by Defenders of Wildlife and Mexican Wolf Fund, 

which provide funding directly to livestock producers for implementation of 

proactive conflict avoidance measures (for example, range riders, fencing and flagging). Another $70,000 was granted from the Wolf-livestock Demonstration Program 

to the White Mountain Apache Tribe for proactive measures. 

Under the Council’s Strategic Plan, the Payments for Presence Program has provided some financial compensation to offset the additional management costs associated with the presence of wolves. This program recognizes the economic impact of 

co-existing with wolves, including undetected depredations, and changes in livestock 

behavior that can result in a reduction of weight gain and reproductive rates, and 

increased management costs. In 2014 and 2015, the Council approved payments to 

28 and 35, respectively, qualifying Arizona and New Mexico livestock operators 

totaling $85,500 to help defray the costs of managing livestock on a landscape with 

wolves. 

The Strategic Plan also provides funds to support the implementation of wolflivestock proactive conflict avoidance measures by livestock producers through 

Defenders of Wildlife and the Mexican Wolf Fund. Both organizations are members 

of the Mexican Wolf/Livestock Council and fund voluntary adaptive management 

techniques to reduce wolf-livestock conflicts. Tools and techniques such as increased 

human presence, timed calving, range riders, turbo fladry (temporary electric fencing with flagging), and use of alternate pastures are just a few of the approaches 

that have been used successfully to keep both livestock and wolves safe. 

The third strategy implemented through the Co-existence Plan is to provide compensation for livestock death or injury, including working dogs and livestock other 

than sheep and cattle. The Council has been providing compensation for confirmed 

17 

or probable livestock depredations by Mexican wolves since September 2010. This 

is done in partnership with USDA’s Wildlife Services, which investigates and confirms wolf kills before a rancher can receive compensation. The Council and the 

Service recognize that depredation compensation does not fully address the costs experienced by ranchers due to wolf presence. As a result, wildlife managers have 

placed greater emphasis on conflict avoidance in recent years to help the Mexican 

wolf population grow alongside profitable livestock operations. 

These programs implemented through the Council have helped address the economic concerns of livestock producers that have experienced wolf depredations on 

their livestock. While the Council is not able to fully compensate ranchers for the 

costs of co-existing with wolves, through the Strategic Plan, they are able to create 

incentives for livestock producers to promote viable ranching operations, selfsustaining Mexican wolf populations, and healthy western landscapes. 

CONCLUSION

In 1973, Congress provided the Nation with a strong tool to conserve and recover 

our most imperiled species and the ecosystems upon which they depend—the ESA. 

Since they were first listed in 1974, gray wolves in the WGL and NRM have rebounded from near extirpation, thanks to strong protections that guard against extinction and to the flexibility that the ESA affords the Service as managers. These 

flexibilities have allowed the Service to cultivate strong, lasting, and productive 

partnerships with a wide range of stakeholders; partnerships that have proven integral in the biological recovery of gray wolves. But it was a complex and difficult 

path, complicated by the passion that the public brings to all matters relating to 

wolf conservation, on all sides of the issue. There are some who think recovery is 

not yet achieved for these wolf populations, or that question the commitment of the 

states to manage wolves sustainably. As a result, our delisting decisions for wolves 

in Wyoming and the WGL were challenged, and the final outcome is now in the 

hands of the courts. 

In contrast, the Mexican gray wolf and the red wolf remain highly endangered. 

They were effectively extirpated from the wild and have be reintroduced into portions of their former range that now abound with threats—illegal shooting, conflicts 

with livestock production, sea level rise, genetic swamping by coyotes, low social tolerance, and many other challenges. No one said the job would be easy, and the 

Service is committed to continue the hard work of recovering the Mexican gray wolf 

and the red wolf in partnership with affected landowners, state and Federal agencies, tribes, the government of Mexico, academia, the conservation community, and 

others so that Mexican and red wolves can continue to be part of the remarkable 

natural biodiversity of the United States. 

Challenges as well as opportunities remain for wolf recovery in the Lower 48, and 

it will take continued collaboration between the Service and our partners to finish 

the work to bring these species and populations off of the Federal list of threatened 

and endangered species and return management to the states. To reduce the time 

until that day comes, wildlife managers, government agencies, and the public must 

absorb the wisdom of Leopold and ‘‘think like a mountain’’ when it comes to wolves. 

QUESTIONS SUBMITTED FOR THE RECORD TO STEVE GUERTIN, DEPUTY DIRECTOR FOR

POLICY, U.S. FISH AND WILDLIFE SERVICE

Questions Submitted by Rep. Gohmert 

Question 1. The U.S. Fish and Wildlife Service announced its intent to double the 

size of its red wolf captive breeding population, with the aim of eventually reintroducing those wolves into the wild anywhere in the region between Texas, 

Pennsylvania, and the Atlantic Ocean. Please identify the specific areas in which 

the Service is considering introduction. Please also identify the Service’s goal for 

total number of wolf reintroduction areas and the number of wolves that would 

likely be introduced in each area. 

Answer. No specific locations for reintroduction have been identified at this time. 

The Service must first secure the captive population of red wolves before considering 

the establishment of any new populations in the wild. This past September, the 

Service committed to identifying potential new sites for additional reintroduced populations by October 2017. To do so, the Service will coordinate closely with state 

fish and wildlife agencies as it works collaboratively through the recovery planning 

process to identify potentially suitable sites based on habitat characteristics. This 

would include stakeholder and partner engagement, appropriate rulemaking, and 

18 

public review and comment. The current Red Wolf Recovery Plan calls for the establishment of three wild populations. It is premature to speculate on the number of 

wolves that may be released at any future site. 

Question 2. The Service severely underestimated the habitat needed for successful 

red wolf recovery in North Carolina and Tennessee. Please explain, in thorough detail, the methodology that the Service will use to evaluate potential reintroduction 

areas throughout the region to ensure that enough habitat is available in future red 

wolf recovery efforts. 

Answer. The Service learned a great deal from its experience with red wolf reintroductions through the nonessential, experimental population in eastern North 

Carolina to date. The Service now has a much better understanding of red wolf 

habitat and space requirements, as well as other important logistical and societal 

factors that must be considered in establishing and managing a wild red wolf population. We now know the space needs of red wolves exceed the available Federal 

land base in eastern North Carolina. As such, successful reintroduction efforts must 

engage private landowners in reintroduction decisions and population management 

and must ensure that the interests and needs of the community are protected. The 

recent report by the Red Wolf Recovery Team ( https: / / www.fws.gov / redwolf / 

docs / red-wolf-recovery-team-recommendations-facilitated-by-group-solutions-inc.pdf) 

concluded that the socio-political factors related to red wolf reintroductions are as 

important as ecological factors in determining the likelihood of success. The Service 

will carefully consider these societal needs and ensure that affected communities are 

fully engaged in all potential reintroduction efforts. 

Question 3. What exactly does the Service mean when it says it will manage the 

red wolf captive breeding population as part of the nonessential, experimental population? Please explain, in detail, how this management approach will work. Service 

staff also mentioned that captive wolves will receive a ‘‘wildlife experience,’’ please 

explain the meaning of ‘‘wildlife experience’’ in this context. 

Answer. Conservation of genetic diversity is an important aspect of recovering 

species, including the red wolf. In the past, the Service’s partners in the red wolf 

Species Survival Plan managed genetic diversity within the captive populations by 

carefully selecting the wolves that will be paired for breeding purposes on an annual 

basis. This process has conserved approximately 89 percent of the genetic diversity 

represented in the 14 founding wolves. Our intention going forward is to better integrate the wild red wolf nonessential, experimental population into the overall management of genetic diversity within the entire population by bringing wild red 

wolves that are of particularly high genetic value into captivity to be paired with 

captive animals. The Service plans to manage all red wolves, both the captive breeding population and nonessential, experimental population, as a single entity. 

Animals will be moved between the captive and wild populations to maintain 

genetic diversity for both populations. 

Maintaining a wild population that is fully integrated with the captive population 

will allow for animals removed from the wild to support the necessary expansion 

and improved genetic health of the captive population and also retain some of the 

influences of natural selection on the gene pool. A wild population also would serve 

as a small stock source for new reintroduction efforts. Selecting animals that are 

believed to have the best chance of surviving the initial release, successfully establishing territories and reproducing is essential to maximize the chances for success 

of a new population of red wolves. These qualities are more likely to be found in 

wild-born or wild-fostered wolves. Additionally, any wolf released into unfamiliar 

territory faces increased risks. These risks are reduced for animals that are already 

skilled hunters, not habituated to human presence and care, and fostered in the 

wild. The chance for survival increases for introduced wolves if they have experienced living on their own in the wild. The concept of ‘‘wild experience’’ incorporates 

natural selection into captive breeding efforts as well as the fostering of captive-bred 

pups in the wild. 

Question 4. How has the Service addressed its failures to receive written consent 

of owners prior to releasing wolves on private property? How will the Service keep 

red wolves off of private property going forward? Has the Service standardized its 

procedures for dealing with wolves and/or wolf releases on private property? If so, 

please provide written documentation of those procedures. 

Answer. Before 2014, the Service did not require written consent for red wolf recovery actions on private lands. This was consistent with the 1995 governing rule 

(50 C.F.R. 17.84(c)), which did not require such written consent. During that time 

frame, however, the Service did enter into written or verbal agreements with landowners to access private lands for the management of red wolves. In 2014, and 

19 

thereafter, the Service required written consent from willing private landowners for 

all red wolf recovery actions on their properties. Also in 2014, the Service stopped 

the practice of relocating red wolves onto private lands. 

In September 2016, the Service announced it would refocus the project to Federal 

lands within Dare County, North Carolina. The Service recognizes that red wolves 

will not stay on Federal lands. Prior to the September 29, 2016, preliminary injunction by Federal Judge Terrence Boyle, the Service had committed to removing red 

wolves from private lands when requested to do so by the landowner in accordance 

with the 1995 rule. In accordance with the injunction, the Service now can only remove red wolves when there is a risk of harm to people or property. Red wolves 

removed from the landscape will be handled and cared for humanely. Some wolves 

removed from private lands would be released on Federal lands in Dare County and 

others will be relocated to a captive breeding facility. The Service will continue to 

seek written agreements with willing landowners adjacent to Federal lands to facilitate management of wild wolves. 

Question 5. The Service identified coyote hybridization as an existential threat for 

the red wolf. Does the Service have a plan for limiting hybridization in the wild? 

If so, please provide it to the committee. If not, does the Service intend to generate 

such a plan prior to additional releases of red wolves into the wild? 

Answer. The Red Wolf Adaptive Management Plan (https://www.fws.gov/redwolf/ 

Images/20130211_RWAMP_2013-2015.pdf) was developed for the express purpose of 

managing coyote genetic introgression into the red wolf population. Its components 

include monitoring of the population to identify hybrid animals for management 

action. Potential actions include removing hybrid animals from the population or 

sterilizing and releasing them for use as placeholder animals, which continue to 

hold territorial space until that animal can be replaced naturally or by management 

actions. The plan also includes an active research effort to assess the effectiveness 

of management actions so that adjustments can be made as needed. Scientific research has shown the plan to be effective in limiting hybridization. 

Question 6. Director Sandoval from the New Mexico Department of Game and 

Fish stated that the biggest contributing factor to the lack of success in Mexican 

wolf recovery efforts is the Service’s unwillingness to cooperate with the states. How 

does the Service intend to repair its poor relationship with states involved in wolf 

recovery efforts? Does the Service intend to involve states in its revised Mexican 

Wolf recovery plan? 

Answer. Throughout the initial efforts to reintroduce Mexican wolves, the Service 

has cooperated with the states of Arizona and New Mexico. Although the 

New Mexico Department of Game and Fish withdrew as a partner in the Mexican 

Wolf Recovery Program in 2011, the Service has continued to encourage them to reengage and has continued to provide information to keep them up-to-date on the 

program. New Mexico Department of Game and Fish supports the Service’s efforts 

to revise the 1982 Mexican Wolf Recovery Plan. In December 2015, the Service reinitiated efforts to develop a revised recovery plan for the Mexican wolf based on 

the best available science. We have convened workshops and worked collaboratively 

with representatives of the states of Arizona, Colorado, New Mexico, and Utah; 

Federal agencies in Mexico; the White Mountain Apache Tribe; the Forest Service; 

and independent scientists from both countries to review the biological information 

that will inform the development of the revised recovery plan. All four states have 

been extensively involved in recovery planning workshops, including biologists and 

legal counsel from the New Mexico Department of Game and Fish. Since December 

2015, we convened five recovery-planning workshops in the United States and 

Mexico; the four states participated in all five workshops, which are facilitated by 

the International Union for Conservation of Nature’s (IUCN) Conservation Breeding 

Specialist Group. In addition, the New Mexico Department of Game and Fish participated as a Cooperating Agency in the Service’s development of an Environmental 

Impact Statement (EIS) for the revision to the regulations for the nonessential experimental population of the Mexican wolf. That EIS was completed in November 

2015. 

Question 7. Does the Service intend to introduce Mexican wolves into Colorado 

and Utah? If so, how would such introductions be justified when the Service itself 

identified only the southwest corner of New Mexico and southeast Arizona as the 

northern extent of its historic range? 

Answer. We have no plans to introduce Mexican wolves into Utah or Colorado. 

Only as a final resort, after full consideration of options south of I–40, would we 

consider looking north. 

20 

Question 8. The OIG found that a Mexican wolf field team coordinator and her 

employees deliberately interfered in livestock predation investigations. Please 

provide the committee with an update about steps that the Service has taken to 

discipline and/or fire this employee. Please also provide the committee with information about how the Service plans to ensure similar interferences in predation investigations do not occur in the future. 

Answer. In 2013, prior to the OIG inquiry, the Service recognized that the 

Mexican Wolf Recovery Program was not performing adequately in some key functions pertaining to field operations and made decisive management changes to address those shortcomings, including personnel moves and hiring additional field 

staff. In order to resolve this, the Service reassigned the former Field Projects 

Coordinator to an administrative position based in Tucson, Arizona in August 2013. 

The current Field Projects Coordinator is now located in the Albuquerque, New 

Mexico office. The Field Projects Coordinator position now oversees not only the 

field operations in the current Mexican wolf population area, but also in the areas 

where the population is expected to expand, in accordance with the revised experimental population 10(j) Rule. This new organization will facilitate consistent management of all field operations under the Field Projects Coordinator as the Mexican 

wolf population expands. In 2015, the Service also hired an Interagency Field Team 

(IFT) Leader, who is located in the Alpine, Arizona IFT Office. This position directly 

supervises the Service staff in the IFT Office and reports to the Field Projects 

Coordinator. This position also coordinates directly with the other IFT staff and the 

local livestock producers, landowners, and communities to improve communications 

with stakeholders. 

Investigations of livestock depredations are typically conducted by staff of the U.S. 

Department of Agriculture-Wildlife Services (USDA-Wildlife Services), who determine the cause of death. The Service is involved only if asked by USDA-Wildlife 

Services to assist. If the USDA-Wildlife Services confirms the cause of death as a 

wolf depredation, the Service and jurisdictional IFT lead (state or tribe) review radio 

telemetry data and recent observations to determine which wolves were in the area 

at the time of the depredation. This information enables the IFT to manage the situation to deter additional depredations using a suite of management actions including hazing, trapping and translocation, and removal of wolves from the wild if 

necessary to stop chronic depredations. 

Question 9. Is there evidence of hybridization of the Mexican wolf with domesticated dogs? How will the Service ensure that hybridization of the Mexican wolf 

will not occur with dogs, coyotes, and other wolf species? Please provide all genetic 

testing results that the Service has performed on Mexican wolves. 

Answer. The Service monitors the genetics of the wild Mexican wolf population 

by taking blood samples from every canid handled, as well as through the opportunistic collection and testing of hair and scat from some areas. All samples are sent 

to the Laboratory for Ecological, Evolutionary, and Conservation Genetics at the 

University of Idaho for species confirmation, meaning the samples are analyzed to 

determine if they are from a pure Mexican wolf, pure coyote, pure dog, or hybrid. 

The Laboratory also uses DNA analyses to determine the parentage of the animal. 

In the Mexican wolf experimental population, hybridization is a rare event. Three 

confirmed hybridization events between Mexican wolves and dogs have been documented since the reintroduction project began in 1998. In the first two cases, hybrid 

litters were humanely euthanized. In the third case, four of five pups were 

humanely euthanized; the fifth pup, previously observed by project personnel but 

not captured, has not been located and its status is unknown (BRWRA Monthly 

Project Updates, June 24, 2011, https://www.fws.gov/southwest/es/mexicanwolf/ 

CEBRWRA.cfm). This pup likely died based on the age of the pup and the circumstances associated with this animal (after June of that year, the adult female 

was observed several times traveling alone, and the IFT was unable to document 

the survival of the pup. The pup was at an age (1–2 months) that would have made 

survival on its own highly unlikely. In July, the IFT captured and placed the female 

in temporary holding in an attempt to observe or capture the pup; the pup was not 

observed during this time frame or before the female was removed from the wild 

in December 2011, further indicating the pup had not survived). 

No hybridization between Mexican wolves and coyotes has been confirmed 

through our genetic monitoring of coyotes, wolves, and dogs. Our response to the 

three hybridization events with dogs has negated potential impacts to the genetic 

integrity of the experimental population from these events. Moreover, the likelihood 

of hybrid animals surviving, or having detectable impacts on wolf population genetics or viability, is low due to aspects of wolf sociality and fertility cycles. 

21 

All genetic testing results for Mexican wolves in the wild population are included 

as an attachment. It should be noted, however, that the Service does not conduct 

these analyses. Samples are sent to, and the analyses are conducted independently 

by, the Laboratory for Ecological, Evolutionary and Conservation Genetics at the 

University of Idaho. 

Question 10. Please provide the total number of captive-released Mexican wolves 

that are alive in captivity and also the total number of captive-released Mexican 

wolves that are alive in the wild. What is the maximum possible number of Mexican 

wolves, including observed first-year pups, that could be living in the wild today? 

Why did the Service stop reporting this graphically in annual IFT reports after 

2002? 

Answer. As of July 2016, there were four Mexican wolves that were born in captivity, released to the wild, and now live again in captivity. They are M863, M1049, 

M1133, and F1046. 

Our best estimate is that there was a minimum of 97 wolves in the wild as of 

December 31, 2015. 

All of the wolves alive in the wild at the end of 2015 were born in the wild. Since 

then, we have cross-fostered six pups from captivity to the wild. These captive-born 

pups were removed from their natal dens in captivity at less than 10 days old, and 

two-each were placed into three similarly aged litters in the wild. If successful, 

cross-fostering allows for captive-born pups to be placed into wild dens and be raised 

by experienced wolves in the wild. Of the six captive pups placed into wild dens in 

2016, we have confirmed at least two of them have survived. The IFT is continuing 

efforts to confirm the survival of additional cross-fostered pups. 

Mortality occurs throughout the year and is particularly high on young pups, so 

while we have documented reproduction, we will not have a complete idea of how 

many of these young pups and adults have died until the annual population survey 

conducted in the winter. Annual surveys are conducted in the winter because it is 

when the population is experiencing the least amount of natural fluctuation (i.e. in 

the spring the population increases dramatically with the birth of new pups and declines throughout the summer and fall as mortality is particularly high on young 

pups). Thus, we summarize the total number of wolves at a fairly static or consistent time of year. This allows us to establish comparable year-to-year trends at 

a time of year that accounts for most mortality and survival of young pups. 

The ‘‘maximum’’ population reported in 2002 represented the minimum documented population plus the addition of ‘‘fate-unknown wolves’’ (previously radio 

collared, but the radio collar failed and the signal was lost). Some of the fateunknown animals were likely dead, while others could be alive, and still others were 

known to be alive but could no longer be monitored via telemetry due to collar failure. Thus, this ‘‘maximum’’ number was confusing and represents a combination of 

possible fates (likely dead, likely alive, etc.) for wolves. Further, the longer an animal is considered fate-unknown, the more likely it is that the animal is dead. 

After 2002, the IFT improved methods for counting wolves in the wild. The current technique includes the use of helicopters and trail cameras to count wolves. 

Through these methods, the IFT was able to obtain evidence of the fate-unknown 

animals that were alive with a failed collar, and those that were likely dead. Thus, 

it was no longer necessary to generate a maximum population estimate based on 

fate-unknown animals. Further, the minimum population count represents the best 

trend in the population without the vagaries of fate-unknown animals accumulating 

through many years of a project. The IFT continues to expend significant resources 

counting the population, inclusive of: (1) fate-unknown animals that are determined 

to be alive; (2) uncollared animals that are associated with a collared pack; and (3) 

uncollared packs and single animals. The minimum population count, however, is 

a minimum and generally under-represents the true population by a small proportion of animals. 

Question 11. What is the average annual number of Mexican wolves that permanently disappear? Under what criteria does the Service presume a missing Mexican 

wolf is dead? Are Mexican wolves that are missing and documented as ‘‘presumed 

dead’’ tracked, tallied and compared against known mortalities? If not, please 

explain why. 

Answer. In general, the project has 2–3 radio-collared animals each year that are 

fate-unknown (radio-collared animals that have not been documented through radio 

telemetry or visual evidence for 3 months) and presumed dead. We base the presumption of death on loss of radio contact with no indication of transmitter failure, 

if subsequent bi-weekly telemetry flights and bi-monthly search flights failed to locate the animal over a large area, and if the animal failed to be observed for at least 

22 

3 months through intensive monitoring efforts. These numbers are tracked relative 

to an overall failure rate (inclusive of wolves that are determined to be dead; fateunknown and presumed dead; and removed from the wild) based on radio collar 

data and reported in each annual report since 2007. There is some uncertainty 

associated with whether or not these wolves have died, and there is complete uncertainty about the cause of death, so the number of mortalities does not include fateunknown animals, but represents a minimum number of documented mortalities 

based on actual carcasses that are found. 

Question 12. How many confirmed wild-born, first-year Mexican wolf pups have 

been observed since 1998? How many of those pups died or disappeared within the 

first year of life? What percentage of those pups are still alive today? 

Answer. For the period covering 1998–2015, 383 pups have been documented as 

wild-born. Of those, for the period covering 2005 to 2015, we have documented 323 

pups, approximately 103 of which reached adulthood; and many of those have since 

died during adulthood. The project estimates that on average, 54 percent of the pups 

that are born die prior to reaching 1 year of age (consistent with most mammal populations). Much of this mortality occurs during the first 30 days of life, and prior 

to when the IFT counts pups. Overall, roughly 32 percent of the pups we do count 

are expected to reach adulthood, and of those animals, 19 percent are expected to 

die during each year of adulthood. The 2015 end-of-year minimum population in the 

wild primarily consisted of wild-born wolves, ranging in age from ‘‘young of the 

year’’ (less than 1 year old) to 10 years old (two wolves were over 10 years old). 

***** 

The following document was submitted as an attachment to Mr. Guertin’s response 

to Chairman Gohmert’s Question 9. This document is part of the hearing record and 

is being retained in the Committee’s official files: 

Table—Mexican Wolf Genetic Results as of October 2016 

Questions Submitted by Rep. Dingell 

Question 1. On September 29, 2016, Judge Terrence Boyle in the Eastern District 

of North Carolina issued a preliminary injunction preventing the Fish and Wildlife 

Service from removing wolves from the landscape unless there is a showing of danger to people or property. In his order, Judge Boyle admonished the FWS regarding 

its duty to conserve red wolves in the wild. In light of this decision, will the FWS 

revisit its recent proposal on changes to red wolf management? 

Answer. No. The Service is committed to recovering the red wolf. We are moving 

forward with the implementation of a series of actions announced in September 

2016 to secure the captive and wild red wolf populations. We believe this strategy 

is scientifically sound and will move us toward recovery. 

Question 2. What are your management plans from now until the fall of 2017 for 

the current wild red wolf population? Do you intend to remove wolves from Pocosin 

Lakes NWR to Dare County? 

Answer. We do not anticipate removing red wolves from private or public lands 

due to Judge Boyle’s preliminary injunction. The Service will only authorize take 

of red wolves when there is a threat to human safety or to the safety of livestock 

or pets as dictated by Judge Boyle’s order. When the preliminary injunction is lifted, 

the Service will resume managing red wolves in accordance with the existing 1995 

rule and its proposed course of action to refocus red wolf recovery actions on Federal 

lands. 

Question 3. How many red wolves are currently being held in captivity? How long 

have they been held? 

Answer. Currently, there are approximately 225 red wolves in over 40 captive 

breeding facilities around the country. Red wolves have been held and bred in 

captivity at over 40 zoos and institutions around the country since 1969. 

Question 4. How many red wolves have been removed from the wild from 2014– 

2016? 

Answer. Since 2014, the Service removed nine wolves from the five-county 

nonessential, experimental population area in eastern North Carolina. 

23 

Questions Submitted by Rep. Newhouse 

Question 1. The gray wolf is an important issue to my district in Central 

Washington, where as you said the gray wolf has recently expanded its range. I 

have been frustrated by the lack of movement by the Fish & Wildlife Service to 

delist the gray wolf in the lower 48 states. In your testimony you state: ‘‘Our goal, 

consistent with our legal mandates, is to recover wolves—so that they are no longer 

threatened or endangered—and return management of those recovered wolves to the 

states.’’ However, since issuing a proposed rule to delist the gray wolf in 2013, the 

Service has not taken further action on the rule, which you state is due to several 

court decisions vacating the delisting decision. What is the status of the Federal 

Government’s appeal in those cases? Additionally, if your goal is to ‘‘return management of those recovered wolves to the states,’’ what steps can the Service take in 

the interim to help states prepare to manage their own wolf populations? 

Answer. The Service has worked tirelessly to delist recovered populations of gray 

wolves and return management to the states. For nearly a decade now, these decisions have consistently been met with legal challenges. While the Northern Rocky 

Mountain population of gray wolves (except for wolves in Wyoming) has been 

delisted and under state management since 2012, the Service’s 2011 and 2012 

determinations delisting the recovered wolves in Wyoming and the recovered population in the Western Great Lakes (WGL), were vacated by separate D.C. District 

Court judges in 2014, reinstating Endangered Species Act protections for these 

wolves. The June 13, 2013, rule to which you refer was premised upon wolves in 

Wyoming and the WGL being both recovered and delisted. At the Service’s recommendation the Department of Justice is actively appealing both of the 2014 court 

decisions and recently participated in oral arguments on September 23 and October 

18, 2016. We are now awaiting decisions from the court. 

The state wildlife agencies in Wyoming, Minnesota, Wisconsin and Michigan have 

more than sufficient experience managing wolf populations within their borders, as 

each was able to successfully implement their respective wolf management programs prior to the court reinstating Federal protections for wolves in their states. 

The Washington and Oregon wildlife agencies are currently actively managing the 

recovered and delisted wolf populations within the eastern one-third of their states 

and the Service is coordinating closely with these agencies and California Department of Fish and Wildlife to provide technical assistance, including identifying nonlethal measures (e.g., physical barriers, deployment of visual and auditory devices, 

and active hazing), to help prevent gray wolf depredations on livestock where wolves 

are federally protected. In addition, the Service administers the Wolf Livestock 

Demonstration Project Grant Program to provide grants to states and tribes to support livestock producers conducting proactive, nonlethal activities to reduce the risk 

of livestock loss due to predation by wolves and to compensate livestock producers, 

as appropriate, for livestock losses due to such predation. Washington was awarded 

funds in Fiscal Year 2015 and has been selected to receive funds for Fiscal 

Year 2016. 

Question 2. I am concerned that the Service is not treating the appeals process 

with enough urgency and is using the court decisions as a cop-out to not move forward with the 2013 proposed rule, which is strongly opposed by many environmental organizations. The proposed delisting rule states the Service ‘‘evaluated the 

classification status of gray wolves currently listed in the contiguous United States 

and Mexico under the Endangered Species Act of 1973’’ and found the ‘‘best available scientific and commercial information indicates that the currently listed entity 

is not a valid species under the Act.’’ Outside of appeals, what actions are you taking to ensure that sound science is being followed and that recovered species are 

being delisted from ESA? 

Answer. As you mention, the Service is actively participating in the appeals process and we anticipate receiving the court decisions in 2017. If we prevail in these 

cases, the Service intends to take action on our 2013 proposal, because we find that 

gray wolves in the lower 48 states, except for the Mexican wolf subspecies in the 

Southwest, are recovered and no longer warrant protection under the ESA. In the 

meantime, we find ourselves at the mercy of the courts with respect to the legal 

status of gray wolves in the lower 48 states under the ESA. 

The Service continues to make improvements to the implementation of the ESA. 

However, regardless of what we can do to improve implementation of the ESA, the 

fact is that recovery is not a simple or fast process. There will always be complicating biological and human factors to contend with. Recovery of listed species is 

often a lengthy, intricate process, reflective of the long periods of time that the 

species faced impacts leading to listing. As our world continues to evolve, climate 

24 

change impacts are felt, and our economy and populations grow, species will face 

growing threats that will impact the recovery process. With limited resources available, it is important for the Service to balance multiple mandates under the ESA, 

including preventing species from going extinct and bringing them off the list 

through recovery efforts. 

Question 3. Recently, the Profanity Peak wolf pack in eastern Washington has 

drawn considerable attention. Since July 8, the Washington Department of Fish & 

Wildlife documented at least 13 depredation events on livestock, including 

8 confirmed and 5 probable depredations. The Profanity Peak pack is located in the 

eastern-third of Washington State, where the wolf is not federally listed. 

Washington Fish & Wildlife decided to initiate a lethal removal effort of the pack 

in August and has since removed a total of six wolves. Can you discuss how the 

U.S. Fish & Wildlife Service works with state-level wildlife management agencies 

to manage wolves located in areas that are not under Federal management? How 

is the Fish & Wildlife Service working with individual state agencies to prevent 

wildlife and livestock depredations? 

Answer. State wildlife agencies manage gray wolf populations that are no longer 

listed under the Endangered Species Act due to successful recovery efforts, including 

those in Montana, Idaho, eastern Washington and Oregon, and north central Utah. 

The Service’s role in these areas has been to provide technical assistance to states 

when requested and to distribute Federal funds to prevent livestock depredations 

and compensate for livestock losses. The Service awards prevention and compensation funding to states and tribes through the Wolf Livestock Demonstration Project 

Grant Program, as described in P.L. 111–11. In 2015 the Service awarded $900,000 

in grants under this program distributed among eight states and the White 

Mountain Apache Tribe. In the coterminous United States where gray wolves are 

still listed as endangered, outside of Wyoming where wolves are listed as a nonessential experimental population, the Service’s assistance to state agencies in managing wolves is currently limited to nonlethal measures. 

In federally-listed areas, the Service works closely with state fish and wildlife 

agencies to prevent livestock depredations. Specifically in Washington, the Service 

participates in the State’s Wolf Advisory Group meetings and also meets with 

Washington Department of Fish and Wildlife (WDFW) leadership and USDA APHIS 

Wildlife Services on how depredation investigations will be handled in the listed 

portion of the state. In FY2016, the Service’s Washington Fish and Wildlife Office 

obligated $65,000 from its Recovery budget to help WDFW provide technical assistance to landowners. This was in addition to the approximately $100,000 WDFW received from the Service for livestock depredation response efforts in FY2016. In the 

listed portion of Washington State, individuals can use nonlethal munitions, including cracker shells and rubber bullets, to haze wolves near livestock; the use of these 

tools must be done in coordination with WDFW and Federal authorities. The Service 

continues to work closely with landowners and WDFW and is taking steps to increase our capacity to provide assistance with wolf deterrents and nonlethal 

measures aimed at reducing wolf-livestock conflicts in Washington. 

Other examples of the Service’s works with state-level wildlife management 

agencies includes: 

• In the listed portion of Oregon, the Service has authorized active hazing of 

wolves near livestock, including the use of rubber bullets and other management techniques that are ‘‘not reasonably anticipated to result in death or 

permanent disabling of the animal’’ in helping prevent depredation and other 

conflicts. 

• In Minnesota, where gray wolves are listed as a threatened species, the 

Service has promulgated a special rule under section 4(d) of the ESA, which 

allows state and Federal Government agents to relocate or remove wolves 

that are verified to have depredated on livestock. 

The Service works with each state to authorize and implement a state management plan that meets the state’s needs. We understand that each state has unique 

circumstances and we work with our state partners on a state-by-state basis to address their specific needs. 

Question 4. Proponents of keeping a Federal ESA listing for the gray wolf often 

argue that the wolf plays a critical role in ‘‘ecosystem balance.’’ However, one issue 

that is drawing increased attention is the impact the wolf has had on the Shiras 

Moose. When wolves were reintroduced in 1995 in the Northern Rocky Mountains, 

Federal estimates predicted the impact to these moose populations would be 

7 percent to 13 percent. However, recent reports and studies have found that Shiras 

25 

Moose populations have declined by almost 90 percent. What steps has the Service 

taken to address this growing problem and how do you plan to continue protecting 

the wolf, while also ensuring these moose populations do not decline further? 

Answer. Declines of the Shiras moose (moose) across its entire range, from 

Minnesota to the Northern Rockies, have been well studied over the past decade. 

The reasons for the decline of the moose are primarily loss of habitat and impacts 

associated with climate change (leading to parasite load issues directly impacting 

health and vigor), in conjunction with the secondary impact of predation. For example, research has demonstrated substantial declines in moose in many local areas 

where wolves do not exist and predation is not an issue. Consequently, the best 

available science does not support a cause-effect relationship between wolf numbers 

and decline (or increase) of Shiras moose in Wyoming. 

In Wyoming, and the Jackson/Yellowstone area in particular, nutritional deficiencies and habitat loss have largely been responsible for the decline of the moose. 

Subsequently, wolves have been able to exploit vulnerable Shiras moose in this area 

and, thus, contributed to the decline. However, predation by wolves has been opportunistic and not the primary cause. 

Delisting has allowed significant state flexibility in its management of the gray 

wolf population in the Northern Rocky Mountains. While the delisting rule was vacated for gray wolves in Wyoming, that case is on appeal. It remains the Service’s 

view that the entire Northern Rocky Mountains gray wolf population is biologically 

recovered and therefore management of the entire population should belong to the 

states. We remain confident that the states will be successful in achieving a reasonable balance between the needs of a recovered wolf population and other public 

needs. 

Question 5. In a state like Washington, with split management of gray wolves and 

a state plan with recovery goals in excess of Federal requirements, could a Section 

4d exemption possibly help to add consistency and ensure that wolf populations 

across the state are all benefiting from successful state management? 

Answer. The WDFW is currently managing gray wolves in the eastern one-third 

of the state, which was delisted along with the rest of the Northern Rocky Mountain 

gray wolf population (except for Wyoming) in 2012. The western two-thirds of the 

state and any wolves that may occur there are part of the broader gray wolf listing 

which has a legal status of endangered under the ESA. When a species is listed as 

endangered, all the take prohibitions (section 9) of the ESA apply. Section 4(d) does 

allow the Service to issue a rule that establishes specific prohibitions and exceptions 

that are tailored to the specific conservation needs of threatened species. Section 

4(d) of the ESA applies only to species listed as threatened; this authority does not 

apply to species listed as endangered, such as the gray wolf. 

While a section 4(d) rule is not currently an option for consideration, the Service 

is actively working with WDFW and providing technical expertise regarding appropriate nonlethal measures (e.g., physical barriers, deployment of visual and auditory 

devices, and active hazing) that may be used to help prevent depredation on livestock within the state. In addition, the Service administers the Wolf Livestock Demonstration Project Grant Program to provide grants to states and tribes to support 

livestock producers conducting proactive, nonlethal activities to reduce the risk of 

livestock loss due to predation by wolves and to compensate livestock producers, as 

appropriate, for livestock losses due to such predation. Washington was awarded 

funds in Fiscal Year 2015 and has been selected to receive funds for Fiscal 

Year 2016. 

Questions Submitted by Rep. Pearce 

Question 1. The Department of the Interior (DOI) Inspector General (IG) Report 

from June 29, 2016 states on page 8 that the IFT coordinator of the Mexican Gray 

Wolf Recovery Program (MGWRP) did not know the difference between an Alaskan 

Gray Wolf and a Mexican Gray Wolf, despite the significant differences. 

a. Why did the Fish and Wildlife Service (FWS) hire someone that could not even 

make this simple distinction? 

Answer. The statement in the OIG Report is: ‘‘The former IFT member felt that 

the former IFT coordinator, who had worked with wolves in Alaska, had been unprepared to assume the role of coordinator because she did not understand the differences between Alaskan and Mexican wolves, but then did not listen to those who 

did understand and offered to help her.’’ The context of this statement was to note 

that there are management differences between gray wolves in Alaska (where the 

26 

Former IFT Coordinator managed them on a National Wildlife Refuge), and 

Mexican wolves on working landscapes in the Southwest. 

b. Is it a common practice for the FWS to hire coordinators that are not familiar 

with the species they are tasked with recovering? 

Answer. See response above. 

Question 2. In Director Ashe’s letter addressed to me on September 2, 2016 he 

claims that the current IFT coordinator spends roughly ‘‘50 percent’’ of his time 

‘‘working on issues specifically related to Grant and Catron counties.’’ However, in 

the travel logs sent by the FWS to my office it appears the IFT coordinator only 

made three visits to New Mexico from January 2014 through August 2016. He also 

made 49 trips to Arizona. 

a. Could you explain why he spends so much time in Arizona and not 

New Mexico? 

Answer. The Mexican Wolf IFT office has been located in Alpine, Arizona since 

the reintroduction program began in 1998. The Field Projects Coordinator (termed 

above as IFT Coordinator) usually stays in a hotel in Alpine, Arizona when he travels to work out of the IFT office. The Field Projects Coordinator’s official travel location, therefore, is accurately shown as Alpine, Arizona. From the Alpine IFT office 

(which is located near the border of Arizona and New Mexico), the IFT manages 

wolves in both Arizona and New Mexico (although as of this year, the Arizona Game 

and Fish Department conducts most of the wolf management in Arizona out of an 

office in Pinetop, Arizona). The Arizona Game and Fish Department staff conducts 

most of the management of Mexican wolves in Arizona, and, following the departure 

of the New Mexico Department of Game and Fish Department from the recovery 

program in 2011, Service employees conduct most of the management of Mexican 

wolves in New Mexico. The Field Projects Coordinator spends additional time traveling to sites in New Mexico within a single day, which does not require travel 

expenses. The Coordinator also spends time talking to landowners, livestock producers, and others in New Mexico regarding Mexican wolf management issues by 

phone. 

b. How does the coordinator travel from Albuquerque, where he’s stationed, to 

Arizona? 

Answer. The IFT Coordinator travels to the Alpine IFT Field Office and conducts 

field work from a government vehicle. 

c. When he travels to Arizona, does he stay overnight? If so, please provide logs 

for overnight stay. 

Answer. In general, the Field Projects Coordinator stays overnight when he travels to the Alpine Field Office. The travel log included in the Director’s September 

2, 2016 response, which was derived from the government’s Concur travel program, 

provided the dates on which the IFT Field Projects Coordinator stayed overnight in 

Arizona. The travel log is included as an attachment. 

***** 

The following document was submitted as an attachment to Mr. Guertin’s response 

to Rep. Pearce’s Question 2c. This document is part of the hearing record and is 

being retained in the Committee’s official files: 

Table—Log of Current IFT Coordinator Travel 

Questions Submitted by Sen. Tillis 

Question 1. A report on the Red Wolf Program recently released by the Office of 

the Inspector General found that the Fish and Wildlife Service violated its rule by 

releasing 132 wolves into the wild between 1987 and 2013 when the rule had only 

provided for the release of 12 wolves. Furthermore, many of these wolves were released on private lands without permission from the landowners, something the 

Fish and Wildlife Service maintained it was not going to do. 

a. Normally, if the shoe were on the other foot and it was a private landowner 

violating breaking a law or Federal regulation, there would be some sort of recourse. 

Answer. In 2014, the Service acknowledged it made some mistakes in its management of the Red Wolf Recovery Program. In those past instances, the Service only 

released wolves on private lands with agreements—either written or verbal—to do 

so. Since then, the Service has managed the nonessential, experimental population 

27 

in eastern North Carolina in accordance with the 1995 rule (50 C.F.R. 17.84(c)). The 

Service is no longer releasing wolves on private lands. 

b. What action did Fish and Wildlife take to correct this clear and obvious 

violation of its own rules? 

Answer. Over the past 3 years, the Service has conducted comprehensive reviews 

of the Red Wolf Recovery Program, ensured the program is in compliance with 

enacted rules, and reorganized the program to avoid future deviations from the existing rules. The Service also is complying with Judge Boyle’s order. 

Question 2. As Fish and Wildlife attempted to manage its nonexperimental population of wolves and secure that population on Federal lands, the Agency made the 

promise that it would remove Red Wolves found to be on private lands at the landowners’ request. Additionally, the Fish and Wildlife Service has stated that it would 

issue private take permits to landowners for the landowners to trap the wolves to 

be returned to the Agency. 

a. How many landowners made requests to the Fish and Wildlife Service to have 

wolves removed from private lands? 

Answer. The Service has received six requests to remove red wolves from private 

lands as of October 2016. In previous years, the number of these requests has been 

less than 10 per year with the exception of 2014 when the Service received 405 

requests. In 2014, the Service received several petitions with multiple signatures requesting removal of red wolves from private properties. Upon contacting each requestor, the Service determined that many of the landowners had no evidence that 

red wolves were on their property. Several requestors also indicated that they were 

unaware of the purpose of the petitions. 

b. How many special take permits have been applied for? 

Answer. The Service does not issue trapping permits to private landowners for the 

removal of red wolves since the agency or agents of the Service, including private 

trappers, conducts the trapping operations. When trapping efforts are abandoned, 

the Service may issue an authorization to take a red wolf by lethal means. 

c. How many special take permits have been issued by the Agency? 

Answer. As of October 2016, the Service has issued five lethal take authorizations 

affecting three properties. 

Question 3. Mr. Myers’ mentions in his testimony that the flooding at the Pocosin 

Lakes Wildlife Refuge may have adversely impacted its suitability to support the 

wild wolf population. 

a. What is the condition of that refuge now given the ongoing hydrology 

restoration efforts? 

Answer. The Service is taking a science-based approach working with hydrologists 

to restore the natural hydrology and rewetting pocosin peat soils at the Pocosin 

National Wildlife Refuge (Refuge). Since the Refuge was established in 1991, the 

Service has been working to restore the pocosin peat soils in three of the most significantly ditched and drained areas affecting nearly a third of the Refuge’s 110,107 

acres. Restoration activities include raising the elevation of existing berms and installing flashboard riser water control structures in strategic locations. The Service 

will then use this infrastructure to stop the artificial drainage of rainwater from the 

peat soils through the ditch system. The new infrastructure enables the Refuge to 

rewet historically drained peatlands and return lands to a natural, seasonally saturated condition. Within the restored area, low-lying areas where standing water 

may be present seasonally are expected and may be acceptable for foraging and 

hunting by terrestrial wildlife, including red wolves. The flooding recently experienced on the Refuge and adjacent private lands is the result of excessive amounts 

of rain falling on lands already saturated by repeated tropical events including 

Hurricane Matthew aggravating conditions in ditches, creeks, and sounds, already 

full from previous rain events. No management strategy would prevent localized 

flooding on or off the Refuge under these conditions. We are working diligently with 

adjacent landowners to ensure a better understanding of the hydrology restoration 

effort and to identify opportunities of mutual interest that have great potential to 

improve drainage conditions for these landowners. 

b. How many wolves are currently living on the Refuge? 

Answer. Five adult red wolves are known to use portions of the Refuge. We are 

uncertain as to the number of pups potentially born in 2015 or 2016 that may use 

portions of the Refuge at this time. 

28 

Question 4. It is my understanding that the Fish and Wildlife Service can account 

for less than 30 wild wolves with collars and have estimated that there are about 

15 more wolves whose whereabouts are unknown. 

a. What steps will the Agency make to recover these 15 ‘‘missing’’ wolves? 

Answer. The current wild population estimate is approximately 45 wolves, including the known number of animals (28 radio collared wolves) and a percentage of the 

number of observed puppies born this spring that were PIT tagged but not collared 

because they were too small. The exact number of these young animals that survive 

their first year of life will not be known until they are old enough to be safely 

trapped. However, trapping cannot occur until the existing Federal court injunction 

has been lifted. Additionally, there are a small, but unknown, number of animals 

that avoid being trapped and are undetected on the landscape, as well as animals 

that inhabit lands to which we do not have access. 

b. If the Agency already has difficulty tracking the collared wolves that are out 

there, how can I and private landowners be assured that a wolves will be accurately 

tracked and kept off private lands in any future non-experimental population site 

that are created? 

Answer. The Service is able to closely monitor the wild population when its biologists can trap and fit adult red wolves with tracking collars. In recent years, 

reduced access to private lands has limited the Agency’s ability to find red wolf litters and conduct trapping operations that would allow for a more accurate account 

of the wild population and movement of red wolves on the landscape. Additionally, 

the recent injunction has further limited the Service’s ability to trap wolves for 

monitoring activities. 

Mr. GOHMERT. Thank you. 

At this time, Mr. Myers, you are recognized for 5 minutes. 

STATEMENT OF GORDON MYERS, EXECUTIVE DIRECTOR, 

NORTH CAROLINA WILDLIFE RESOURCES COMMISSION, 

RALEIGH, NORTH CAROLINA 

Mr. MYERS. Chairman Gohmert, Ranking Member Dingell, and 

members of the subcommittee, thank you for the opportunity to 

come before you today to provide testimony regarding red wolf 

management in North Carolina. Wolf management in North 

Carolina is currently at a key decision point. 

Let me first take you back four decades ago, when the U.S. Fish 

and Wildlife Service redirected its efforts to remove red wolves 

from the wild, from protecting animals in the wild, to a planned 

removal of the species from the wild, thus establishing the species 

survival captive breeding program. This extreme decision to forcibly extirpate wolves highlighted a clear and present danger of extinction, due to hybridization with coyotes. These steps were taken 

with hopes of identifying a future reintroduction site. 

In 1986, the Service promulgated rules that authorized taking 

wolves from the captive breeding program to establish a reintroduction experiment on Federal lands in northeastern North Carolina. 

The location was selected for the following key reasons: it met the 

recovery plan goal of abundant and Federal lands with habitat and 

prey-based characteristics, presumed to be suitable for red wolves; 

the surrounding area had a relatively low human population; and 

coyotes were practically non-existent on the landscape, which supported the recovery objective that the population be self-sustaining. 

The reintroduction was designated a nonessential experimental 

population in accordance with section 10(j) of the Endangered 

Species Act. It was nonessential because the red wolf was secure 

29 

in the captive breeding program. Because of public comments about 

possible adverse impacts to the species by removing wolves from 

captivity, the Service’s final rule stated they would limit their releases to no more than 12 wolves. 

However, according to Service records, 165 wolves had been released between 1986 and 2014, of which 130 came from the captive 

breeding program and 64 were released onto private lands, an action that was also not authorized in the Service’s rules, nor is it 

congruent with the goal of managing red wolves on Federal lands. 

In the 29-year period since the reintroduction, active management of red wolf habitat has been minimal. In fact, hydrology 

manipulation at Pocosin Lakes National Wildlife Refuge may very 

well have adversely impacted the use of those lands by wolves, the 

wolves that persisted predominantly on private lands, which is not 

in harmony with achieving the explicit goal to manage the red wolf 

experiment on Federal lands. 

Under the rules that applied to the red wolf reintroduction, the 

Service must remove unwanted wolves from private land upon 

which the landowner requests. The Commission has recently 

worked with the Service to try to fulfill this requirement. However, 

most efforts have proven ineffective, largely due to the tremendous 

challenges of capturing wolves and their propensity to quickly return to those private lands after being released again on Federal 

lands. It is essentially a revolving door. 

On September 12, 2016, the Service issued a new call to action 

as it announced recommended decisions in response to an ongoing 

evaluation of the red wolf recovery program. The Service’s decision 

memorandum states the wild red wolf population is projected to 

crash in as few as 8 years. It further concedes the species is currently not secure in captivity, and recommends the captive breeding population be increased to approximately 400 animals with a 

minimum of 52 breeding pairs. 

The Service has identified this change as its highest priority for 

the red wolf recovery program. As of January 1, 2015, the captive 

population contained 207 wolves and 29 breeding pairs, which is 

far short of identified needs. The Service’s recommendation to 

maintain a small population of intensively-managed wolves on 

Federal lands in Dare County is inconsistent with the captive 

breeding population objectives. 

Today, nearly 30 years after the first reintroductions, and despite 

tubal ligations and vasectomies of coyotes, releases of 165 wolves, 

including 58 in Dare County, there is only one known wolf pack occupying Federal lands. Meanwhile, in the 10-year period from 2002 

to 2012, reported numbers of coyotes trapped statewide has increased 2,600 percent in North Carolina. The degree of intensive 

management required to recapture wolves that leave Federal lands 

or to address the perpetual threat of hybridization with coyotes 

would encumber the critical and limited financial and human resources necessary to expand the capacity within the captive breeding program. 

The Commission believes there is once again a clear and present 

danger of species extinction, and the best decision to safeguard the 

red wolf is to capture the remaining wolves from northeastern 

North Carolina, safely secure them in a captive breeding program, 

30 

and redirect available resources toward increasing the capacity of 

those facilities while sorting out the red wolf taxonomy. 

Once again, thank you very much for this opportunity to appear 

here today. 

[The prepared statement of Mr. Myers follows:] 

PREPARED STATEMENT OF GORDON MYERS, EXECUTIVE DIRECTOR, NORTH CAROLINA

WILDLIFE RESOURCES COMMISSION

INTRODUCTION

Chairman Gohmert, Ranking Member Dingell, and members of the subcommittee, 

I am Gordon Myers, Executive Director of the North Carolina Wildlife Resources 

Commission (Commission), a state agency whose mission is to conserve North 

Carolina’s wildlife resources and their habitats and provide programs and opportunities that allow hunters, anglers, boaters and other outdoor enthusiasts to enjoy 

wildlife-associated recreation. I am grateful for the opportunity to come before you 

to provide testimony regarding red wolf management in the state of North Carolina. 

BACKGROUND

During the fall of 1973, the U.S. Fish and Wildlife Service (Service) established 

a recovery program for the red wolf (Canis rufus) based on belief that a pure population of red wolves still existed in southeast Texas and adjacent areas of Louisiana. 

Field work revealed extensive hybridization with coyotes across the limited remaining red wolf range. Hybridization with coyotes threatened the continued existence 

of the species. Therefore, all recovery efforts were redirected from protecting 

animals in the wild to a planned extirpation of the species from the wild. This extreme decision to extirpate red wolves from the wild highlighted the immediate and 

significant threat of inter-specific breeding with coyotes. The removal of the species 

from the wild was accompanied by a long-range objective to eventually return the 

species to areas of its historic range. 

Between the fall of 1973 and July 1980, the Service captured and examined more 

than 400 wild canids from which only 14 animals became the founding stock for the 

Red Wolf Species Survival Captive Breeding Program (SSP). Red wolves were declared extinct in the wild in 1980. Today, 12 founder lines are represented in the 

wild and captive populations. As of January 1, 2015 the SSP included 207 wolves 

and 44 institutions. 

After the species was believed to be safeguarded in captivity, the Service conducted small-scale reintroduction experiments in 1976 and 1978. The Service then 

released mated pairs of red wolves onto Bulls Island, a 4,909-acre component of the 

Cape Remain National Wildlife Refuge near Charleston, South Carolina. The results 

of these releases indicated potential feasibility of establishing adult wild-caught red 

wolves in selected habitats in the wild. 

SETTING UP THE EXPERIMENT IN NORTH CAROLINA

In 1986 the Service promulgated rules that would use wolves sourced from the 

SSP captive breeding program to establish a reintroduction experiment at Alligator 

River National Wildlife Refuge (ARNWR) located in Dare and Tyrrell Counties, 

North Carolina. 

ARNWR was selected as an experimental reintroduction site for the following key reasons: 

1. Abundance of Federal lands with habitat and prey base characteristics 

presumed to be suitable for red wolves 

2. Relatively low human population 

3. Absence of coyotes on the landscape 

The final special rule published in the Federal Register on November 19, 1986 

provided guidelines and sideboards for the experimental reintroduction. Those rules 

designated the red wolf reintroduction as a nonessential experimental population 

(NEP) in accordance with section 10(j) of the Endangered Species Act (ESA). Under 

the ESA, the Secretary of the Department of the Interior is required to determine 

whether or not the population is essential to the continued existence the species. 

In the case of red wolf, it was determined that despite extirpation from the wild, 

the red wolf was secure in the SSP captive breeding program. Notably, in response 

to public comments expressing concern about potential adverse impacts resulting 

from removing animals from the SSP captive breeding program and introducing 

31 

them into ARNWR, the Service responded in the final rules that they would limit 

their release of wolves to no more than 12 animals. Further, the Service stated the 

refuge and adjacent U.S. Air Force lands could eventually sustain a red wolf population of 25 to 35 animals. In 1995, the Service amended its special rule to include 

additional Federal lands. The Service stated the reintroduction area probably could 

not support 30 wolves for an extended period of time; however, the addition of 

Pocosin Lakes National Wildlife Refuge (PLNWR) would add approximately 112,000 

acres to the reintroduction area. The Service estimated the additional refuge lands 

could support 15 to 25 wolves. Thus, based on the 1995 rule, the Service estimated 

a total carrying capacity of 55 wolves on Federal lands. 

The Red Wolf Recovery Plan institutes the clear goal that the nonessential experimental population of red wolves introduced into northeastern North Carolina 

(NENC) should be managed on ‘‘Federal lands.’’ Further, the recovery plan explicitly 

states the objective that the population be ‘‘self-sustaining.’’ The Service’s 1986, 

1991, and 1995 special rules for the red wolf NEP incorporate this goal and 

objective. 

CONDUCTING THE EXPERIMENT IN NORTH CAROLINA

According to Service records 165 wolves were released into the NENC population 

between 1986 and 2014, 130 of which came from the SSP captive breeding program, 

far exceeding the 12 wolves noted in the 1986 final rules. Further, of those releases, 

64 occurred on private lands—an action that is not authorized in the Service’s rules 

nor is it congruent with the goal of managing wolves on Federal lands. 

In the 29-year period since the reintroduction of red wolves into NENC, active 

management of habitat for red wolves has been minimal. Consequently, wolves have 

persisted predominantly on private lands. As evidenced by research, red wolves are 

more likely to utilize agricultural fields than all other habitat types combined. Early 

successional fields comprise the second most likely utilized habitat type. Both of 

these habitat types are primarily found on privately-owned lands within the reintroduction area. This well documented persistence on private land is not in harmony 

with achieving the explicit goal set forth in the Red Wolf Recovery Plan that the 

red wolf population in NENC should be managed on ‘‘Federal lands.’’ 

Because the population of red wolves reintroduced to NENC was determined to 

be a nonessential experimental population in accordance with Section 10(j) of the 

ESA, the final special rules included circumstances under which take of the species 

was authorized. Those take provisions were promulgated in accordance with Section 

4(d) of the ESA. 

Under the special rules that apply to the NENC NEP red wolf population, the 

Service stated ‘‘programs to purposely reintroduce predators, such as the red wolf, 

must be accompanied by provisions to protect private property from the presence of 

such reintroduced animals if the landowner does not want them on his property.’’ 

Accordingly, those rules incorporate the requirement that the Service remove unwanted wolves from private land upon request of the landowner. The Commission 

has worked closely with the Service to try to fulfill this requirement; however, most 

efforts have proven to be ineffective, largely due to the tremendous challenges associated with recapturing animals and the propensity for animals to return to the 

vicinity of their capture subsequent being released again on Federal lands. 

The special rules also allow direct and incidental take of red wolves by landowners under certain circumstances, including incidental take pursuant to lawful 

harvest of coyotes. Despite those explicit provisions, the Commission was sued in 

Federal court for adopting state regulations that allowed coyote hunting at night 

statewide. Ironically, a court ordered injunction provided greater Federal protection 

to non-native coyotes than to the red wolf. Ultimately, the state entered into a 

settlement agreement that restored coyote hunting during daylight hours, but maintained a prohibition against hunting coyotes at night within the five-county 

reintroduction area. 

LESSONS LEARNED

The NENC NEP is one of two attempts to reintroduce red wolves in to the wild. 

The other experiment in Great Smoky Mountains National Park located in the 

North Carolina-Tennessee mountains failed, in part, due to lack of access to key 

land areas, including private lands. The Service terminated the experiment in 1998 

based on low pup survival and the inability of the wolves to persist on Federal 

lands. 

The NENC experiment and associated regulations were not designed to achieve 

a recovery scale population. Instead, the experiment provided an opportunity to test 

goals incorporated into the Red Wolf Recovery Plan. Specifically, the Federal lands 

32 

in NENC provided a crucial living laboratory to test if red wolves could achieve wild 

reproduction, become self-sustaining, and persist on Federal lands. 

Perhaps one of the greatest accomplishments of the NENC NEP was to prove that 

captive red wolves could be introduced into and reproduce in the wild. Prior to the 

proliferation of coyotes on the landscape, there were some indications that the red 

wolf may become self-sustaining over time; however, coyote interactions drastically 

deceased if not eliminated this feasibility. 

With the continued expansion of coyote ranges in the continental United States, 

including eastern North Carolina, the threat of genetic introgression of coyotes into 

the NENC red wolf population increased throughout the 1990s and the first known 

hybridization event occurred in 1993. In 1999, similar to the 1970s, the Service 

declared hybridization with coyotes the greatest threat to red wolf recovery. North 

Carolina hunting and trapping records provide state-level indices of harvest. In the 

10-year period from 2002 to 2012, reported numbers of coyotes trapped statewide 

increased from 133 to 3458, an increase of 2600 percent. In the five counties comprising the red wolf reintroduction area, reported harvest increased from 0 to 138 

coyotes between 2004 and 2012. For the foreseeable future, it appears the hypothesis that red wolves can become self-sustaining, particular within landscapes that 

include coyotes, has been disproven. 

There is an abundance of data that clearly indicates red wolves cannot be managed to stay on Federal lands. Furthermore, significant resources are necessary to 

attempt to meet such expectations and to date, no management scheme has proven 

effective to meet the expectations of private landowners. Today, nearly 30 years 

after the first reintroductions in Dare, there is one known wolf pack occupying 

Federal lands, despite releases of 58 wolves into Dare County. It is clear that any 

success future reintroductions must be accompanied by participation and support of 

private landowners. Realistic expectations, predictability, responsiveness, and accountability are essential to sustaining support. 

CURRENT STATUS

On September 12, 2016, the Service announced recommended decisions in response to an ongoing evaluation of the Red Wolf Recovery Program. The Service’s 

decision memo acknowledges growing concerns from private landowners regarding 

management of the Service’s NENC project and the collaborative commitment between the Service and the Commission to develop a canid management strategy. 

The memo further outlines the actions taken by the Service in the past 3 years to 

evaluate the program. 

The decision memo describes decision options and recommendations for the overall Red Wolf Recovery Program and the NENC NEP. The memo includes important 

information regarding the current status of the SSP captive breeding population and 

the NENC NEP. This information from a report released June 10, 2016 by the Red 

Wolf Population Viability Analysis (PVA) workgroup is the most up-to-date 

information currently available. 

With regard to the NENC NEP, the Service recommends reducing the focus of the 

NENC NEP to Federal lands within Dare County, removing isolated wolf packs 

from lands to which the Service lacks access, incorporating those animals into the 

SSP captive breeding program, and to better manage the remaining animals to the 

Federal lands in Dare County. 

The June 10, 2016 PVA workgroup report indicates that under conditions modeled 

in the baseline scenario, the SSP captive breeding population has a moderate chance 

(65.7 percent) of maintaining the genetic diversity for at least 150 years as set forth 

in the Red Wolf Recovery Plan. Further, under conditions modeled for the NENC 

NEP in the baseline scenario, the population is projected to crash in as few as 

8 years. The PVA workgroup modeled a range of permutations to examine options 

that would improve chances for success. Of the model simulations, the permutations 

that reflected an increase to 400 animals in the SSP captive population indicate the 

best chances for successfully maintaining red wolf genetics as set forth in the red 

wolf recovery plan. In fact, the scenario under which the SSP captive breeding program capacity is increased to 400 animals and all NENC NEP wolves are brought 

into program yielded a 91.2 percent chance of maintaining the genetic diversity for 

at least 150 years as set forth in the Red Wolf Recovery Plan. There were several 

other model scenarios that yielded a greater than 90 percent chance of success, but 

each scenario was based on the operational premise that captive breeding success 

could be increased more than 30 percent from 19 percent to 25 percent. 

The Service’s decision memorandum states the species is not secured in captivity 

and the SSP captive breeding population must increase to approximately 400 

animals with a minimum of 52 breeding pairs. It further states this is the number 

33 

one management priority for the red wolf recovery program and that if the situation 

is not managed immediately, the entire species would be in peril. It is notable that 

the fundamental basis of establishing the NENC NEP was the red wolf was secure 

in captivity. 

The Service’s recommendation to maintain a small population of intensively 

managed wild wolves as part of an SSP captive breeding program meta-population 

is incongruent with this priority. Intensive management required to address the 

perpetual risks of hybridization with coyotes and to recapture wolves that leave 

Federal lands will encumber critical financial and human resources that should be 

used to expand capacity within the SSP captive breeding program. Recall that hybridization with coyotes was the impetus for forced extirpation of red wolves from 

the wild three decades ago. Further, the recent PVA report indicates the NENC 

NEP has a 2.38 times higher risk of mortality than the SSP captive population. 

The Commission believes there currently exists a clear and present danger of 

species extinction and the best decision for safeguarding the red wolf is to capture 

the remaining wolves in the NENC, safely secure them in the SSP captive breeding 

program, and redirect resources toward increasing the capacity of the SSP facilities. 

QUESTIONS SUBMITTED FOR THE RECORD BY SEN. TILLIS TO GORDON MYERS, 

DIRECTOR, NORTH CAROLINA WILDLIFE RESOURCES COMMISSION

Question 1. How closely do you believe the Fish and Wildlife Service is following 

its own rules and regulations pertaining to the program? 

Answer. The U.S. Fish and Wildlife Service (Service) and the North Carolina 

Wildlife Resources Commission (Commission) pledged to collaborate on management 

of canid species throughout the Albermarle Peninsula in November 2013. Although 

the Service leadership in the Southeast Region Office has demonstrated commitment to following the its own rules pertaining to the program during the past 3 

years, it is very clear the Service’s own rules pertaining to its nonessential experimental population of red wolves are fundamentally unrealistic. The Red Wolf 

Recovery Plan institutes the clear goal that the nonessential experimental population of red wolves introduced into northeastern North Carolina should be managed 

on ‘‘Federal lands.’’ Further, the recovery plan explicitly states the objective that the 

population be ‘‘self-sustaining.’’ The Service’s 1986, 1991, and 1995 special rules for 

the red wolf NEP incorporate this goal and objective. Both foundational elements 

have been undeniably disproven. Instead, red wolves predominantly persist on 

private lands. 

Further, the Service established in their 1986 rules that only 12 wolves would be 

released from captivity; however, according to Service records 165 wolves were released into the NENC population between 1986 and 2014, 130 of which came from 

the captive breeding program. Further, of those releases, 64 occurred on private 

lands—an action that is clearly not authorized in the Service’s rules nor is it 

congruent with the goal of managing wolves on Federal lands. 

The following is excerpted from a Wildlife Management Institute (WMI) report 

from November 2014: 

‘‘We learned that program authority rested largely with local staff. Decisions 

made at the local level . . . did not always comply with the rules established 

for the reintroduction program.’’ 

‘‘FWS staff reported to WMI that some red wolves were released on private 

property . . . These actions appear to conflict with the 10(j) Rule that stated 

red wolves would be released on the Alligator River NWR property.’’ 

‘‘The 10(j) Rules also stated that, at the request of the landowner, wolves 

would be captured on private property and returned to the refuge property. 

WMI found that it was a common practice to inform landowners that wolves 

would not stay on the refuge and would probably return to private property. 

Some wolves captured on private property were released on private property 

rather than returned to the refuge lands. These activities were contradictory 

to the 10(j) Rules established at the onset of the recovery program. WMI concluded that the authors of the rules were either misinformed about red wolf 

dispersal behavior or were unconcerned if the rules were violated. Local 

program staff was asked to comply with rules that were untenable.’’ 

34 

Question 1a. Has the Fish and Wildlife Service made good on the commitments 

it made to private landowners? 

Answer. In my opinion, the Service has not and cannot make good on the 

commitments it made to the private landowners. 

Question 2. Do you consider doubling the wolf population and identifying 

additional non-experimental population sites as a shutdown of the program? 

Answer. Doubling the wolf population and identifying additional locations to 

establish experimental populations is not in any way a ‘‘shutdown of the program.’’ 

Question 3. Based on the conclusions made in the Red Wolf report Fish and 

Wildlife Service released last week, what recommendation would the North Carolina 

Wildlife Resources Commission have made as to the future of the Red Wolf 

program? 

Answer. Based on information from the program evaluation conducted by WMI 

and released in November 2014; a recent scientific report regarding red wolf taxonomy released in July 2016; and a red wolf population viability analysis released 

in June 2016, the Commission recommends several actions for the Red Wolf 

Recovery Program, including the nonessential experimental population of red wolves 

located in northeastern North Carolina. Specifically, the Commission recommends 

the Service contract with an independent scientific organization such as the 

National Academy of Sciences to conduct a scientific review of the Red Wolf 

Recovery Program, including evaluation of red wolf taxonomy using whole-genome 

sequence analysis to determine uniqueness of red wolf ancestry and appropriateness 

of listing red wolf under the Endangered Species Act. Because the primary and existential threat to red wolf recovery is hybridization with coyotes, we believe the evaluation must also examine efficacy of methods to address the threats of hybridization 

with coyotes; and consider the extent and duration of conservation reliance needed 

to achieve recovery goals. Finally, the Commission recommends the Service terminate or suspend the Nonessential Experimental red wolf project in North Carolina 

and redirect available red wolf recovery resources to address deficiencies of the Red 

Wolf Species Survival Plan captive breeding program. 

Question 4. How well has the Fish and Wildlife Service worked with your Agency 

when it comes to making decisions regarding the management of the Red Wolf 

program? 

Answer. In the past 3 years, the Service leadership has been very forthright in 

its communication and collaboration regarding on the ground management of the 

nonessential experimental population of red wolves; however, it is not very clear if 

our perspectives related to future red wolf program management have been fully 

considered. 

Mr. GOHMERT. Thank you very much. 

Director Moore, you are recognized for 5 minutes. 

STATEMENT OF VIRGIL MOORE, DIRECTOR, IDAHO 

DEPARTMENT OF FISH AND GAME, BOISE, IDAHO 

Mr. MOORE. Thank you, Mr. Chairman and members of the 

committee. I will begin by describing Idaho’s wolf management 

today after 5 years of state authority, post-delisting. It is a success. 

I will then share with you some insights from this journey to recovery and what it means for state management. 

In 2016, Idaho’s wolf population continues to far exceed the 

Federal recovery criteria which were 10 breeding pairs and 100 

wolves in Idaho. Our state management plan is 15 pairs and 150 

wolves above that Federal standard. As our map shows—and you 

will see the graphic up here—I have one figure. Each of those circles represents a pack. Idaho’s wolf population has more than 100 

documented packs—now, remember, our goal was 100 wolves—and 

nearly 800 wolves in the state of Idaho as a minimum population 

as of this year. 

35 

In May of 2016, as I noted, that was the end of the Federal oversight for the 5-year monitoring period post-delisting in 2011. So, 

not only do we celebrate the success of recovery, we can celebrate 

the fact that we have successfully done the 5-year monitoring in 

both the states of Idaho and Montana. 

Idaho’s biologist manages sustainable prolific wolf population in 

ways that address the conflicts with people, pets, livestock, and 

Idaho’s other big game population, including our valuable deer, elk, 

and moose. We primarily manage wolves through public hunting 

and trapping, as we do with all game species. 

As Director, I also authorize additional control actions to respond 

to specific attacks on pets and livestock, and in situations where 

predation takes too big a toll on local elk herds and other big game 

populations. We have 29 elk zones in the state of Idaho; 9 of them 

are not achieving management criteria; 7 of those have been measured to be the result of predation. 

I would also point out that Idaho’s management of elk, deer, and 

other wildlife gave the introduced wolves the food supply necessary 

for recovering, demonstrating the gray wolf’s ability to reproduce 

and disperse across our state. 

Idaho’s wolf population passed that 100 wolf recovery goal in 

1998, within 3 years of reintroduction. The Federal Endangered 

Species Act and Federal wolf introduction into Central Idaho and 

Yellowstone were designed to achieve that outcome: a robust gray 

wolf population under state management. But the tortuous path on 

how we got to this point is certainly not a model, in my view, for 

species recovery. 

In fact, I am deeply disappointed that it took an Act of Congress 

to reinstate the Fish and Wildlife Service’s decision to take wolves 

in Idaho and Montana off of the Endangered Species List, nearly 

10 years after Federal and state agencies agreed, and the scientific 

community generally recognized, that the population met and later 

far exceeded Federal recovery criteria. Nonetheless, I am thankful 

to Congress for doing that. 

If species do not come off the endangered species list when 

science-based recovery criteria are achieved, states and local communities may have no incentive to be active participants. In fact, 

for species having high potential for human conflict, intensive management, and where costs are especially high, the marathon 

delisting processes may incentivize states and local communities to 

sit it out on the sidelines of the recovery process, to actively fight 

proposals to list species, or to avoid expansion of listed species into 

unoccupied habitat—all factors affecting us today. 

Certain advocacy groups sought to leverage legal road blocks to 

increase Federal requirements and minimum population size, hunting moratoriums, and other post-delisting management restrictions. 

This resulted in a lot of problems for the state of Idaho. Lawsuits 

also hampered our ability to use ESA tools for management. 

As our effort to improve this incredibly frustrating situation 

came to an impasse in late 2010, as a result of all of those legal 

and other actions, our governor chose to notify the Fish and 

Wildlife Service that we would no longer be involved in management of wolves in the state of Idaho. Fortunately, Congress intervened to reinstate the Fish and Wildlife Service’s final rule to 

36 

delist wolves in part of the Northern Rocky Mountains, including 

Idaho, in 2011. 

Under state management since 2011—I am going to run out of 

time here, so I will thank you for your time and move on. 

[The prepared statement of Mr. Moore follows:] 

PREPARED STATEMENT OF VIRGIL MOORE, DIRECTOR, STATE OF IDAHO

DEPARTMENT OF FISH AND GAME

The Committee invited Idaho to share our state’s perspective on Federal management of wolves. Let me begin, however, by describing wolves in Idaho today under 

state management. In 2016, Idaho’s professional wildlife biologists manage a recovered wolf population that is sustainable and prolific, and we do so in way that 

addresses wolf conflicts with people, pets, livestock, and Idaho’s other big game populations, including elk, deer, and moose. 

Idaho’s wolf population continues to far exceed the recovery levels set by the U.S. 

Fish and Wildlife Service, which were 10 breeding pairs and 100 wolves in Idaho. 

As our map shows, Idaho has more than 100 documented wolf packs, distributed 

across much of our state (see attached map depicting documented and suspected 

wolf packs at the end of 2015). That means we have more wolf packs than the 

Federal recovery goal was for individual wolves in our state. 

Under state management, we are able to maintain this robust wolf population and 

reduce conflicts, primarily through public hunting and trapping. Our Agency takes 

additional control actions to respond to specific attacks on pets and livestock, or situations where predation takes too big of a toll on local elk herds or other big game 

populations. 

In May 2016, Idaho marked the end of Federal oversight of wolf management in 

Idaho with our successful completion of the 5-year Federal monitoring period that 

follows delisting. At the end of 2015, about 800 wolves inhabited Idaho, based on 

intensive annual capture and radio-collaring, trail cameras, harvest reports, and reliable public observations. Similar maps of surrounding states would show a strong 

core population in Idaho, Montana, and Wyoming, with wolf dispersal and breeding 

packs well into Oregon and Washington and as far as California. 

The Federal Endangered Species Act and Federal wolf introduction into central 

Idaho and Yellowstone were supposed to achieve this outcome—a robust gray wolf 

population under state management. The tortuous path to how we ultimately 

achieved a state-managed, robust wolf population, however, is certainly not a model 

for species recovery. 

In fact, I’m deeply disappointed that we needed an Act of Congress to reinstate 

a U.S. Fish and Wildlife’s decision to take wolves in Idaho and Montana off the endangered species list, nearly 10 years after Federal and state agencies agreed, and 

the scientific community generally recognized, that the population met, and later far 

surpassed, Federal recovery criteria. 

I say that as someone who has invested over 40 years—my entire professional 

career—as a trained biologist working for, and now leading, state wildlife management agencies, mostly in Idaho. I am the elected Vice-President of the Association 

of Fish and Wildlife Agencies, which represents state and territorial fish and wildlife management from across the U.S. states, as well as several Canadian provinces 

and Mexican states. I’m not representing AFWA today, but in my position with 

AFWA, I am aware of the choices my counterparts in other states face in how they 

engage in conservation of ESA-listed species. 

If species do not come off the endangered species list when science-based recovery 

criteria are achieved, states and local communities have no incentive to be active 

participants in recovery efforts. In fact, for species having a high potential for 

human conflict or other intensive management, where the costs of meeting Federal 

monitoring and management requirements are especially high, marathon delisting 

processes incentivize states and local communities to sit on the sidelines of the recovery process, to actively fight proposals to list species, or to avoid expansion of 

listed species into unoccupied habitat. 

If the Federal ESA delisting process is ultimately an exercise in moving the goalposts such that Federal restrictions never really end and the Federal Government 

prescribes how states manage populations well above recovery criteria, states and 

local communities will question why they should invest their time and money in the 

enterprise. That’s simply not a good incentive program for wildlife conservation. 

Protracted administrative and legal delisting delays based on procedural 

technicalities and armchair quarterbacking, rather than legitimate scientific or 

management concerns, also fuel public resentments toward the species and the ESA. 

37 

Now that Idaho has state management of a recovered, robust wolf population in 

Idaho, we sometimes forget where we were right before congressional intervention 

in 2011. 

Gray wolves were listed under the Endangered Species Act in 1974. In 1987, the 

U.S. Fish and Wildlife Service developed a Northern Rocky Mountain Wolf Recovery 

Plan, with recovery goals of 100 wolves and 10 breeding pairs in each of the three 

states of Idaho, Montana, and Wyoming. 

In a controversial action, the Federal Government transplanted a total 66 wolves 

into Yellowstone and Central Idaho in 1995 and 1996, as a ‘‘10j’’ nonessential experimental population. The Federal Government provided assurances that there would 

be resources and mechanisms to address predation conflicts with livestock and elk 

and deer populations. These assurances did not come to fruition; what happened 

instead was over 10 years of largely unchecked population growth, while Federal 

restrictions limited our ability to address a corresponding increase in wolf-human 

conflicts with our agricultural community and with excessive predation impacts on 

elk herds. 

Idaho’s management of elk, deer, and other wildlife gave the introduced wolves 

a good food supply. Demonstrating the gray wolf’s ability to reproduce and disperse, 

Idaho’s wolf population had already passed the 100-wolf recovery goal in 1998, within 3 years of introduction. By 2002, the Fish and Wildlife Service recognized that 

the Northern Rocky Mountain gray wolf population was recovered, and that 

delisting was appropriate. The Service eventually issued a final rule delisting the 

population in 2008, but a Federal district court ordered wolves back on the list, citing deficiencies in the Service’s reliance on Wyoming’s state management plan. The 

Service delisted the Northern Rocky Mountain wolf population outside of Wyoming 

in 2009, but the Federal district court ordered wolves put back on the list, again 

citing procedural deficiencies with the Federal agency delisting, rather than biological ones. 

Not only did lawsuits and protracted administrative process thwart the transfer 

to state management that was supposed to happen upon recovery, they also hampered our ability to use tools like the ESA’s 10j rule, which the Federal Government 

had said states would be able to use to respond to conflicts where predation was 

taking too big a toll on our elk herds. 

Certain advocacy groups sought to leverage legal and administrative roadblocks 

to increase Federal requirements for minimum population size, hunting moratoriums, and other post delisting management restrictions. Federal funding was insufficient to meet our wolf monitoring and management responsibilities. Advocacy 

group compensation programs for wolf predation on livestock were short lived and 

inadequate to cover all losses associated with the growing conflicts. After our efforts 

to improve this incredibly frustrating situation came to an impasse, in late 2010 

Idaho’s governor notified the Fish and Wildlife Service that we were ending our 

state’s participation in wolf management until wolves were delisted. 

Fortunately, Congress intervened to reinstate the Fish and Wildlife Service final 

rule to delist wolves in part of the Northern Rocky Mountains, including Idaho, in 

2011. 

Under state management, we have substantially reduced wolf predation on livestock. In 2010 there were 109 wolf depredation incidents on livestock in Idaho with 

75 cattle and 148 sheep confirmed killed. In 2015 there were 55 depredation incidents with 35 cattle and 125 sheep confirmed killed. We have demonstrated that 

a combination of regulated public wolf hunting and trapping seasons, and agencydirected control to address specific livestock predation situations, have been effective 

at reducing these conflicts. This is consistent not only with our state wildlife management policy, but also the original commitments of Federal wolf recovery to 

mitigate financial impact of wolf predation on ranching families. 

In contrast, where wolves remain under Federal management and under protection of the ESA in Wyoming, wolf depredations on livestock have continued to increase. In 2010, 26 cattle and 33 sheep were confirmed killed by wolves. That 

impact has grown to 105 cattle and 103 sheep killed in 2016 through the first week 

of September. 

In closing, I again draw your attention to the map I referred to at the beginning 

of my statement. 

As the map shows, the recovered wolf population under state management is distributed throughout Idaho’s forest lands. The Federal recovery criteria was 100 

individual wolves in Idaho, we have 100 documented packs, roughly 800 wolves at 

the end of last year. 

In Idaho, we manage populations of both predator and prey species so they are 

sustainable, and so they do not need Federal protection. In Idaho, public hunting 

is important to our culture and our management. We sustainably manage elk, mule 

38 

and white-tailed deer, moose, wolves, mountain lions, black bears, a variety of game 

birds, and many other species of fish and wildlife. 

Our Nation has long recognized that managing wildlife and conflicts between 

wildlife and people, as well as reconciling different public values about wildlife, is 

the traditional province of state police powers. Federal management of migratory 

birds, endangered species, and Federal enclaves such as Yellowstone National Park, 

serve as the exceptions and not the rule. 

It should not take an Act of Congress to return a species to state management 

once it is clearly no longer threatened or endangered. And if states and local communities know it is going to take an Act of Congress to return management decisions to them despite their investing a lot of energy and financial resources on a 

single species, most sensible people with lots of priorities to choose from are going 

to choose elsewhere. Wolf management in Idaho should be an ESA success story, 

but what it took to get to this point is also a cautionary tale for those of us who 

care deeply about wildlife conservation. 

ATTACHMENT 

39 

QUESTIONS SUBMITTED FOR THE RECORD BY REP. NEWHOUSE TO VIRGIL MOORE, 

DIRECTOR, IDAHO DEPARTMENT OF FISH AND GAME

Question 1. Can you discuss the ways wolf management in Idaho has improved 

under state-level management? What are the major changes and benefits you have 

seen compared with Federal management of gray wolves in Idaho? 

Answer. Under state management, wolf predation incidents on livestock and 

domestic animals have declined. With state management of wolves, we have made 

improvement in some backcountry elk herds for which wolf and other predation has 

been a major factor in herd decline. Although less quantifiable, the ability to manage the wolf population through licensed, regulated hunting and trapping has generally improved attitudes toward wolves in communities within and near where 

wolves occur. It has likewise been important for the state to be able to take agency 

action as appropriate to address wolf predation on livestock and domestic animals 

or predation on elk and other ungulates, both in terms of predation management 

and public attitudes. Under state management, Idaho’s wolf population has 

remained robust and well above Federal recovery criteria. 

Question 2. In your testimony you state that the failure to delist species that are 

no longer endangered or threatened removes the incentive for states and local 

communities to be active participants in recovery efforts. This has been a source of 

frustration for me due to the partial-listing in Washington State and the ongoing 

conflicts between wolves and livestock. I have been a staunch proponent of delisting 

the gray wolf and returning management to the individual states, which I believe 

are better prepared to manage the species. Through your experiences in Idaho, what 

advice would you give to communities in Washington that want to see a Federal 

delisting and return to state-level management? Additionally, what do you view as 

the biggest impediments to a Federal delisting actually occurring? 

Answer. I would defer to Washington to evaluate what solutions may work best 

for that state’s unique circumstances. In Idaho, the biggest impediments to Federal 

delisting were lawsuits and protracted administrative processes, despite the wolf 

population being well above recovery standards soon after wolf introduction into 

central Idaho and Yellowstone in the mid-1990s. In Idaho’s experience, some advocacy groups and legal organizations continue to pursue procedural litigation, administrative appeals, and political pressure to obtain or prolong listed status for species 

despite broad scientific support for delisting or non-listing. Their incentives for 

doing so appear to outweigh any disincentives. My prepared statement described the 

negative consequences of delisting paralysis. 

We found it valuable to make our case for delisting efforts in multiple forums. In 

addition to pursing and supporting the U.S. Fish and Wildlife Service’s rulemaking 

for delisting, and defending those efforts in court, we also coordinated with our congressional delegation, state and local elected officials, the Western Governors 

Association, the Western Association of Fish and Wildlife Agencies and its national 

counterpart, and wildlife professional associations such as the Wildlife Society. We 

also found it important to provide scientific and professional wildlife manager 

perspectives to respond to misinformation spread by some advocacy groups. One example of a response is available at: https://idfg.idaho.gov/press/op-ed-idahos-wildlifeprofessionals-advocacy-groups-stop-crying-wolf. 

Question 3. You discussed how wolf populations in Idaho have remained robust 

under state management, while also allowing for a reduction in conflicts between 

wolves and livestock populations. You also detail the exhaustive, marathon-like 

process Idaho had to go through to delist and return the wolf to state management. 

As I’m sure you’re well-aware, Washington is currently confronting many of the 

same issues and problems that you have discussed today. In your opinion, will 

Washington be able to adequately address wolf predation while it remains federally 

listed under ESA? What steps could Washington take to improve this process absent 

a Federal delisting? 

Answer. Wolves in western Washington are federally listed as endangered. 

Endangered status significantly restricts management options to address wolf predation, and the U.S. Fish and Wildlife Service is the lead agency, not the state. 

Take of endangered species requires USFWS authorization, and the Endangered 

Species Act broadly defines ‘‘take.’’ 

Wolves in northern Idaho were previously listed as endangered, and wolves introduced into central Idaho and Yellowstone were listed under a ‘‘10j’’ designation as 

a nonessential, experimental population. Federal 10j regulations were supposed to 

allow more flexibility for management, including the ability to respond to excessive 

predation on ungulate populations. However, that promised flexibility did not 

40 

materialize to protect elk and other ungulate populations, again due to litigation 

and protracted administrative processes. So I would expect USFWS to offer little 

management flexibility as the lead agency for wolves listed as endangered. 

Mr. GOHMERT. OK, thank you very much. 

Dr. Vucetich, you are recognized for 5 minutes. 

STATEMENT OF JOHN VUCETICH, ASSOCIATE PROFESSOR, 

SCHOOL OF FOREST RESOURCES AND ENVIRONMENTAL 

SCIENCE, MICHIGAN TECHNOLOGICAL UNIVERSITY, 

HOUGHTON, MICHIGAN 

Dr. VUCETICH. Thank you, Mr. Chairman and the committee, for 

allowing me the opportunity to testify today. I think with a hearing, or a discussion, about wolves, it is appropriate to have some 

kind of broad context about where it is that we have been with respect to wolf management and how far it is that we have come. 

Wolves once inhabited most of the Lower 48. After more than a 

century of persecution by humans, their darkest hour led wolves to 

be just a few hundred living in the most remote portions of the 

state of Minnesota. Then, beginning in approximately the 1970s, 

and for the next four decades, we, the American people, made tremendous strides and advances in wolf conservation. Today, there 

are about 5,500 wolves living in the Lower 48. This represents 

about 15 percent of the former range over which wolves once lived. 

While we have made great progress, at the very same time there 

is still much work to do. I also think that continuing the work that 

needs to be done may indeed require some course correction in 

some of the directions that we have been going. 

Wolves are a complicated and diverse issue. There are wolves in, 

of course, the Northern Rockies and the Western Great Lakes. 

There are red wolves and there are Mexican wolves. In all of these 

cases, there are some issues that are very important. But distinct 

to those populations—for example, for red wolves—issues about hybridization are a great concern. In the Western Great Lakes, there 

are concerns about the application of distinct population segment 

policy. 

While there are these distinct differences among the geographic 

regions where we conserve wolves, there are also some common 

themes; and the common themes, of course, are familiar to everyone in the room, I think. They include conflicts with livestock, and 

they include conflicts with interest related to deer and elk hunting. 

They include perceived risks pertaining to human safety, and there 

are also some legal and policy issues. Those four items, while they 

are challenging, are also very, very manageable issues. And, not 

only are they manageable issues, humans are quite positive in 

their attitude about wolves, positive enough to allow us to overcome these challenges. 

But I think it is also fair to ask, if there are these challenges, 

why would we even bother trying to meet them? It is a hard thing 

to do. What is the interest? I think the interest is that the health 

of many of our Nation’s ecosystems depends greatly on the presence of healthy, functioning wolf populations. 

41 

Just as important, when Americans talk about wolves, we are 

not talking just about the four-legged creature. We are, at the very 

same time, talking about a symbol. We are talking about something that represents our understanding of how it is that we relate 

with nature on the whole. That is an unfortunate burden for 

wolves to have to bear. But, nevertheless, it is how we approach 

wolves. And what this means is that we have to get it right. If we 

don’t get it right with wolves, we will be not getting it right with 

our relationship with nature on the whole. 

As a result, our treatment of wolves, and our treatment of the 

people who are impacted by wolves, is going to be a bellwether for 

how it is that we treat other natural resources in the United 

States, and it will be a bellwether for how it is that we treat other 

species under the Endangered Species Act. So, these are the two 

reasons that it is so important to get it very right. 

I think it is also important to appreciate that the American people are very supportive of this. They have the endurance for it, 

they have the energy for it. What we need most, I think, is better 

leadership, better leadership both from Congress, from the Fish 

and Wildlife Service, from state governments, and from NGOs to 

live up to the expectations that the American people have for how 

it is that we manage wolves. 

Thank you very much for the opportunity to share. 

[The prepared statement of Dr. Vucetich follows:] 

PREPARED STATEMENT OF JOHN A. VUCETICH, PH.D., SCHOOL OF FOREST RESOURCES

AND ENVIRONMENTAL SCIENCE, MICHIGAN TECHNOLOGICAL UNIVERSITY

I am a professor in the School of Forest Resources and Environmental Science, 

Michigan Technological University. I have held a faculty position with Michigan 

Technological University since 1996. My scholarly expertise is population biology, 

most frequently examining wolves and their prey. I am also a scholar for certain 

topics pertaining to the human dimensions of conservation. I have authored or coauthored more than 80 peer-reviewed articles over the past two decades related to 

these and other subject areas, and have given more than 50 invited talks in the past 

12 years. 

I have been studying wolves for about 25 years. My predation ecology research 

includes but is not limited to how predator populations affect their prey and how 

prey affect predators. The majority of my wolf-related scholarship has been in Isle 

Royale National Park, located in Michigan and surrounded by Lake Superior. I have 

been working on the Isle Royale wolf-moose project since the early 1990s, and have 

been leading the project since 2001. It is also the longest running wolf study in the 

world and the longest study of any predator-prey system in the world. 

OVERVIEW

Prior to persecution by humans, wolves inhabited most of the coterminous United 

States. By the 1960s, after more than a century of persecution, wolves in their darkest hour were reduced to perhaps a few hundred, living only in the remote northern 

reaches of Minnesota. Over the past four decades, however, we have made incredible 

progress toward the recovery of wolves. Today, approximately 5,500 wolves inhabit 

about 15 percent of their historic range within the coterminous United States. That 

effortful progress is one of the success stories in American conservation. At the very 

same time, the job is not done. Important work remains. Moreover, if we are to be 

successful, then some adjustment to our present course is required. 

Essential background for many concerns about wolf conservation is conveyed 

through the series of annotated maps that are included as Supplementary Material 

#1 appended to the end of this testimony. The maps pertain to gray wolves (Canis 

lupus), including a subspecies known as the Mexican wolf (Canis lupus baileyi). Red 

wolves are not treated in that series of maps, but are addressed in a separate 

section of this testimony. 

The conservation and recovery of wolves entails a broad and disparate range of 

topics. In this testimony, I will highlight several of these topics. 

42 

The essential issues surrounding wolves—livestock losses, interests pertaining to 

deer and elk hunting, perceived threat to human safety, and legal/political issues— 

these issues are all quite manageable. 

The health of many of our Nation’s ecosystems depends on the presence of 

healthy, functioning wolf populations (see Supplementary Material #2 for a pictorial 

summary). Wolves are also important for a second reason. That is, wolves are important for what they represent. When we Americans talk about wolves we are 

speaking simultaneously about both the four-legged creature and a creature that 

represents our understanding for how we ought to relate to nature. If the bald eagle 

is sacred as a symbol of our national spirit, then wolves are sacred as a symbol of 

our relationship with nature on the whole. 

Consequently, our relationship with wolves is a bellwether for our relationship 

with nature and the Nation’s natural resources. For similar reasons, our treatment 

of wolves through the U.S. Endangered Species Act, 1973 (ESA) is also a bellwether 

for how we will treat the ESA in general and for the hundreds of species whose 

well-being depends on ESA protection. 

For those two reasons, we must get it right by discovering a healthy relationship 

with wolves. We will be defined, in part, by the kind of relationship we forge with 

wolves and the fair treatment of our fellow citizens who are impacted by wolves in 

a genuinely negative manner. Those relationships, whatever they may be, will say 

much about the kind of people that we are. 

Opportunities to work through some important challenges of conservation are impaired if and when Congress intervenes by making decisions about individual 

species in the context of the ESA. Such intervention can seem like an expedited solution, but its larger effect is to inhibit progress on the broader issues. Congress, 

the Fish and Wildlife Service, state wildlife agencies, and NGOs can all do better 

to provide stronger leadership on these issues. The American people are supportive 

of this work and we are more than able to handle this work. 

WESTERN GREAT LAKES WOLVES

The Fish and Wildlife Service delisted gray wolves in the Western Great Lakes 

in December 2011. The decision was challenged in Federal court. In December 2014, 

the court rejected the Fish and Wildlife Service’s delisting decision and ordered the 

Fish and Wildlife Service to restore ESA protections for gray wolves in the Western 

Great Lakes. An important basis for the court’s decision was that a DPS cannot be 

designated for the purpose of delisting. Details of the court’s opinion in this case 

and other related cases indicate that the root concern is considerably broader. 

The broader pattern of court decisions indicate that the ESA requires a species 

to be well-distributed throughout its historic range. That view is also well supported 

by conservation scholarship (e.g., Vucetich et al. 2006, Tadano 2007, Enzler & 

Bruskotter 2009, Geenwald 2009, Kamel 2010, Carroll et al. 2010, and Bruskotter 

et al. 2014, and references therein). On those grounds, Western Great Lakes wolves 

should not be delisted. 

Failure to understand the legal definition of ‘endangered species’ also lies at the 

heart of concerns for the management and delisting of gray wolves in the Northern 

Rocky Mountain DPS. 

Addressing these concerns would require the FWS to: 

1. Develop policy on ‘‘significant portion of range’’ that is consistent with the 

ESA. I believe the courts will eventually decide that the current Fish and 

Wildlife Service policy on this topic is inconsistent with the ESA. (‘‘Significant 

portion of its range’’ is a key phrase in the legal definition of endangered 

species.) 

2. Develop a robust national plan for wolf conservation and recovery. 

RED WOLVES

Background 

There are important scientific uncertainties about the taxonomic status of red 

wolves. Nevertheless, there is widespread agreement among experts that the red 

wolf is a listable entity under the ESA under any plausible scenario describing its 

evolutionary history (see, e.g., USFWS 2016). Consequently, a recovery program is 

required by law. 

The Fish and Wildlife Service had been managing red wolves through an 

‘‘adaptive management’’ program that appears to have been effective in maintaining 

and growing the red wolf population. This adaptive management program included, 

among other strategies, sterilizing coyotes in order to reduce hybridization between 

wild red wolves and coyotes. Such hybridization adversely impacts the genetic 

43 

constitution of the red wolf population and negatively impacts the ability of the red 

wolf population to grow and expand. 

The red wolf population has declined from more than 100 wolves to 45 to 60 

wolves in 2 years’ time. The population is in extreme danger of extinction. 

Recently, the Fish and Wildlife Service ended its adaptive management program 

and reintroductions of red wolves on the landscape, while allowing landowners to 

request the removal of wolves by lethal and nonlethal means. Those circumstances 

will exacerbate an already dire situation. 

Concerns about the removal of wolves from private land need to be resolved because it is not possible to have a recovered red wolf population without red wolves 

living on private lands. 

Even though this red wolf population is designated as nonessential experimental, 

its loss would be a grave setback to red wolf recovery. 

Red wolves are adversely affected by poaching. Anti-poaching laws exist but are 

not enforced. Anti-poaching laws are not enforced through an informal policy known 

as the McKittrick policy. Under the McKittrick policy, prosecutors do not pursue 

cases of red wolf poaching if the defendant claims the killed animal was a coyote. 

Some additional background is provided in Cart (2013). The policy lends tacit support for poaching red wolves and is antithetical to red wolf recovery. In no other 

part of our American hunting heritage is mistaken identity a defense for poaching. 

The McKittrick policy should be discontinued. 

Recovery Goals 

An explicit goal of the Fish and Wildlife Service’s Red Wolf Recovery Plan is to 

grow the wild population of red wolves to 220 individuals. With the population recently having declined significantly from approximately 100 animals to perhaps less 

than 50, management clearly is not moving toward, and may even be undermining, 

that established goal. 

Recent actions of the Fish and Wildlife Service are not moving toward that goal. 

These recent actions are more consistent with abandoning the conservation and recovery of the red wolf than with its advancement. 

In addition, these recovery goals were set 30 years ago and do not reflect the best 

available science about the size of a recovered population. Any formal scientific review of the recovery plan would undoubtedly recommend increasing the number of 

red wolves needed in the wild to qualify as recovered under the ESA. Until the recovery plan and the targets are updated, however, the Fish and Wildlife Service 

should work toward its established recovery goals. 

Last week the FWS announced significant adjustments in its approach to managing the red wolf recovery program. The announcement is explained in a memorandum (12 Sept 2016) to the Regional Director (of the FWS’s Southeastern Region) 

from the Assistant Regional Director (USFWS 2016). The changes include a significant shift of effort away from the experimental population. The underlying rationale 

for the adjustment is ‘‘maximizing efficient use of Services resources.’’ In scholarly 

parlance, the rationale is ‘‘conservation triage.’’ 

The concern is that conservation triage, when conducted according to the principles of best-available science, require a formal, explicit, and appropriately quantified analysis of the cost and benefits of various allocations of resources (e.g., Botrill 

et al. 2008, McDonald-Madden et al. 2008). To my knowledge, no such analysis has 

been shared with the public. 

General concerns about the FWS’s treatment of conservation triage were aptly 

summarized by Evans et al. (2016). They wrote that the Fish and Wildlife Service 

(FWS) has 

a prioritization system for analyzing trade-offs . . . [that] includes 36 

ranked categories grouped according to 4 factors: degree of threat, potential 

for recovery, taxonomic uniqueness, and conflict with human activities . . . 

However, it is well established that FWS does not frequently use its system. 

Instead, FWS’s allocations are more often driven by political and social 

factors [emphasis added], including congressional representation, the number of employees in field offices, staff workload, and opportunities to form 

partnerships and secure matching funds. In addition, different regions and 

field offices often use different allocation formulas. 

44 

Without following a uniform and explicit system for prioritizing recovery actions, FWS cannot efficiently allocate its funding to meet recovery needs. 

That is partly why most recovery funding has benefited only a small fraction 

of listed species. Moreover, FWS cannot clearly articulate to Congress and 

other stakeholders what recovery actions it will implement with available 

funding and what additional achievements are possible with more funding. 

As a result, the agency is poorly positioned to request additional funding. 

The authorship of Evans et al. (2016) included 18 scholars, including federallyemployed scientists that collectively represent considerable ESA expertise. 

I am also concerned that the memorandum associated with announcement (i.e., 

USFWS 2016) seems to arrive at its conclusion, in part, through a misunderstanding or misrepresentation of some of the science that is cited (and should have 

been cited) in the memo, especially Gese et al. (2015), Murray et al. (2014), and 

Bohling et al. (2016; Evolutionary Applications). 

Because last week’s announcement was (i) preceded by FWS actions that represent a significant shift in effort away from the experimental population and (ii) 

not accompanied by a formal and appropriately quantified analysis of the costs and 

benefits associated with various allocations of resources—for those two reasons, 

there is a concern that the announcement is an ad hoc explanation for the shift in 

focus and that the appropriateness of the announced shift was prejudged. 

MEXICAN WOLVES

Mexican wolf recovery has faced a variety of challenges. I believe the three most 

important concerns at present are: 

The FWS has failed to fulfill its statutory obligation to develop a scientifically defensible recovery plan. In response to a legal challenge to FWS’s failure to complete 

a recovery plan, the FWS committed in a settlement agreement to complete a recovery plan by November 30, 2017. More precisely, the Fish and Wildlife Service has 

been actively attempting to develop a science-based recovery plan for the past 15 

years. On two occasions in the past 15 years, the Fish and Wildlife Service suspended the activities of the Mexican wolf recovery team just as the team was on 

the cusp of presenting its findings. The FWS is now working through a third effort. 

No stakeholder group thinks it is desirable for the recovery planning process to have 

taken so long. The delays have resulted in stakeholder mistrust and created opportunities to interfere with the scientific process, both of which ultimately impair 

Mexican wolf recovery. The delay in producing a recovery plan is clearly a problem 

in its own right, but it is also symptomatic of a deeper, chronic problem. 

The second challenge pertains to the reliable identification of best-available 

science as it pertains to the ESA. The challenge is illuminated, in part, by recent 

sociological research pertaining to grizzly bear recovery. The scholarship indicates 

that the problem is identifying best available science. Recent work shows that scientists ‘‘working for state or Federal wildlife agencies were 2–3 times more likely 

to recommend delisting grizzlies than those employed by academic institutions’’ 

(Bruskotter et al. 2016). That paper goes on to say that these recommendations: 

were influenced not so much by an expert’s knowledge or assessment of risk 

but more so by their social environment; in particular, the peers with whom 

an expert regularly interacts and respects . . . our concern is that supposed 

scientific judgments may well be heavily influenced by socially segregated 

groups and their associated beliefs. 

Of course, it is not inherently problematic that an expert’s judgment is 

affected, in part, by how he or she expects respected peers would judge a 

given circumstance. Nor is it necessarily problematic that judgments about 

conservation routinely depend on factors beyond science, like one’s values 

and emotions. Indeed, the dichotomy between facts and values may well be 

a false dichotomy, as argued by the great American philosopher Hillary 

Putnam . . . 

What’s concerning here is that, as opposed to academic scientists who are 

somewhat shielded from politics by tenure, scientists in state and Federal 

agencies can face strong, top-down pressure to reach a particular decision. 

A full discussion of how to reliably identify the best-available science is beyond 

the scope of this written testimony. The relevance of this concern to Mexican wolf 

recovery planning is explained below. 

Recent deliberations in the development of a recovery plan may be of concern. In 

particular, state governments have been advancing the notion that recovery actions 

should be focused in Mexico. Other scientists on the recovery team believe that 

45 

while Mexico is an important partner in wolf restoration, prudent recovery planning 

should remain focused on efforts in the United States. The concern is that the 

political expediency may end up being mistaken for a genuine spirit of 

state-Federal collaboration and the Fish and Wildlife Service will focus recovery 

efforts in Mexico when doing so is otherwise not justified. Details of this concern 

appear below. 

Focusing recovery efforts for Canis lupus baileyi in Mexico is unlikely to be successful because the lands in Mexico where recovery efforts might be focused are 

dominated by private land, higher densities of livestock, and the abundance of wild 

prey is not reliably known. Because the Fish and Wildlife Service wouldn’t focus 

wolf recovery efforts on such lands if they existed in the United States, the Service 

should not find it wise to do so in Mexico. 

By contrast, recovery efforts would be successful if they focused on selected regions in Arizona, New Mexico, southern Colorado and possibly southern Utah. 

Details for this claim are presented in draft documents prepared about 2 years ago 

by the scientific sub-team of the Mexican wolf recovery team. 

Mexico is a valuable partner in efforts to restore Mexican wolves. However, the 

largest share of the task in recovering Mexican wolves will almost certainly fall 

within the borders of the United States. 

Two concerns that are sometimes expressed about efforts to recover C. lupus 

baileyi in the United States are: 

1. The historic range of C. lupus baileyi did not extend as far north as northern 

Arizona and northern New Mexico, and 

2. C. lupus baileyi is physically smaller than other subspecies of gray wolf; as 

such they are not well adapted to survive on elk. Rather they are better 

suited to surviving on smaller prey like deer and javelina. 

The concerns are addressed by noting: 

1. The best-available science indicates that the historical distribution of gray 

wolf subspecies involved wide zones of overlap such that the traditional 

notion of historical range, with sharp boundaries, does not apply well. 

2. C. lupus baileyi living for many years on the Blue Range (in Arizona and New 

Mexico) demonstrate that they are more than capable of surviving very well 

on elk. 

NORTHERN ROCKY MOUNTAIN WOLVES

Many of the issues surrounding recovery and management of wolves in the 

Northern Rocky Mountain DPS are identified and discussed in other sections of this 

testimony. 

In 2011, wolves in Montana and Idaho were delisted by an Act of Congress, i.e., 

a congressional rider to the ‘‘Department of Defense and Full-Year Continuing 

Appropriations Act.’’ That action compromised important opportunities for critical 

concerns and challenges to be worked out and addressed by key stakeholders (e.g., 

the Fish and Wildlife Service, state governments, NGOs, etc). Congressional 

delisting did not ameliorate those concerns and challenges. 

HUMAN ATTITUDES PERTAINING TO WOLVES

Attitudes pertaining to wolves are important for at least two reasons: 

1. If attitudes of Americans were, on the whole, negative; then the values and 

expressed values of Americans may be at odds with the ESA’s mandate to 

conserve and recover wolves. 

2. If attitudes of Americans are, on the whole, supportive of wolf recovery; then 

negative attitudes by smaller segments of American society represent an 

important concern deserving attention. 

Americans’ attitudes toward large carnivores, including wolves, are largely positive. Those attitudes have also become increasingly positive over the past four decades (George et al. 2016; See also Supplementary Material #3). And, only 10 percent 

of Americans have significantly negative attitudes about wolves (George et al. 2016; 

See also Supplementary Material #3). 

What accounts for the false impression of low tolerance for wolves? 

Some sociological studies suggest that attitudes toward wolves have become 

more negative over time; these studies tend to focus on hunters and rural residents living within wolves’ range (e.g. Treves et al. 2013, Ericsson & Heberlein 

46 

2003). While it is important to address these attitudes (see below), they are not 

representative of the interests of most Americans. 

Other research indicates that biased media coverage gives the impression of low 

and deteriorating tolerance for wolves. For example, Houston et al. (2010) examined North American news coverage about wolves over a 10-year time period 

(1999–2008). Of the 6,000 stories they analyzed, 72 percent of the news media 

represented negative attitudes about wolves. They also found that these negative expressions had increased significantly over time. The concern is that 

media coverage does not accurately represent Americans’ attitudes (see George 

et al. 2016). 

In 2003 the Utah Division of Wildlife Resources hosted a series of scoping meetings concerning wolf management. About 80 percent of the 900 people who attended those meeting identified ‘do not allow wolves in Utah’ as a management 

priority. At the same time (i.e., in 2003), a systematic study of attitudes toward 

wolves found that 74 percent of Utahans exhibited positive attitudes toward 

wolves. 

This case illustrates that state agencies can get the false impression of low support for wolves on the basis of their contact with the public. The concern is that 

agencies’ contact with the public is not always representative of the public’s attitude 

on the whole, or even of those who care about wildlife conservation issues. This circumstance is regrettable, but understandable, given that scoping meetings, for example, are often attended disproportionately by stakeholders who are especially 

upset about an issue. This case and these circumstances are detailed in Bruskotter 

et al. (2007). 

Psychological research indicates that intolerance for wolves (and other large carnivores) may originate from negative emotional reactions toward these species (Slagle 

et al. 2012) that are at gross odds with scientific knowledge about these species 

(Johannson et al. 2012). Other sociological research makes the case that negative 

attitudes about wolves are associated, less so with the negative impact of wolves, 

and more so with ‘‘deep-rooted social identity’’ (Naughton-Treves et al. 2003; see also 

Heberlein 2012). 

While it is important to ameliorate the adverse impacts of wolves for those few 

individuals who are actually impacted, doing so is not likely to cause those individuals to have more positive attitudes, as was demonstrated by Naughton-Treves et 

al. (2003). 

Existing data indicate that public support for the ESA is widespread and strong. 

A sociological study concludes that most Americans (84 percent) are supportive of 

the ESA (Czech & Krausman 1997). That study also indicated that 49 percent of 

respondents believed that ESA should be strengthened. And, only 16 percent believed it should be revoked or weakened. 

Recent polling data give the same positive impression. One poll, conducted in 

2015, indicates that approximately 80 to 90 percent of Americans are supportive of 

the ESA (Harris Interactive 2011). Another poll, conducted in 2011, indicates that 

support for the ESA transcends political ideology. That is, support for the ESA by 

self-identified liberals, moderates, and conservatives is 96 percent, 94 percent, and 

82 percent, respectively (Tulchin Research 2015). 

Conclusion 

The values and willpower of the American people, on the whole, support the ESA 

and wolf conservation. We are also a sufficiently resourceful and generous people 

to fairly redress the concerns and negative attitudes held by a small segment of 

Americans. 

WOLF HUNTING

Wolf hunting in several states is intensive enough to raise the following concerns: 

1. The Findings section of the ESA (Sec 2.(a)(3)) indicates that species are valuable to the Nation and its people, in part, for their ‘‘ecological’’ value. The 

primary ecological value of wolves is largely associated with their influence 

on deer and elk populations, including preventing deer and elk from becoming 

overabundant. The ecological value of wolves is impaired if they are hunted 

too intensively. There is considerable evidence that deer and elk are overabundant in numerous places where wolves are intensively harvested or 

where wolves once lived but no longer live (e.g., McShea et al. 1997, Bradford 

and Todd 2008; Dickson 2015). Overabundant deer and elk are detrimental 

to human safety, agriculture, and forestry. 

47 

2. An important prospect for wolves achieving recovery is through dispersal and 

range expansion from areas where wolf populations are already established. 

The concern is that range expansion is, at least, significantly curtailed by intensive hunting of wolves. 

3. Intensive hunting of wolves will likely impair the adequate genetic connectedness of subpopulations in the Northern Rocky Mountain gray wolf population. 

The importance of adequate genetic connectedness is memorialized through 

recovery criteria. (This concern is not ameliorated by the feasibility of humanassisted dispersal. For details, see the FWS’s scientific peer-review of 

Wyoming’s state management plan conducted in December 2011.) 

Four important motivations for wolf hunting: 

1. Hatred of wolves is an important motivation to hunt wolves. In the past, 

hatred has motivated programs designed to eliminate certain populations of 

wildlife. But, never before in the history of America’s hunting heritage has 

hatred been an acceptable or ethical basis for hunting. 

2. Wolf hunting is motivated, in part, by state game and fish agencies’ interest 

to satisfy elk and deer hunters. This motivation may be sensible when all of 

the following conditions hold: (i) wolves cause elk and deer abundance to decline; (ii) wolf hunting (as implemented) results in a significant increase in 

elk or deer abundance without impairing the health and functioning of the 

wolf population; (iii) increased elk or deer abundance will translate to hunters’ satisfaction with their hunting experience; and (iv) interests to increase 

ungulate abundance outweigh interest to decrease ungulate abundance. In 

many cases, it is far from reasonably certain that all of these conditions hold. 

3. Some argue that wolf hunting is important for building tolerance for wolves. 

However, sociological evidence suggests that tolerance is not built by legal 

killing of wolves (e.g., Treves et al. 2013, Browne-Nunez et al. 2015, Hogberg 

et al. 2015). 

4. Wolf hunting is also, in some cases and at least to some extent, a kind of 

trophy hunt. 

Concerns raised by the above-mentioned motivations: 

Our treatment of wolf hunting is importantly connected to hunting in general. 

American participation in hunting has been declining for several decades. The demographic forces behind that decline are expected to continue into the foreseeable 

future. Those trends are of great concern to state wildlife agencies, and they are 

searching for ways to reverse those trends. 

While participation in hunting is low and declining, support for hunting by nonhunters is high. However, that support depends on the reason that is offered for 

why hunting takes place. For example, 85 percent of Americans support hunting 

when motivated by the acquisition of meat. But only about 26 percent of Americans 

support hunting motivated by the acquisition of a trophy. For details, see Duda and 

Jones (2008). 

Because motivation for hunting affects support for hunting by non-hunters and 

because the motivations for wolf hunting are weak, wolf hunting is liable to harm 

the honor of America’s hunting tradition. We should not be surprised to see that 

wolf hunting works against interests to promote hunting in a society with waning 

participation in hunting. 

I believe that Congress, the Fish and Wildlife Service, and state wildlife agencies 

could be effective agents for better promoting our American hunting heritage. 

LIVESTOCK, LETHAL CONTROL AND CONFLICT AVOIDANCE

According to a 2011 USDA report on cattle death loss, wolf depredation represents 

less than half of 1 percent of all losses (USDA 2011). For context, about half of all 

losses are health-related (e.g., digestive problems, respiratory problems, metabolic 

problems). Losses due to dogs are almost three times as common as wolf-related 

losses. Losses due to poisoning and theft are six times as common as wolf-related 

losses. These statistics are similar within each of the states inhabited by wolves, i.e., 

Michigan, Minnesota, Wisconsin, Montana, Idaho, Wyoming, Washington, Arizona 

and New Mexico. Wolves are not a threat to the livestock industry. 

In certain instances, wolves compete with the interests of individual livestock 

owners. Those instances are important. The American people share a burden to assist in these instances. To this end, the states, the Fish and Wildlife Service, the 

Department of Agriculture and non-profit organizations all have programs to assist 

ranchers financially or with tools and management techniques to reduce conflicts 

48 

with wolves. Several varieties of these programs exist, focusing variously on: 

compensation for livestock losses; cost-share and technical assistance for the use of 

nonlethal tools that reduce conflict; and incentive payments such as payment for 

presence. Where there is a need to improve these programs, they should be so 

improved. 

Lethal and Non-Lethal Control 

Scientific evidence indicates that lethal control may be less effective than is 

commonly supposed (reviewed in Treves et al. 2016). 

Lethal control is also a source of public controversy, as it is shunned by some 

stakeholders. A critical component of meeting the challenges represented by lethal 

control (both the establishment of lethal control policy and the aftermath that can 

follow some instances of lethal control) is a robust multi-stakeholder committee, 

such as the Wolf Advisory Group in the state of Washington. The establishment and 

maintenance of such bodies is effortful, but also very important. 

Non-lethal methods are often effective for preventing depredation and avoid conflict before considering lethal control. There is a suite of nonlethal methods and 

strategies that have been effectively used in the Northern Rockies and the Southwest to do just this. These include: nonlethal predator deterrents such as livestock 

guarding dogs, fencing and fladry; increasing human presence on the landscape 

through range riders; use of scare tactics and alarms; best management practices 

for livestock and land such as changing grazing strategies and removing carcasses. 

Those tools have been used effectively, for example, in a community-based project 

in the Wood River Valley of Idaho—an area with between 10,000 to 22,000 sheep 

grazing per year. During the first 7 years of the project (which began in 2007) fewer 

than five sheep were killed per year. 

HUMAN SAFETY

Except in the very rarest of circumstances, wolves are not a threat to human safety. Incidents of wolves harming people are incredibly rare. Wolves generally avoid 

people and in almost all cases people have nothing to fear from wolves in the wild. 

In the 21st century, only two known deaths have been attributed to wild wolves 

in all of North America. There have been no deaths from wolves in the conterminous 

United States. Far more Americans are killed by bees or dogs than by wolves. Far 

more Americans are killed in deer-car collisions. Our overall response to any threat 

to human safety should be, in part, commensurate with the risk of that threat. 

On the extraordinarily rare occasions when a wolf has appeared to be even potentially problematic, the appropriate agency (state or Federal) has moved swiftly to 

address any possible threat. For example, in May 2015, the Mexican Wolf 

Interagency Field Team lethally removed a wolf that was exhibiting unusual activity near residents and populations in Catron County, New Mexico. 

The false impression that wolves are a threat to human safety is fostered by the 

interaction between (i) a public that is easily and overly impressed by certain kinds 

of fear and (ii) those who fabricate or exaggerate the threat that wolves represent. 

The seriousness of these exaggerations is illustrated with two examples from 

Michigan: 

—A state Senator conveyed a ‘‘horrifying and fictional’’ account of wolves threatening humans. That account was included in a 2011 resolution urging the 

U.S. Congress to remove ESA protections for gray wolves in Michigan. Later 

the Senator conceded that the account was not true. See Oosting (2013) for 

details. 

—Adam Bump, an official from the Michigan Department of Natural Resources, 

‘‘misspoke’’ when he was interviewed by Michigan Radio (a National Public 

Radio affiliate) in May 2013. Bump apparently said to the interviewer: ‘‘You 

have wolves showing up in backyards, wolves showing up on porches, wolves 

staring at people through their sliding glass door while they’re pounding on 

it exhibiting no fear.’’ Later, Bump conceded that this did not happen. See 

Barnes (2013) for details. 

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SUPPLEMENTARY MATERIAL #1: A SERIES OF 

THREE ANNOTATED MAPS 

Map 1—Approximate Range (Historic and Current) of Gray Wolves in the 

Conterminous United States 

Before human persecution, gray wolves occupied most of the conterminous United 

States (blue regions on the map). Currently, gray wolves occupy about 15 percent 

of their former range (purple regions on the map). The map is taken from 

Bruskotter et al. (2014) which explains how it would be feasible for wolves to 

inhabit more geographic range than they currently do. The blackened counties represent areas where wolves and humans would likely not co-exist well, owing to higher human population density. (Note: This map overestimates the size of areas where 

human population density exceeds 142 people/km2.) 

51 

Map 2—Distinct Population Segments of Gray Wolves Established by the 

U.S. Fish and Wildlife Service on April 1, 2003 

A ‘‘distinct population segment’’ is a listable entity under The Endangered Species 

Act (ESA). According to FWS policy (61 Fed. Reg. 4722, Feb. 7, 1996) determinations 

regarding the management of DPSs are to be based on the population’s discreteness, 

its significant to the species to which it belongs, and whether the population would 

be deemed endangered or threatened if treated as a species. 

The DPS provision offers flexibility in recovering species that occupy large geographic ranges. For example, if gray wolves living in the Eastern DPS had reached 

recovery, but wolves in the southwest DPS had not reached recovery, then wolves 

in the Eastern DPS could be removed from the list of endangered species and wolves 

from the southwest DPS could continue receiving the ESA protection necessary for 

recovery. The DPS policy can also enhance FWS’s ability ‘‘to address local issues 

(without the need to list, recover, and consult rangewide) [and] result in a more effective program.’’ Id. 

The DPSs represented on the map above depict the gray wolves’ historic range. 

The dark hatched areas within the Western DPS and the Southwestern DPS on the 

map represent areas in which FWS manages gray wolves as nonessential, experimental populations under section 10(j) of the ESA. That provision authorizes the release of an endangered or threatened species or subspecies outside their current 

range ‘‘if the Secretary determines that such release will further the conservation 

of such species.’’ Section 10(j)(B). Moreover, species managed under Section 10(j) do 

not receive the full protection otherwise provided by the ESA. For example, an experimental population deemed ‘‘not essential to the continued existence of the 

species,’’ and which is not located within the National Refuge or National Park systems, is treated as a species proposed for listing and the FWS may not designated 

critical habitat for that population. Section 10(j)(C)(i)–(ii). 

52 

Map 3—Revised Distinct Population Segments of Wolves Established by the 

U.S. Fish and Wildlife Service 

The Northern Rocky Mountain DPS was created in April 2009 (74 FR 15123). 

Except for the state of Wyoming, gray wolves are delisted in this DPS. 

The Western Great Lakes DPS was created in December 2011 (76 FR 81665). The 

Fish and Wildlife Service also delisted wolves in this DPS in December 2011. Three 

years later, in December 2014, a Federal court ordered the Fish and Wildlife Service 

to reinstate full ESA protection for wolves living in this DPS. 

The most recent census of the wild Mexican wolf population living in Arizona and 

New Mexico, conducted in December of 2015, found only 97 individuals. Mexican 

wolves are listed as a subspecies. The Fish and Wildlife Service has been actively 

working on a recovery plan for Mexican wolves for the past 15 years. 

Red wolves are not represented on this map, but are discussed in section 3 of this 

testimony. 

53 

SUPPLEMENTARY MATERIAL #2 

The figure below, is taken from Ripple et al. 2014, which was published in 

Science. The figure represents a conceptual summary of 12 scientific publications, 

and is a conceptual representation of what is known about how wolves influence the 

health of ecosystems. 

54 

SUPPLEMENTARY MATERIAL #3 

The figure below is taken from George et al. (2016). 

55 

QUESTIONS SUBMITTED FOR THE RECORD BY REP. DINGELL TO JOHN A. VUCETICH, PH.D., SCHOOL OF FOREST RESOURCES AND ENVIRONMENTAL SCIENCE, MICHIGAN

TECHNOLOGICAL UNIVERSITY

Question 1. You state in your testimony that when Congress legislates species listings and delistings under the ESA it inhibits progress on both conservation of and 

co-existence with wildlife. Will you please explain what you mean by that? 

Answer. When Congress passed the Endangered Species Act (ESA), it set a standard for conserving and co-existing with wildlife that a large majority of Americans 

clearly support. That widespread support would seem to be on a short-list of ideas 

that unify Americans in today’s divisive political climate. For some species on some 

occasions, meeting the conservation standards of the ESA is a little more challenging—not overwhelming, just a little more challenging. Americans still support 

the ESA, even in those more challenging cases.1 

Moreover, the Fish and Wildlife Service (FWS) has the expertise and mandate to 

manage individual species in the context of the ESA and to mount any challenges 

that may arise along the way in a manner that is both fair-minded and scientifically 

sound. If the FWS should ever fall short of standards set forth by the ESA, then 

the Federal courts are the proper place for rectifying such a shortcoming. These 

processes—led by the FWS and corrected when necessary by the courts—take time. 

The goodness of government is manifest when those processes are afforded the necessary time. 

In contrast to that honored model of governance, Congress has increasingly made 

efforts to influence the management of individual species in the context of the ESA. 

These efforts have been motivated by local and special interests aiming for outcomes 

that do not meet the conservation standards of the ESA. As such, they eviscerate 

the essential purpose of Federal governance and the ESA, which is to conserve 

species insomuch as doing so is a national interest. The most constructive role that 

Congress can play in these circumstances is to encourage and further enable the 

FWS to fulfill its mandate. 

In this way, congressional legislation focused on individual species inhibits 

progress toward conservation. 

These concerns—expressed above in general form—are exemplified by the management of wolves under the ESA and detailed in the subsequent pages of this Q&A 

section. 

Question 2. Can you please speak to the claim that wolves negatively impact deer 

or other ungulate populations? 

Answer. Wolves are not negatively impacting the health or vitality of any deer 

or elk population. Several considerations indicate that concerns over the impact of 

wolves on deer and elk hunting are overstated: 

1. Healthy wolf populations are vital to the health of ecosystems inhabited by 

ungulates, as summarized by the image included with my written testimony 

(see page 53). The figure represents a conceptual summary of 12 scientific 

publications, and is a conceptual representation of what is known about how 

wolves influence the health of ecosystems. 

2. Ungulates are widely acknowledged—even by scientists working for state 

wildlife agencies—to be overabundant in many portions of current and historic wolf range. Overabundant ungulate populations are widely understood 

to be of significant detriment to agriculture, forestry, private property, and 

human safety (deer-vehicle collisions). 

3. Ungulate hunting is successful in all states where wolves live. For example, 

in 2015 Idaho experienced record high harvest of white-tailed deer and the 

highest harvest of elk since 1996. The high numbers were not attributed to 

the state’s control of wolf predation, but instead to a series of mild winters 

(Idaho Fish and Game 2016). Moreover, hunters’ dissatisfaction with ungulate 

harvest, where it occurs, is likely connected less with any discernable effect 

of wolves and more with ill-informed perceptions of how wolves impact 

ungulate populations, lack of trust in state wildlife agencies, and unrealistic 

expectations concerning the harvest levels. It would be valuable for state 

wildlife agencies to tend those likely sources of dissatisfaction. 

4. In many places where ungulates are less abundant, poor habitat is believed 

to be the limiting factor, not wolf predation. 

5. It is normal and healthy for ungulate populations to fluctuate in response to 

many factors—the most important factors being winter severity, habitat 

quality, and human hunting. It is a deeply unrealistic expectation to think 

that ungulate abundance would not fluctuate over time. 

56 

Moreover, observing a decline in ungulate abundance is not evidence that wolf 

predation is the cause of decline. For example, during a congressional oversight hearing held on September 21, Rep. Benishek seemed to suggest that 

wolf predation was the reason the Michigan Department of Natural Resources 

has allowed for fewer opportunities to hunt antlerless deer in Upper Michigan 

in recent years. However, the Michigan Department of Natural Resources indicates those decisions were a response to a string of severe winters that were 

the primary cause of recent decline in deer abundance (MI-DNR 2016). Three 

of the last four winters in Upper Michigan have been severe. 

6. Wolf predation is a relatively small source of ungulate mortality. For example, 

information provided by the Wisconsin DNR indicates that hunters kill approximately nine times as many deer than do wolves, vehicle-deer collisions 

kill approximately the same number of deer as do wolves, starvation in a typical winter kills nearly four times more deer than do wolves. In many cases 

wolves are killing deer that are less fit and vulnerable to starvation. In the 

absence of wolves, more deer would likely die of starvation (Wisconsin 

Department of Natural Resources 2009). Finally, poachers and hunters who 

do not retrieve the deer they shoot likely kill considerably more deer than do 

wolves. 

This assumes that wounding losses are about 10 percent of the harvest and 

that rates of poaching are on the order of 4 percent. Those rates of wounding 

loss and poaching are consistent with peer-reviewed literature (e.g., Unsworth 

et al. 1993, Van Deelen et al. 1997, Nixon et al. 2001, Mayer et al. 2002, 

Grovenburg et al. 2011, McCorquodale et al. 2011). By those rates (10 percent 

and 4 percent), these sources of deer death are approximately 40–50 percent 

more than what wolves kill, when considered in conjunction with information 

presented in Wisconsin DNR (2009). 

7. Finally, the views of Carter Niemeyer seem appropriate. Mr. Niemeyer is an 

avid hunter and served for 6 years as the wolf recovery coordinator for the 

U.S. Fish & Wildlife Service. He was also a long-time trapper with USDA 

Wildlife Services, and involved with both lethal and nonlethal control of 

wolves. Mr. Niemeyer stated in an interview with Outdoor Idaho: ‘‘. . . I don’t 

think [wolves are] any excuse for not being a successful hunter. There’s tremendous numbers of game animals available to sportsman and with a little 

effort and sleuth, you still have great potential to collect a wild animal from 

hunting. I don’t know what the excuse was before wolves, but it has become 

the main excuse now for unsuccessful hunters. I mean, there are just so many 

other issues involved in why hunters are not successful, but the wolf is a lame 

excuse.’’ 

Question 3a. Is the wolf population increasing in the Great Lakes? 

Answer. According to records collected and kept by Michigan, Minnesota, and 

Wisconsin, wolf abundance in the Great Lakes region (MI, WI, MN) has either been 

stable since 2011 or there is some evidence to suggest that abundance has declined 

slightly over that time frame. There is no evidence to suggest that wolf abundance 

in the Great Lakes region has increased since 2011.This perspective of wolf abundance emerges from state-specific trends in wolf abundance as reported by state 

wildlife agencies in Michigan, Wisconsin, and Minnesota: 

1. Wisconsin wolves (representing ∼20 percent of the Great Lakes population) 

having increased in by an estimated 16 percent over recent years. 

2. Michigan wolves (representing ∼20 percent of the Great Lakes population) 

having been likely stable in recent years. (Though point estimates of abundance have declined slightly by about 10 percent between 2012 and 2016, 

from 687 wolves to 618 wolves.) 

3. Minnesota wolves (representing ∼60 percent of the Great Lakes population) 

having likely declined by approximately 24 percent in recent years (2008– 

2013). 

No less important than the abovementioned patterns are the following ideas: 

1. There are unresolved concerns pertaining to the methods used in Wisconsin 

for estimating wolf abundance. These concerns give reason to doubt the increase in wolf abundance reported by the state of Wisconsin. These concerns 

are explained, in part, in Treves et al. (2013). 

57 

2. Intense persecution by humans was likely an important contributor to decline 

in Minnesota. That decline has brought the number of wolves in Minnesota 

close to state’s minimum goal of 1,600 wolves and close to the Federal recovery goal of 1250 to 1400 wolves. That circumstance raises concern about the 

existence of adequate regulatory mechanisms which is a requirement for 

delisting. 

3. Wolf management should be focused on treating the regularly raised concerns 

about wolves—livestock depredation, interests pertaining to deer and elk 

hunting, and perceived threat to human safety. The magnitude of those concerns are not well correlated with fluctuations in wolf abundance. Focusing 

efforts to manage those concerns on attempts to influence wolf abundance, per 

se, through hunting or trapping are liable to be ineffectual. For details, see 

Vucetich et al. (2013). 

Question 3b. Are wolves really a threat to livestock in the Great Lakes region, 

or in other areas where wolves are present? 

Answer. According to a 2011 USDA report on cattle death loss, wolf depredation 

represents less than half of 1 percent of all losses (USDA 2011). For context, about 

half of all losses are health-related (e.g., digestive problems, respiratory problems, 

metabolic problems). Losses due to dogs are almost three times as common as wolfrelated losses. Criminal losses, due to poisoning and theft, are six times as common 

as wolf-related losses. These statistics are similar within each of the states inhabited by wolves, i.e., MI, MN, WI, MT, ID, WY, WA, OR, AZ and NM. Wolves are 

not a threat to the livestock industry in any state or region of the country. 

One response to the facts described just above is to argue that no industry of any 

kind should accept losses on the order of 0.5 percent. That response would represent 

a basic misunderstanding of the circumstance. The circumstance is: Of the lost 

cattle, about 0.5 percent are attributable to wolvesOf existing head of cattle, some 

92 million head, wolves kill approximately one hundredth of 1 percent—tantamount 

to a rounding error. 

An industry interested in managing its losses would tend to focus on larger, higher-ranking sources of loss. Of the 20 categories of loss tracked by the USDA, wolves 

are the 6th least important. For example, even domestic dogs and vultures are each 

more important sources of loss. 

Disturbing images of wolf-killed livestock are sometimes presented as evidence for 

the failure of efforts to manage wolf-livestock conflicts. This is analogous to presenting emotion-laden images of a car accident as evidence that the Nation’s transportation system is, on the whole, a failure. A car wreck and a lost head of livestock 

are certainly both unfortunate events, but neither is evidence of widespread or 

systematic failure. 

In certain instances, wolves compete with the interests of individual livestock 

owners. Those instances are important. The American people share a burden to assist in these instances. To this end, the states, the FWS, the Department of 

Agriculture and non-profit organizations all have programs to assist ranchers financially or with tools and management techniques to reduce conflicts with wolves (e.g., 

range riders, moving female livestock to give birth in safer locations, cleaning up 

stillborn young, electric fencing, electrified fladry or guard animals). Several varieties of these programs exist, focusing variously on: compensation for livestock 

losses; cost-share and technical assistance for the use of nonlethal tools that reduce 

conflict; and incentive payments such as payment for presence of live wolves. These 

programs are very beneficial. Where there is a need to improve these programs, 

they should be so improved. 

Related to this concern, the legalized killing of carnivores to prevent livestock loss 

does not have a strong record of effectiveness (Treves et al. 2016). Most studies on 

the topic conclude that the killing has no positive effect and in some cases a 

counter-productive effect. Two studies of lethal control offer a countervailing sense. 

One of these studies concluded that lethal control had a slight effect in reducing 

depredation (Herfindal et al. 2005) and the other reported a significant reduction 

(Bradley et al. 2015). The concern is that those results are not reliable because both 

studies are associated with non-trivial methodological shortcomings (Treves et al. 

2016). 

Treves et al. (2016) also reviewed studies aimed at assessing the efficacy of nonlethal control. Of the studies reviewed, only two were robustly designed (i.e., 

random assignment of treatments) and thereby capable of providing reliable inference. One of these studies involved livestock-guarding dogs and the other involved 

‘‘fladry,’’ a visual deterrent. In both studies the nonlethal control method resulted 

in reduced depredation. 

58 

Question 4. Can you address the premise that liberalizing the culling or trophy 

hunting of wolves will reduce poaching and livestock loss, and improve the population status of native carnivores? 

Answer. Some advocates of wolf hunting assert that increased allowances for legal 

wolf killing (hunting, lethal control, culling) will reduce poaching and improve attitudes about wolves—thereby improving the conservation status of wolves. This view 

is not supported by the best-available science nor is it supported by basic moral 

values. 

Best-available science—For example, sociological research focused on hunters and 

livestock owners living within the geographic range of Wisconsin wolves indicates 

that those groups were, on the whole, as inclined to poach wolves before the liberalization of legal wolf killing as afterward (Browne-Nunez et al. 2015). These groups 

also had similarly negative attitudes about wolves, before and after the liberalization of legal wolf killing. The same conclusion is supported by a different study 

using different research methods (Hogberg et al. 2015). A third study, relying again 

on different research methods, also found that tolerance for wolves declined and inclination to poach increased throughout an 8-year period during which legal wolf 

killing was liberalized (Treves et al. 2013). Surveys conducted by the Montana Dept. 

of Fish and Game also indicate that tolerance for wolves among hunters was similarly low before and after wolf hunting (Pauley 2013). 

Those studies focusing on attitudes and behavioral intentions are bolstered by ecological studies suggesting that rates of poaching increased with the liberalization of 

legal killing in Wisconsin (Chapron and Treves 2016; Treves et al. 2016a). Moreover, 

the claim that liberalized legal killing of wolves would improve the conservation status of wolves is not supported by the tendency of wolf populations to have declined 

in response to states’ management of legal wolf killing. 

Related to this concern, the legalized killing of carnivores to prevent livestock loss 

does not have a strong record of effectiveness (Treves et al. 2016b). Most studies 

on the topic conclude that the killing has no positive effect and in some cases a 

counter-productive effect. Two studies of lethal control offer a countervailing sense. 

One of these studies concluded that lethal control had a slight effect in reducing 

depredation (Herfindal et al. 2005) and the other reported a significant reduction 

(Bradley et al. 2015). The concern is that those results are not reliable because both 

studies are associated with non-trivial methodological shortcomings (Treves et al. 

2016b). 

Treves et al. (2016b) also reviewed studies aimed at assessing the efficacy of nonlethal control. Of the studies reviewed, only two were robustly designed (i.e., 

random assignment of treatments) and thereby capable of providing reliable inference. One of these studies involved livestock-guarding dogs and the other involved 

‘‘fladry,’’ a visual deterrent. In both studies the nonlethal control method resulted 

in reduced depredation. 

Basic moral values [This section is a synopsis of a portion of Vucetich and Nelson 

(2014)]—Some advocates of wolf hunting believe that legal wolf hunting would be 

beneficial to wolf conservation because it would lead to a reduction in rates of 

poaching by inspiring respect for wolves among those who are currently intolerant. 

This view is at odds with basic moral values for several reasons: 

First, many instances of wolf poaching are wrong because they are primarily motivated by hatred of wolves. These instances of poaching qualify as wrongful deaths, 

if not a hate crime against nature. To legalize such killings does not make them 

any less wrong. Moreover, people who threaten to poach wolves unless wolf killing 

is legalized are engaging a kind of ecological blackmail by threatening harm to 

wolves unless their demands to kill wolves are met. If poaching is wrong because 

it represents an adequate reason to kill, then it is not made right simply by legalizing the killing of wolves. 

Second, this argument is a perverse misinterpretation of the relationship between 

respect and hunting. Hunting reinforces or deepens respect for the deer because the 

hunter knows the deer sacrificed its life for the sustenance of the hunter. In this 

relationship, respect exists before the hunting; the hunting did not generate respect 

ex nihilo. In other words, the hunter respects the deer in spite of killing him, not 

because she killed him. By contrast, the wolf-hater’s a priori attitude is hatred, not 

respect. Thus, his killing the wolf is an exercise of hatred—he would likely celebrate 

the killing. Without moral concern for the wolf, the wolf’s sacrifice cannot be recognized. For hunters, recognition of sacrifice is necessary for the realization of respect. 

Third, there is a perverted sense in which allowing those who hate wolves to hunt 

wolves would result in respect for wolves. That is, hatred is sometimes dissolved 

when the hater becomes familiar with his victim, and hunting provides an opportunity to become familiar with the victim. However, if this reasoning were generally 

59 

appropriate, killing would be a commonly prescribed therapy for unjustified hatred. 

It is not. 

Wolf intolerance is likely not distinct from other irrational intolerances (such as 

racism or sexism). That is, no one expects individual wolf haters to change their attitudes. Instead, over time their behaviors become less tolerated and their attitudes 

become less common. To paraphrase Martin Luther King, the long arc of history 

bends toward justice. 

Question 4 makes reference to whether trophy hunting, in particular, is a proper 

management tool for wolves. In general, wildlife management is proper when it can 

provide robust answers to three questions: What is the goal?, Why is the goal appropriate?, and How will planned management actions achieve that goal?. These questions have not been robustly answered in any of the lower 48 states where wolf 

hunting has occurred. Those instances represent improper wildlife management. 

Michigan illustrates the concern, where the stated reason for wolf hunting was 

to protect livestock and human safety. While protecting human safety and livestock 

are laudable goals, there is little reason to think that wolf hunting as planned 

would have alleviated either concern. The weakness of those reasons for wolf hunting lead a reasonable person to believe that the real (unstated) reason to hunt was 

to mollify hatred for wolves held by a small minority. Hatred is not an acceptable 

reason to hunt any creature. For a formal account of this perspective on Michigan 

wolf hunting, see Vucetich et al. (2016). 

The properness of wildlife management might also be judged by the North 

American Model of Wildlife Conservation, which is held in high regard by many 

hunting organizations, wildlife professionals, and state agencies. A detailed analysis 

of wolf hunting in Michigan clearly indicates that wolf hunting violates four of the 

seven principles of the North American Model—i.e., wildlife should only be killed 

for a legitimate purpose, wildlife is a public trust, and principles of democracy and 

best-available science. For details, see Vucetich et al. (2016). 

In other states, wolf hunting has been motivated, in part, by state game and fish 

agencies’ interest to satisfy a segment of the hunting community. This motivation 

may be sensible when all of the following conditions hold: 

• wolves cause an appreciable decline elk or deer abundance; 

• wolf hunting (as implemented) results in a significant increase in elk or deer 

abundance without impairing the health and functioning of the wolf 

population; 

• increased elk or deer abundance will translate to appropriate levels of 

hunters’ satisfaction with their hunting experience; and 

• interests to increase ungulate abundance outweigh interest to decrease 

ungulate abundance. 

That all those conditions routinely do not hold is indicated by the following 

circumstances: 

• Ungulate populations in many portions of current and former wolf range are 

overabundant to the point of causing detriment to agriculture, livestock, 

forestry, private property, and human safety (deer-vehicle collisions). This circumstance is widely acknowledged by state and Federal wildlife agencies. 

• Of the elk populations deemed by state wildlife agencies to be underabundant, poor habitat rather than predation is thought (by state biologists) 

to be the concern. 

• Some state plans for wolf hunting, if implemented, might reduce wolf abundance to the point of increasing ungulate abundance, but would also risk 

reducing wolf abundance to the point of falling below minimum levels 

(Wyoming is an example). Other state plans entail essentially no such risk, 

but also have essentially no chance of resulting in increased ungulate abundance (Michigan is an example). 

• Hunting success is relatively high in states such as Idaho and Montana. 

Question 5. Are wolves a threat to humans? 

Answer. Except in the very rarest of circumstances, wolves are not a threat to 

human safety. Incidents of wolves harming people are incredibly rare. Wolves 

generally avoid people and in almost all cases people have nothing to fear from 

wolves in the wild. 

During the oversight hearing held on September 21, 2016, Rep. LaMalfa (CA) 

mentioned an incident in New Mexico, where parents placed their children in 

‘‘cages’’ on the roadside while waiting to be picked up by a school bus. Associate 

60 

Professor Daniel MacNulty, wolf expert and close colleague, said of this episode 

(Berlin 2013), 

‘‘. . . I think people are over-reacting here, as is often the case with wolves 

. . . wolves are not going to be attacking children at the bus stop. The 

suggestion that they would is fear-mongering and unhinged from the facts. 

I think the ‘‘kid cages’’ are a publicity stunt designed to stoke opposition 

to Mexican wolf recovery in general and to the Federal Government in 

particular.’’ 

I agree with that assessment and I am unaware of any one knowledgeable of 

wolves who disagrees with that assessment. 

Even a casual perusal of press coverage plainly reveals that these ‘‘cages’’ had, 

prior to any concern about wolves, been serving as ‘‘shelters’’ to protect children 

from inclement weather (see for example a Fox News report by Miller 2013). The 

shelters were transformed in the public’s mind into notorious ‘‘cages’’ after they 

were portrayed as such by special interests with an opposition to wolves that is not 

rooted in an accurate understanding of wolves. 

In the 21st century, only two known deaths have been attributed to wild wolves 

in all of North America. There have been no deaths from wolves in the conterminous 

United States. Far more Americans are killed by bees or dogs than by wolves. Far 

more Americans are injured or killed in deer-vehicle collisions (U.S. Dept of 

Transportation). Our overall response to any threat to human safety should be, in 

part, commensurate with the risk of that threat. Moreover, it should be acknowledged that large carnivores are, on the whole, beneficial to human safety by helping 

to reduce the number of deer-vehicle collisions (Gilbert et al. 2016). 

On the extraordinarily rare occasions when a wolf has appeared to be even potentially problematic, the appropriate agency (state or federal) has moved swiftly to address any possible threat. For example, in May 2015, the Mexican Wolf Interagency 

Field Team lethally removed a wolf that was exhibiting unusual activity near 

residents and populations in Catron County, New Mexico. 

The false impression that wolves are a threat to human safety is fostered by the 

interaction between (i) a public that is easily and overly impressed by certain kinds 

of fear and (ii) those who fabricate or exaggerate the threat that wolves represent. 

The seriousness of these exaggerations is illustrated with two examples from 

Michigan: 

—A State Senator conveyed a ‘‘horrifying and fictional’’ account of wolves 

threatening humans. That account was included in a 2011 resolution urging 

the U.S. Congress to remove ESA protections for gray wolves in Michigan. 

Later the Senator conceded that the account was not true. See Oosting (2013) 

for details. 

—Adam Bump, an official from the Michigan Department of Natural Resources, 

‘‘misspoke’’ when he was interviewed by Michigan Radio (a National Public 

Radio affiliate) in May 2013. Bump apparently said to the interviewer: ‘‘You 

have wolves showing up in backyards, wolves showing up on porches, wolves 

staring at people through their sliding glass door while they’re pounding on 

it exhibiting no fear.’’ Later, Bump conceded that this did not happen. See 

Barnes (2013) for details. 

Question 6. Can you further explain why you think wolves should not be delisted? 

Answer. A species should not be delisted until it is recovered. A species is recovered when it no longer fits the legal definition of an endangered species, i.e., when 

it is not ‘‘in danger of extinction throughout all or a significant portion of its range’’ 

and when the species is unlikely to fit the definition in the foreseeable future. The 

quoted text is the legal definition of an endangered species as specified in the 

Endangered Species Act (ESA). That legal definition means that the ESA has at 

least some restorative mandate beyond ensuring that a species is merely not at risk 

of extinction. Recovery requires a species to be broadly distributed throughout portions of its historic range. 

Those views of recovery are well supported by considerable scholarship (e.g., 

Vucetich et al. 2006, Tadano 2007, Enzler & Bruskotter 2009, Geenwald 2009, 

Kamel 2010, Carroll et al. 2010, and Bruskotter et al. 2014, Nelson et al. 2016, and 

references therein), congressional intent (H.R. Report 412, 93rd Congress, 1973), the 

history of endangered species legislation in the United States (see the section entitled ‘‘Why Focus on Significant Portion of Range? ’’ Vucetich et al. 2006), the 

Findings section of the ESA (see second from last paragraph of Nelson et al. 2016), 

and are consistent with numerous decisions made by several Federal courts (e.g., 

Enzler and Bruskotter 2009). 

61 

By this view of recovery, wolves in the conterminous United States are not recovered and should not be delisted because wolves occupy only about 15 percent of their 

former range. 

During the oversight hearing held on September 21, 2016, Rep. Benishek (MI) 

seemed to indicate that this view of recovery requires a species to occupy all of its 

former range. The explanation offered above indicates that this plainly not true. 

Moreover, no one working to better understand the legal meaning of recovery has 

ever suggested this to be the case. For additional discussion on this point see Nelson 

et al. (2016). 

Some have argued that this view of recovery requires a species to occupy all of 

its former range. The explanation offered above indicates this plainly not true. 

Moreover, no one working to better understand the legal meaning of recovery has 

ever suggested this to be the case. For additional discussion on this point see Nelson 

et al. (2016). 

The FWS recently argued, in a proposed rule, that wolves should be delisted because they currently occupy all of the range that they can possibly occupy (78 Fed. 

Reg. 35,664). There are two concerns with this position. First, the inability to 

achieve recovery is not a reason to delist. Second, abundant evidence indicates that 

wolves could feasibly occupy portions of their former range that they do not currently occupy. For details, see Bruskotter et al. (2014). 

The Director of the FWS seems to suggest, in a letter to the editor of the 

New York Times (September 4, 2014) that limited resources available to the FWS 

are a reason to delist wolves and that delisting wolves would allow the FWS to focus 

resources on other species in greater need of attention. Limited resources is not an 

adequate reason to delist a species prior to its being recovered. If limited resources 

prevent the FWS from actively recovering a species, that species should remain protected by the ESA until the FWS has sufficient resources to actively recover that 

species. For details, see Nelson and Vucetich (2014). 

No less important than the legal meaning of endangerment, is that recovery requires the existence of adequate regulatory mechanisms (Sec. 4(a)(1)(D) of the ESA). 

There are significant concerns that such mechanisms are not in place. These concerns are reflected, in part, by two Federal courts decisions, one pertaining to 

Minnesota and Wyoming (HSUS et al. v. Jewell et al. 2014. U.S. District Court, D.C. 

and Defenders of Wildlife et al. v. Jewell et al. U.S. District Court, D.C.). Related 

concerns have been raised for wolves in Wisconsin. [Dr. Adrian Treves of University 

of Wisconsin and colleagues sent an open letter to the FWS in 2014, describing concerns about use of the best available science in the state of Wisconsin’s post 

delisting monitoring report on gray wolves. http://faculty.nelson.wisc.edu/treves/ 

reports/Letter%20to%20USFWS/Response_to_Acting_Director_Wooley_USFWS.pdf.] 

Adequate understanding of what constitutes wolf recovery will require the FWS 

to: 

1. Develop policy on ‘‘significant portion of range’’ that is consistent with the 

ESA. I believe the courts will eventually decide that the current FWS policy 

on this topic is inconsistent with the ESA. 

2. Develop a robust national plan for wolf conservation and recovery. 

Question 7. What are public attitudes currently toward large carnivores, such as 

wolves? 

Answer. Americans’ attitudes toward large carnivores, including wolves, are largely positive. Recent research indicates that attitudes toward wolves have become increasingly positive over the past four decades (George et al. 2016). In fact, 3 in 5 

Americans hold a positive attitude toward wolves only 1 in 10 Americans have significantly negative attitudes about wolves (George et al. 2016; see figure included 

with my written testimony (see page 54). Even those living in wolf range have a 

largely positive attitude about wolves. For example, only 18 percent of non-tribal 

residents living within the geographic range of wolves in Wisconsin had a very 

unfavorable view of wolves (Shelley et al. 2011). 

Despite widespread positive attitudes about wolves, some have a false impression 

that the public has a low tolerance for wolves. There are at least three explanations 

for this misimpression. First, some sociological studies suggest that attitudes toward 

wolves have become more negative over time; however, these studies tend to focus 

on hunters, those familiar with hunting, and rural residents living within wolves’ 

range (e.g. Treves et al. 2013, Ericsson & Heberlein 2003). [A poll of attitudes about 

wolves was conducted by the state of Montana in 2012. The plurality of respondents 

in that poll expressed being very intolerant of wolves (Montana Fish, Wildlife & 

Parks 2012). Methodological details of that poll have not, to our knowledge, been 

subjected to scientific peer-review. A concern with that poll is that the results are 

62 

an artifact of disproportionate or misrepresentative sampling.] While it is important 

to address these attitudes, they are not representative of the interests of most 

Americans. 

Second, other research indicates that biased media coverage gives the impression 

of low and deteriorating tolerance for wolves. For example, Houston et al. (2010) 

examined North American news coverage about wolves over a 10-year time period 

(1999–2008). They found 72 percent of ∼30,000 paragraphs they analyzed, represented wolves negatively. They also found that these negative expressions had increased significantly over time. Yet, media’s coverage of wolves does not accurately 

represent Americans’ attitudes, and such media bias could lead to distorted perceptions of public opinion (see George et al. 2016). 

Third, the perceptions of wildlife professionals working for state agencies may be 

distorted by interactions with individuals who are not representative of the broader 

public or even the interest groups to which they belong. An example serves to illustrate: In 2003 the Utah Division of Wildlife Resources hosted a series of scoping 

meetings concerning wolf management. About 80 percent of the ∼900 people who attended those meeting identified ‘‘do not allow wolves in Utah’’ as a management priority. At the same time (i.e., in 2003), a systematic study of attitudes toward wolves 

found that 74 percent of Utahans exhibited positive attitudes toward wolves. 

This case illustrates that state agencies can get the false impression of low support for wolves on the basis of such interactions. The concern is that agencies’ contact with the public is not always representative of the public’s attitude on the 

whole, or even of those who care about wildlife conservation issues. This circumstance is regrettable, but understandable, given that scoping meetings, for 

example, are often attended disproportionately by stakeholders who are especially 

upset about an issue. This case and these circumstances are detailed in Bruskotter 

et al. (2007). 

With respect to the small segment of Americans with negative attitudes about 

wolves and other carnivores, there is value in understanding the details of those attitudes. Psychological research indicates that intolerance for wolves (and other large 

carnivores) may originate from negative emotional reactions toward these species, 

and perceptions of wolves’ impacts that are grossly at odds with scientific knowledge 

about these species (Slagle et al. 2012, Johannson et al. 2012). 

Other sociological research makes the case that poor attitudes about wolves are 

associated, less so with the perceived negative impact of wolves, and more so with 

‘‘deep-rooted social identity’’ (Naughton-Treves et al. 2003; see also Heberlein 2012). 

While it is important to ameliorate the financial losses caused by wolves for those 

few individuals whose animals are actually harmed, doing so is not likely to cause 

those individuals to have more positive attitudes, as was suggested by NaughtonTreves et al. (2003) and demonstrated longitudinally by Treves et al. 2013, BrowneNunez et al. 2015, and Hogberg et al. 2015. 

A basic principle of wildlife management is that it be based on sound science. For 

that reason, it would be poor governance to manage a wildlife population on the 

basis of attitudes about wildlife that are profoundly untethered from scientific 

knowledge about wildlife. The proper role of government in a case like this is to 

work to ease the misperceptions of that small segment of Americans. 

Unfortunately, there are notable examples of state governments working to fuel 

hatred of wolves and inflame tensions between interest groups. For example, days 

after Congress delisted wolves in Idaho and Montana, the governor of Idaho 

declared wolves to be a ‘‘disaster emergency’’ (Zuckerman 2011). That phrasing, 

‘‘disaster emergency,’’ is usually reserved for truly tragic events such as catastrophic 

hurricanes and tornadoes. 

No less important than positive attitudes about wolves are attitudes about the 

Endangered Species Act (ESA). Existing data indicate that public support for the 

ESA is widespread and strong. An earlier, sociological study concluded that four of 

every five Americans are supportive of the ESA (Czech & Krausman 1997). That 

study also indicated that 49 percent of respondents believed that ESA should be 

strengthened. In contrast, only 16 percent believed it should be revoked or 

weakened. 

Some advocates of delisting wolves are concerned that continuing to protect 

wolves under the ESA will erode public support for the ESA. However, recent polling suggests that attitudes toward the ESA have remained positive over the past 

two decades. In particular, one poll, conducted in 2015, indicates that approximately 

four of every five Americans are supportive of the ESA (Harris Interactive 2011). 

Another recent poll indicates that support for the ESA transcends political ideology. 

That is, support for the ESA by self-identified liberals, moderates, and conservatives 

is 96 percent, 94 percent, and 82 percent, respectively (Tulchin Research 2015). 

Finally, data collected in 2014 by the research firm GfK indicates that attitudes 

63 

toward the ESA similarly positive in wolf recovery areas and the remainder of the 

country (see figure below, J.T. Bruskotter, The Ohio State University, unpublished 

data). 

Support for the Endangered Species Act (ESA) by Region 

The values and willpower of the American people, on the whole, support the ESA 

and wolf conservation. We are also a sufficiently resourceful and generous people, 

committed to fairly redressing the concerns and negative attitudes held by a small 

segment of Americans. 

LITERATURE CITED 

The literature list for this Q&A section is part of the hearing record and is being 

retained in the Committee’s official files. 

Mr. GOHMERT. Thank you, Doctor. 

At this time, the Chair recognizes Director Sandoval for 

5 minutes. 

STATEMENT OF ALEXANDRA SANDOVAL, DIRECTOR, 

NEW MEXICO DEPARTMENT OF GAME & FISH, SANTA FE, 

NEW MEXICO 

Ms. SANDOVAL. Good afternoon, Chairman Gohmert, Ranking 

Member Dingell, members of the subcommittee. Thank you for the 

opportunity to appear today to discuss the status of the Federal 

Government’s management of wolves, specifically the Mexican gray 

wolf. 

The state of New Mexico, through the New Mexico State Game 

Commission and the Department, exercises trust ownership and 

control over New Mexico’s wildlife, including the duty to safeguard 

the wildlife in the interest of the public. 

In our quest to conserve our state’s wildlife and recover federallylisted imperiled species, what has proven to be an unnecessary yet 

significant hurdle is a cloud of uncertainty and added challenges to 

state self-governance resulting from the U.S. Fish and Wildlife 

Service’s failure to implement section 6 of the Endangered Species 

Act. 

Section 6 mandates that the Service ‘‘cooperate to the maximum 

extent practicable with the states.’’ As written, section 6 

contemplates a significant role for the states in the management 

64 

and conservation of threatened and endangered species, a role that 

has yet to be fully recognized in the state of New Mexico. 

As you may be aware, the Mexican wolf was first added to the 

list of endangered species in April of 1976, over 40 years ago. Over 

these 40 years, the Service has spent over $25 million on the 

recovery of the sub-species, which to date has not been declared recovered. At last count, less than 100 wolves exist in the wild. While 

no single factor is to blame for the lack of success recovering the 

Mexican wolf, one factor looms larger than others: the Service’s 

failure to cooperate with the states. 

The Service’s various cooperative failures can be broken down 

into three main categories: first, the imposition of Federal decisions 

and objections over New Mexico’s repeatedly stated concerns; 

second, the lack of cooperation pertaining to an awareness of social 

and cultural considerations; and third, the lack of cooperation on 

wolf releases. 

Regarding the first issue, New Mexico has absolutely no confidence that the Service takes seriously the state’s concerns, and 

the only recovery plan for the Mexican wolf, a plan crafted in 1982, 

the recovery goal was defined as at least 100 wolves in the wild. 

However, in June of 2013, the Service published a proposed revision to the nonessential experimental population of the Mexican 

wolf. During that rule revision process, the Department continually 

asked the Service for a population objective, and was told on every 

occasion that this number would not be presented until a new recovery plan had been finalized. 

Despite the Service’s promise that the revised rule would not 

contain a population objective, the rule, which was finalized in 

2015, did contain a numerical target of 300 to 325 wolves across 

New Mexico and Arizona. The Service not only chose to ignore our 

concerns, but they also chose to publish a population goal, despite 

promising New Mexico they would take no such action. 

Second, as with any well-planned program, fundamental to its 

long-term success, is stakeholder support. This is another arena in 

which the Service has failed. Stakeholder support is particularly 

paramount when working to recover a carnivore species that can 

negatively impact livestock operations, wildlife species management, and a host of related issues. The Service has failed in this 

regard. And, frankly, it is a fatal flaw. 

Regarding the third issue, the Service began releasing Mexican 

wolves in New Mexico in 1998. Releases back then at least had a 

colorable argument that they were guided by the 1982 recovery 

plan. Modern releases now occur under the guidance of the 2015 

rule. However, that rule itself provides no guidance on the definition of recovery. If a population of 325 wolves is accomplished, 

would that trigger a delisting? Nobody knows. 

New Mexico has zero confidence that, once 325 wolves exist in 

the wild, the Service will not announce a recovery target of 600 or 

maybe even 1,000 wolves on the landscape. For years, the Service 

has moved forward with introduction of the Mexican wolf without 

the guidance of a current comprehensive science-based recovery 

plan to frame and inform the effort, and without dedicating sufficient financial or other resources to the program to ensure its success. New Mexico encourages the U.S. Fish and Wildlife Service to 

65 

1State ex rel. Sofeico v. Heffernan, 41 N.M. 219, 227 (1936); N.M. Stat. Ann. §§ 17–1–1 and 

17–1–14; see N.M. Stat. Ann. §§ 17–1–1 through 17–6–11. 2 16 U.S.C. § 1535(a). 

3 Erwin Chemerinsky, Enhancing Government: Federalism for the 21st Century 99 (2009). 

re-examine section 6 of the Endangered Species Act and then 

redouble its effort at implementation of the cooperative mandate. 

Thank you for the opportunity. 

[The prepared statement of Ms. Sandoval follows:] 

PREPARED STATEMENT OF ALEXANDRA SANDOVAL, DIRECTOR, NEW MEXICO

DEPARTMENT OF GAME AND FISH

INTRODUCTION

Chairman Gohmert, Ranking Member Dingell, members of the subcommittee, 

thank you for the opportunity to appear today to discuss the status of the Federal 

Government’s management of wolves, specifically, the Mexican gray wolf (Canis 

lupus baileyi). 

The state of New Mexico, through the New Mexico Game Commission and the 

Department of Game and Fish, exercises trust ownership and control of New 

Mexico’s wildlife, including ‘‘the duty of safeguarding this property in the interest 

of the public.’’ Cognizant of its trust obligations, the New Mexico legislature has enacted a comprehensive statutory scheme to conserve, manage, and protect New 

Mexico’s wildlife.1 Together, the Commission and the Department actively manage 

wildlife across the state, including carnivore species such as the bear and cougar; 

ungulate species such as deer, elk, bighorn sheep and antelope, which serve as prey 

to carnivores; and numerous other fish and wildlife species. With over 100 years of 

experience in restoring and managing wildlife populations across the state, the Department excels at wildlife conservation. 

In 1973 Congress established a program for the conservation of threatened and 

endangered species and a means whereby the ecosystems upon which those species 

depend may be conserved—the Endangered Species Act (the Act). See 16 U.S.C. 

§ 1531(b). It is as true today as it was in 1973, and arguably always has been, that 

the creation with which we share this earth—fish, wildlife, plants, etc.—are of 

aesthetic, ecological, educational, historical, recreational, scientific, and I would add 

spiritual value to our Nation and its people. 

We New Mexicans value our wildlife resources and strive to be excellent stewards 

of this incredible natural resource. One of the species that we are most proud of 

in New Mexico is the desert bighorn sheep. In 1980, New Mexico’s desert bighorn 

population totaled less than 70 and could only be found in two isolated mountain 

ranges, prompting the state to add the species to its list of endangered species. 

Since then, through the tireless efforts of numerous New Mexicans to conserve and 

increase the number of self-sustaining populations, New Mexico now boasts a population of over 1,000 desert bighorns across at least seven mountain ranges. In 2011 

we removed the species from the state endangered species list. Various other once 

imperiled or extinct resident New Mexican species now thrive or on the path to recovery. We know how to conserve wildlife and, when necessary, recover imperiled 

species. 

In the quest to conserve our wildlife and recover federally listed imperiled species, 

what has proven to be an unnecessary yet significant hurdle is the cloud of uncertainty and added challenges to state self-governance resulting from the U.S. Fish 

and Wildlife Service’s (Service) failure to implement Section 6 the Endangered 

Species Act. Section 6 mandates that the Service ‘‘cooperate to the maximum extent 

practicable with the states.’’ 2 Section 6 contemplates a significant role for the states 

in the management and conservation of threatened and endangered species, a role 

that has yet to be fully realized. 

The constitutional scholar Erwin Chemerinsky identified ‘‘state experimentation’’ 

as one of the main functions served by the Federalist division of political authority 

in the United States.3 The Service’s failure to implement Congress’ mandate to 

cooperate with the states has unnecessarily stymied more robust state experimentation in the realm of species recovery. More often than not, through its sanscooperation implementation of the Endangered Species Act, the Service co-opts 

species recovery efforts, leaving little or no opportunity for the states to pursue 

recovery on terms that fit state exigencies and eccentricities. The Mexican wolf recovery program is the cover story in the Service’s failure to cooperate story. 

66 

4 41 Fed. Reg. 17740 (Apr. 28, 1976). 

5 43 Fed. Reg. 9607 (Mar. 9, 1978). 

6 Id. 7 78 Fed. Reg. 35664 (Jun. 13, 2013). 

8 80 Fed. Reg. 2488 (Jan. 16, 2015). 

9 Recovery Plan at 23. 

10 63 Fed. Reg. 1752, 1753 (Jan. 12, 1998). 

BACKGROUND

The Mexican Wolf 

The Mexican wolf is the smallest gray wolf subspecies in North America, with an 

adult weight of 50 to 90 pounds, a length of 5 to 6 feet, and a height at shoulder 

of 25 to 32 inches. Mexican wolves are typically a patchy black, brown to cinnamon, 

and cream color, with primarily light underparts. The Mexican wolf’s smaller stature is a product of the habitat it occupies. The Mexican wolf historically occupied 

central and northern Mexico with small reaches into portions of the American 

Southwest. 

As defined by the Service in its 1982 Mexican wolf Recovery Plan, the core historical range of the subspecies was in Mexico, while core historical habitat in the 

United States was limited to the very southwest corner of New Mexico and the 

southeast of Arizona. When initially releasing wolves into the wild in 1998 the 

Service recognized that the reintroduction site in the Blue Range Wolf Recovery 

Area was at the northern extent of an expanded historical range for the subspecies. 

The Mexican gray wolf subspecies was listed as endangered under the 

Endangered Species Act on April 28, 1976.4 Subsequently, on March 9, 1978, the 

entire gray wolf species (Canis lupus) in North America south of Canada was listed 

as endangered, except in Minnesota where it was listed as threatened.5 The listing 

of the gray wolf in the contiguous United States and Mexico therefore subsumed the 

separate listing of the Mexican gray wolf subspecies.6 In February 2012, the Service 

recommended that the listing of the entire gray wolf species be revised to reflect 

the distribution and status of various gray wolf populations. On June 13, 2013, the 

Service published a proposed rule to delist the gray wolf and maintain protections 

for the Mexican gray wolf by listing it as an endangered subspecies.7 The final rule 

listing the Mexican gray wolf subspecies as endangered was issued on January 16, 

2015.8

Recovery Planning 

The Mexican Wolf Recovery Plan (‘‘Recovery Plan’’) was adopted in 1982. The 

Recovery Plan’s ‘‘prime objective’’ is ‘‘[t]o conserve and ensure the survival of Canis 

lupus baileyi by maintaining a captive breeding program and re-establishing a viable, self-sustaining population of at least 100 Mexican wolves in the middle to high 

elevations of a 5,000-square mile area within the Mexican wolf’s historic range.’’ 9

The Recovery Plan does not contain objective and measurable recovery criteria for 

delisting as required by section 4(f)(1) of the ESA, other than the 100-wolf and 

5,000-square-mile goals referenced above. 

The Service has initiated various failed efforts to revise the Recovery Plan. First, 

in 1995, the Service reported its intent to release a draft revised recovery plan in 

1998.10 A 1998 draft revised Recovery Plan never came to fruition. Later, in 2003, 

the Service again attempted a revision of the 1982 Recovery Plan, which effort was 

abandoned. The 2003 effort was followed by a 2010 attempt, which also failed to 

produce a revised plan. Finally, in 2015, the Service invited the states of New 

Mexico, Arizona, Colorado, and Utah as well as a variety of independent and contract scientists to a series of working group meetings to contribute to the development of a revised recovery plan. According to the terms of a settlement agreement, 

which the court has yet to approve, the Service has announced its intention to publish a revised Recovery Plan by the end of November 2017. 

While New Mexico is optimistic that the current recovery planning effort will ultimately produce a revised plan, until a revised recovery plan is finalized, the 1982 

Recovery Plan will remain the only completed recovery plan for the species, and the 

now obsolete 100-wolf and 5,000-square-mile objectives will remain the only objective and measurable recovery criteria guiding recovery. Given the lack of current 

measurable and objective recovery criteria, New Mexico remains in the dark about 

important recovery questions—how many wolves constitute a recovered population 

and where these wolves will occur. Forty years into the program, New Mexico 

should not be as in the dark on these issues as it is. 

67 

11 Environmental Impact Statement for the Proposed Revision to the Regulations for the Nonessential Experimental Population of the Mexican Wolf (‘‘Final EIS’’) (Nov. 2014) at 4. 12 Id. 13 63 Fed. Reg. 1752 (Jan. 12, 1998) (‘‘1998 Rule’’). 14 80 Fed. Reg. 2512 (Jan. 16, 2015) (‘‘2015 Rule’’). 15 Id. at 2518. 16 Id. 175 Id. at 2512. 18 Id. at 2517. 

Captive Breeding and the 1998 Rule 

A binational captive-breeding program between the United States and Mexico was 

established in the late 1970s, with the capture of the last remaining Mexican wolves 

in the wild. Referred to as the Mexican Wolf Species Survival Plan, the captive 

breeding program’s ultimate objective is to provide healthy offspring for release into 

the wild, while conserving the Mexican wolf subspecies genome.11 The captive 

breeding program originated with seven founding wolves, and has grown to approximately 248 wolves in 55 facilities in the United States and Mexico.12 The wolves 

in the captive population are the only source of animals for release into the wild. 

The success of the captive breeding program has resulted in surplus animals, allowing the Service to undertake efforts to reintroduce populations of the Mexican wolf 

into the wild. 

On January 12, 1998, the Service published a final rule establishing the Mexican 

Wolf Experimental Population Area (‘‘MWEPA’’) in central Arizona, New Mexico, 

and a small portion of northwestern Texas.13 In March of 1998, the Service released 

11 Mexican wolves from the captive breeding program into the wild. 

Under the 1998 Rule, the wolves were released into the Blue Range Wolf Recovery 

Area (‘‘Blue Range’’) of Arizona and New Mexico, which is within the MWEPA. 

Mexican wolves released into the Blue Range and their offspring are designated as 

a nonessential experimental population, which allows for greater management flexibility to address wolf conflict situations such as livestock depredations and nuisance 

behavior. The Blue Range is a defined geographic area that encompasses the entire 

Apache and Gila National Forests and is divided into primary and secondary recovery zones. Under the 1998 Rule, wolves are not allowed to establish territories on 

public lands wholly outside the Blue Range boundary and must be retrieved by the 

Service. At the end of 2014, the Service estimated that 110 wolves inhabited the 

United States in central Arizona and New Mexico, which count exceeded the criteria 

set out in the Recovery Plan. 

The 2015 Rule 

When the Service announced its intention to revise the 1998 Rule, the Department communicated its objection to the proposed revision. New Mexico explained 

that it was nonsensical to modify the 1998 Rule without first updating the now 

obsolete 1982 Recovery Plan. How could the Service propose a rule that might contemplate hundreds of wolves when the Recovery Plan did not venture beyond 100? 

The Department stressed to the Service the importance of revising the Recovery 

Plan to establish what contribution would be required of Mexican wolf historical 

range in New Mexico and Arizona toward Mexican wolf recovery. The Service moved 

forward with its revision of the 1998 Rule despite New Mexico’s objection. 

On January 16, 2015, the Service issued a final rule revising the 1998 Rule.14 As 

explained by the Service, the revisions were needed to help ‘‘enhance the growth, 

stability, and success of the experimental population.’’ 15 The 1998 Rule required 

that Mexican wolves stay within the Blue Range, leading to the removal of wolves 

that strayed into the larger MWEPA. According to the Service, the 1998 Rule 

‘‘constrained the number and location of Mexican wolves that can be released from 

captivity into the wild,’’ ‘‘constrain[ed] the growth of the wild population,’’ and 

‘‘required [the Service] to implement management actions that disrupt social structure.’’ 16 The Service issued the 2015 Rule to modify the geographic boundaries in 

which Mexican wolves are managed, as well as the management regulations that 

govern the initial release, translocation, removal, and take of Mexican wolves.17 In 

the 2015 Rule, the Service established a population objective of 300 to 325 Mexican 

wolves within the MWEPA throughout both Arizona and New Mexico.18 The 2015 

Rule includes a population objective that is triple that included in the Recovery Plan 

for the species and establishes a vastly expanded experimental population area. 

Whereas the 1998 Rule established an approximately 7,000-square-mile area within 

which the species could disperse, the 2015 Rule expanded the area by more than 

an order of magnitude to approximately 154,000 square miles. 

68 

19 16 U.S.C. § 1535(a). 20 Estimated Funds Expended by Lead Agencies for Mexican Wolf Recovery and Reintroduction, available at https://www.fws.gov/southwest/es/mexicanwolf/pdf/MW_Project_Costs_to_ 

Date.pdf. 

COOPERATION UNDER THE ENDANGERED SPECIES ACT

Section 6(a) of the Act requires that in carrying out the activities authorized by 

the ESA, the Service cooperate to the maximum extent practicable with the states.19

Through Section 6, Congress incorporated into the Act principles of cooperative federalism memorialized in the U.S. Constitution. That is, the powers delegated to the 

Federal Government are few and defined and those which remain in the state governments are numerous and indefinite and extend to all the objects which concern 

the lives, liberties, and properties of the people, and the internal order, improvement, and prosperity of the states. 

Section 6 contemplates a much different cooperative scheme than that posited by 

the U.S. Fish and Wildlife Service in the Mexican Wolf Recovery Program. The Act’s 

legislative history tells us that Congress’s intent in drafting Section 6 was not purely academic. Consider the statement from Senator Tummey (D. Cal), when he called 

Section 6 ‘‘perhaps the most important section’’ and a similar statement from 

Senator Stevens (R. AK) when he called Section 6 ‘‘the major backbone of the Act.’’ 

The substance of the provision cannot, or should not, be dismissed by the Service 

as mere aspirational policy. 

The Conference Report for the 1973 Act lends insight into what Congress intended 

Section 6 to accomplish—‘‘[t]he successful development of an endangered species 

program will ultimately depend upon a good working arrangement between the 

Federal agencies, which have broad policy perspective and authority, and the state 

agencies, which have the physical facilities and the personnel to see that state and 

Federal endangered species policies are properly executed.’’ While the Act no doubt 

places ultimate authority in the Federal Government, that authority comes with 

strings attached, specifically, the strings of relationship building and cooperative 

interaction with the several states. 

The Service appreciates the legal obligations flowing from Section 6 and recognizes them, at least on paper. Consider the Service’s pronouncements in its ‘‘Revised 

Interagency Cooperative Policy Regarding the Role of State Agencies in Endangered 

Species Act Activities,’’ published February of this year (2016)—‘‘[s]tates possess 

broad trustee and police powers over fish, wildlife, and plants and their habitats 

within their borders. Unless pre-empted by Federal authority, states possess primary authority and responsibility for protection and management of fish, wildlife, 

and plants and their habitats.’’ In that same publication, the Service announced a 

‘‘renewed commitment by the Service and state fish and wildlife agencies to work 

together in conserving America’s imperiled wildlife.’’ 

When it comes to putting its words into action, however, the Service often fails 

to satisfy the cooperative mandate of Section 6, opting instead to shoehorn its 

square peg version of species recovery into the states’ round hole. 

THE MEXICAN WOLF, A FAILURE IN COOPERATION

As noted above, the Mexican wolf was first added to the list of endangered species 

in April of 1976, over 40 years ago. Very few species have held endangered status 

for as long as the Mexican wolf. Over those 40 years, the Service has spent over 

$25,000,000 on the recovery of the subspecies.20 Forty years and $25,000,000 later, 

one might anticipate that the subspecies is recovered, or in the least something 

more than a mere 100 wolves in the wild, yet that is all the Service has to show 

for its time and money. And while no one single factor is to blame for the lack of 

success recovering the Mexican wolf, one factor looms larger than others, the 

Service’s failure to cooperate with the states. For the sake of brevity, I have categorized the Service’s various cooperative failures into three relatively broad 

categories—(1) lack of cooperation on wolf releases; (2) lack of cooperation pertaining to and awareness of social and cultural considerations; and (3) the imposition of Federal decisions and objectives over New Mexico’s stated concerns and 

objections. 

Wolf Releases 

The Service first began releasing Mexican wolves in New Mexico in 1998. Releases 

back then at least had a colorable argument that they were guided by the 1982 

Recovery Plan. However, in the context of more recent releases, the Recovery Plan 

is all but irrelevant. Modern releases occur under the guidance of the 2015 Rule. 

However, the Rule provides no guidance on the definition of recovery. If a 

69 

population of 325 wolves is accomplished, would that trigger a delisting? No one 

knows. Can New Mexico have any confidence that once 325 wolves exist in the 

MWEPA, the Service will not announce a recovery target of 600 or 1,000 wolves 

across the entire state? No, New Mexico can have zero confidence that such a scenario will not occur because the Service has not, despite numerous requests over 

the last decade from New Mexico, defined what recovery will look like. 

While it would seem logical that the Service define its recovery objective prior to 

implementing a recovery program that contemplates the release of wolves into a 

state wary of the program, that is not how the Service has managed its program. 

Somewhat backwardly, the Service opted to release Mexican wolves in Arizona and 

New Mexico without first defining its recovery objective. Not surprisingly, this 

caused problems for the states, specifically New Mexico. Time and again the Service 

failed to reach agreement with the New Mexico Department of Game and Fish, the 

experts on New Mexico prey densities and awareness of which areas would be most 

suitable and those most impacted by wolves, regarding release locations. 

While New Mexico plugged its nose for the first decade of the release program, 

in 2011 New Mexico decided enough was enough and declined to participate further 

in the Service’s objectiveless program, meaning it would no longer lend human or 

financial resources to aid the program. New Mexico simply could not support a program without certainty about what the program sought to achieve. Certainly, the 

goal was recovery, but what did recovery look like in New Mexico. Would Mexican 

wolves be limited to the Blue Range or did recovery contemplate wolves across the 

state? Questions of great import to New Mexico and Mew Mexicans, but seemingly 

little to the Service. 

While New Mexico declined, beginning in 2011, to participate in the recovery program, the Service’s own regulation, specifically 43 CFR 24.4(i)(5)(i), still required 

that the Service comply with New Mexico’s permitting requirements prior to releasing wolves in the state. New Mexico continued to grant the Service importation and 

release permits up until 2015 when, on the heels of the controversial 2015 Rule, the 

state denied the Service’s request to import and release up to 10 wolves into New 

Mexico. The state’s denial was premised on the lack of a current species management plan, i.e. recovery plan, and on the Director’s inability to determine that the 

Service’s intended releases would not conflict with the state’s conservation management efforts. While the Service’s request was to release up to 10 wolves in the state, 

without a recovery plan informing New Mexico how many more releases were likely 

necessary and where in the state the Service intended to recover the subspecies, 

New Mexico was no longer willing to authorize releases. 

Upon review of my decision to deny the Service the requested permits, the Game 

Commission succinctly stated the state’s position on wolf releases in New Mexico: 

While the Commission sympathizes with the Service’s position—that the 

denial of release permits effectively slows certain aspects of Mexican wolf 

recovery—the recovery of Mexican wolves in New Mexico requires careful 

planning and consideration of myriad issues and the Director’s decision that 

plowing ahead with releases of additional Mexican wolves in New Mexico 

without first delineating the contours of how, when, where, and how many 

Mexican wolves will be introduced in New Mexico, i.e. the information that 

will be developed in a fully vetted recovery plan under the Endangered 

Species Act, cannot be found to be arbitrary or capricious. 

New Mexico’s denial of the Service’s requested permit did not sit well with the 

Service. In September of 2015, Director Ashe communicated to New Mexico that 

‘‘Given the denial of our permit applications, we are left with no option except to 

continue to move forward with wolf recovery efforts.’’ He continued, ‘‘the Service has 

concluded that it has independent legal authority . . . to engage in all activities regarding the reintroduction of the Mexican wolf in New Mexico. Exercising this authority will allow the Service to import, export, hold and transfer Mexican wolves 

in the state of New Mexico; and to release wolves on Federal lands in New Mexico 

without a state permit.’’ 

Troubled by the Service’s intentions, on April 20, 2016, New Mexico filed a notice 

of intent to sue the Service to prevent violations of state and Federal law. Three 

days after receiving New Mexico’s notice of intent, and just 2 months after announcing its renewed commitment to working cooperatively with the states, on April 23, 

2016, the Service, at perhaps the height of its uncooperative approach, imported two 

Mexican wolf pups into New Mexico and released them into the wild of Catron 

County, New Mexico. 

One might assume that the Service had at least notified New Mexico about how 

many wolves would be imported, where they would be released, when they would 

be released, etc. No such communication occurred. New Mexico only learned of the 

70 

21 43 C.F.R. 24.4(i)(5)(i). 22Office of Inspector General: U.S. Department of the Interior; Investigative Report of the 

U.S. Fish and Wildlife Service’s Mexican Gray Wolf Program; July 11, 2016. 

releases after they occurred and only because a colleague with the Arizona Department of Game and Fish notified us and because a local media outlet sought New 

Mexico’s comment on the matter. Upon learning of the releases I promptly called 

the Service’s Southwest Regional Director to confirm what I had heard. The 

Regional Director apologized that I was only just learning of the releases, stating 

that he had intended to notify the state earlier. 

Promptly following the unlawful releases, New Mexico filed a complaint in the 

U.S. District Court for the District of New Mexico along with a request to enjoin 

the Service from conducting further releases in violation of state and Federal law. 

On June 10, 2016, the court granted New Mexico’s request and enjoined the Service 

from releasing any wolves in the state without first complying with state permitting 

requirements. 

In its ruling, the court pointed to the language of the Service’s own regulation, 

which requires that the Service, in carrying out ‘‘programs involving reintroduction 

of fish and wildlife’’ ‘‘shall . . . consult with the states and comply with state permit 

requirements . . . except in instances where the Secretary of the Interior determines that such compliance would prevent him from carrying out his statutory 

responsibility.’’ 21 The court disagreed with the Service’s argument that it had satisfied the regulation when it applied for the permit, and held that the ‘‘clear meaning 

of compliance with state permitting requirements requires actually receiving a permit and not merely applying for one.’’ Answering the Service’s argument that it was 

exempt from complying with state permitting requirements because doing so would 

prevent it from fulfilling its statutory duty under the Endangered Species Act to 

conserve the Mexican wolf, the court held that the Service had no statutory obligation to release a nonessential experimental population. While Section 10(j) of the Act 

authorized the Service to conduct releases, such was not a statutory responsibility. 

Had the Service been more cooperative years ago when New Mexico and others 

demanded a revised recovery plan prior to the Service moving forward with releases 

and had the Service been more responsive to state concerns and ideas about when, 

where, and how many wolves to release, we would likely be at a different place 

today than where we are—a court ordered injunction preventing the Service from 

releasing wolves in New Mexico in violation of state and Federal law. 

Consideration and Understanding of Local Social and Cultural Issues 

As with any well-planned program, fundamental to its long-term success is stakeholder support. This is particularly paramount when working to recover a carnivore 

species that can negatively impact livestock operations, wildlife species management, and a host of related issues. The Service, since its first release of wolves into 

the recovery area, has failed to adequately recognize local and state interests, a 

fatal flaw for the recovery of any species, let alone a carnivore, and has consequently failed to educate relevant stakeholders and ultimately failed to achieve a 

meaningful level of stakeholder support. 

Effective communication and cooperation with local communities has been so 

greatly deficient that the Office of Inspector General for the U.S. Department of the 

Interior (OIG) released an investigate report on the Service’s Mexican wolf program 

earlier this year.22 Of the allegations of misconduct OIG investigated, failure to 

communicate effectively with the communities impacted by Mexican wolf recovery 

was one among several others. Without obtaining some level of social tolerance 

within the communities directly impacted by a recovery program, the program will 

continue to collapse, as is clearly apparent with the Mexican wolf. 

The Department has a record of conserving carnivores, oftentimes in less than 

friendly environs. When the Department set out to recover and increase populations 

of bears and cougars across the state, a program that successfully restored these 

populations from the low hundreds to now thousands, it built programs that recognized impacts to local communities and worked with those communities to find appropriate, workable solutions. We understood that there would be instances in 

which bears and cougars would kill livestock and in turn we would have to work 

with the impacted producers to alleviate losses, including, when appropriate, lethal 

control. As noted in the OIG report, the Service has truly failed in its handling of 

the nuisance wolf issue, which failure has set in stone a deep-rooted mistrust and 

rejection of the Service’s program. 

The Department understands much better than the Service does the issues impacting New Mexican communities where Mexican wolf recovery is occurring. 

Department employees live within impacted communities, raising families, building 

71 

relationships, and gaining an appreciation for the New Mexican way of life. While 

the Department and local communities may not always see eye to eye, there is an 

appreciation that actions have impacts and we have learned to mutually empathize 

with one another. There is a mutual respect and trust that has developed over a 

near century of interaction and relationship building. This mutual respect is born 

from the fact that we are a part of the communities in which we operate and know 

that we must work cooperatively and not through imposition. The Service must recognize that social tolerance and engagement with local and state-level partners in 

an honest and transparent manner is the only path to recovery of the Mexican wolf. 

The Service’s Imposition of its Version of Recovery on New Mexico 

Webster’s Dictionary defines cooperation as ‘‘a situation in which people work together to do something; the actions of someone who is being helpful by doing what 

is wanted or asked for.’’ The same source defines imposition as ‘‘a demand or request that is not reasonable or that causes trouble for someone.’’ Through years of 

exposure to the Service’s Mexican Wolf Recovery Program, it appears that the 

Service confuses cooperation with imposition. It is the normal course for the state 

to communicate a concern to the Service or to request some action, e.g. ‘‘you should 

update the Recovery Plan,’’ and for the Service to do exactly what the state had requested it not do or to entirely ignore the stated concern. Consider as an example 

the Service’s effort to revise the 1998 Rule. 

On June 13, 2013, the Service published a Proposed Revision to the Nonessential 

Experimental Population of the Mexican Wolf. During the associated EIS development and rule revision process the Department continually asked the Services for 

a population objective and was told on every occasion that this number would not 

be presented until a new recovery plan was finalized. As the steward of New 

Mexico’s wildlife resources, the state importuned the Service for the information it 

needed to appropriately assess the Service’s proposed revisions to the 1998 Rule. 

The Department could not adequately analyze all ‘‘proposed alternatives’’ and 

‘‘proposed revisions’’ during review of the preliminary EIS or proposed rule revisions 

without knowledge of a population objective. However, nowhere in the draft rule or 

preliminary EIS did the Service include a target number of wolves to be released 

into New Mexico or Arizona or an objective of wolves that would eventually inhabit 

New Mexico and Arizona. Despite the Service’s promise that the revised rule would 

not contain a population objective, the 2015 Rule did contain a numerical target of 

300–325 wolves across New Mexico and Arizona. 

Where the Service allegedly recognizes that New Mexico ‘‘possesses broad trustee 

and police powers over fish, wildlife, and plants and their habitats within their 

borders’’ as well as the ‘‘primary authority and responsibility for protection and 

management of fish, wildlife, and plants and their habitats,’’ and is committed to 

working cooperatively with the states, one might assume that the Service arrived 

at the target of 300–325 through consultation and cooperation with New Mexico. 

That would be a bad assumption. The Service did not consult with New Mexico 

about the target population. New Mexico learned that the final 10(j) Rule would include a target population of 300–325 wolves in late 2014 after years of asking the 

Service to release that target number. 

The 2015 Rule was not a product of cooperation, but rather an example of Federal 

imposition. The Service decided how it wanted to manage wolves in New Mexico, 

and deliberately ignoring New Mexico’s concerns and requests, pounded away on the 

square peg of Mexican wolf recovery. 

CONCLUSION

Late last year, the New Mexico Game Commission sat in review of my denial of 

the Service’s permit application. In a submission to the Commission the Service 

communicated a thinly veiled threat. It said: 

The Supremacy Clause of the United States requires that state laws that 

‘interfere with or are contrary to,’ Federal law be invalidated . . . To the 

extent that the state’s denials of these permits interfere with the Service’s 

ability to in any way manage Mexican wolves in the state of New Mexico, 

those denials should be overturned. The Secretary would prefer to consult 

and cooperate with the state of New Mexico regarding this issue and thus 

apply for and be issued applicable state permits. However, should the 

Commission decide to not overturn the denials of the Director, and if the 

Director makes similar decisions in the future, the Secretary could decide 

that compliance with New Mexico permits applicable to Mexican wolves will 

prevent her from carrying out her statutory responsibilities. 

72 

Echoing what the Commission said in response, it is my observation that the 

Service employs a definition of cooperation entirely distinct from the term as employed in New Mexico. To the Service, cooperation is applying for and being issued, 

without question from the state, the applicable state permits, and threatening preemption when it does not issue. What is cooperative about threatening preemption 

if a state does not issue a permit or ignoring New Mexico’s legitimate concerns 

about the Mexican Wolf Recovery Program and repeated requests for an updated recovery plan? To New Mexico, cooperation involves a dialogue where the Service sees 

a permit denial for what it is, a big red flag that cooperation has broken down and 

perhaps an opportunity to introspectively examine the status of your program. 

For years the Service has moved forward with introduction efforts in New Mexico 

without the guidance of a current, comprehensive, science-based recovery plan to 

frame and inform the effort and without dedicating sufficient financial or other resources to the program to ensure its success. New Mexico withdrew from the recovery program because it grew weary of being an accomplice to an undefined and 

objectiveless effort. For years New Mexico has implored the Service to develop a recovery plan that would both frame recovery and provide the state with real, objective information that could inform and guide the state’s positions and undertakings 

relative to New Mexico wildlife, including the Mexican wolf. 

The Service has repeatedly declared that it is not obligated to develop a revised 

recovery plan and that legally, the 1982 plan need not be revised. At the same time, 

however, the Service has acknowledge, from the outset of the 1982 Recovery Plan, 

that it was inadequate as a recovery document and that revision was necessary. In 

New Mexico we are not interested in the legal nuances of whether the Service is 

obligated to develop a recovery plan for the Mexican wolf. What we are interested 

in is recovering the species in its historic range and until a valid recovery plan is 

developed, that will be nothing more than a permanently elusive dream. 

The 93rd Congress envisioned an implementation of the Endangered Species Act 

far different from the Service’s current approach with the Mexican wolf. Section 6 

of the Act requires the Service to ‘‘cooperate to the maximum extent practicable 

with the states’’ and those Members of Congress in 1973 that spoke of Section 6 

as ‘‘perhaps the most important section’’ and ‘‘the major backbone of the Act’’ 

certainly envisioned something more significant and meaningful in terms of cooperation than the Service applying for a state permit but then barreling forward without 

it when it did not issue. 

New Mexico objects to the Service’s historical dismissiveness of New Mexican 

ideas and concerns regarding the recovery of the Mexican wolf in our state; to its 

illegal attempt to release Mexican wolves in our state without state approval; and 

to attempting to recover the Mexican wolf without first developing a fully vetted, 

science-based recovery plan to guide and frame recovery efforts. 

In short, New Mexico encourages the U.S. Fish and Wildlife Service to re-examine 

Section 6 of the Endangered Species Act and then redouble its efforts at implementation of the cooperative mandate. 

Mr. GOHMERT. Thank you, Director. At this time, Mr. Bean, you 

are recognized for 5 minutes. 

STATEMENT OF BRIAN BEAN, OWNER, LAVA LAKE LAND & 

LIVESTOCK LLC, AND LAVA LAMB, HAILEY, IDAHO 

Mr. BEAN. Chairman Gohmert, Ranking Member Dingell, and 

members of the committee, thank you for the opportunity to testify. 

Wolves kill nearly double the number of the sheep than any 

other type of livestock in the Northern Rockies. The Wood River 

Wolf Project, a collaborative consisting of producers, county commissioners, wildlife managers, wildlife advocates, public lands managers, and wildlife services, was created to determine if we could 

proactively use nonlethal tools and techniques to significantly reduce losses of sheep to wolves, while reducing lethal control of 

wolves across a large, rugged, and primarily forested landscape. 

Our goal was to evaluate the holistic strategy of increasing 

human presence, providing more diligent sheep management, utilizing a variety of nonlethal techniques in a proactive and adaptive 

73 

fashion. We used a range of nonlethal deterrents, including multiple livestock guardian dogs, temporary fencing, lighting, sound 

devices, and more, depending on the situation. 

Over the 7-year study period, 10,000 to 20,000 sheep grazed annually in the project area. On average, fewer than five sheep were 

killed by wolves per year. Sheep depredation losses to wolves were 

3.5 times higher in the adjacent non-protected area than in the 

project area. No wolves were lethally controlled within the project 

area, and sheep depredation losses to wolves were just 0.02 percent 

of the total number of sheep present, the lowest loss rate among 

sheep grazing areas in wolf range, statewide. 

The Wood River Wolf Project, therefore, provides evidence that 

proactive use of a variety of inexpensive, nonlethal techniques can 

significantly minimize livestock losses on large, open rangeland operations. If a coalition with limited resources can produce these results on the ground, I believe similar outcomes are possible in 

other western states, where wolf and livestock conflicts exist. 

Why should a producer be interested in learning about nonlethal 

techniques? The phone call to request a lethal control action is 

essentially free to the producer. The costs of lethal control are considerable, but are not borne by the producer, but by Federal taxpayers and, in at least one case, state taxpayers. Although there 

are disturbing exceptions, a lethal control request is legitimized if 

livestock have been killed. 

Has the producer then incurred an economic loss? Certainly. But 

Federal funding, typically administered by state agencies, is available to compensate the producer for those livestock losses. If fully 

compensated, the producer has not incurred a net economic loss for 

livestock killed by wolves, and has not participated at all in the 

cost of lethal control. In essence, then, from the producer’s perspective, current policy makes it low-risk, easy, and free to request 

lethal control. 

But it is not really free, is it? The ratio of the cost of lethal control of wolves to the value of livestock killed can range from 2-to3 or 4-to-1 to 35-to-1 or more. Furthermore, depredation by coyotes 

on sheep is a much greater economic issue for most range sheep 

operators than depredation by wolves. For Lava Lake, that ratio 

approaches 10 animals killed by coyotes to 1 animal, on average, 

killed by wolves. 

Consider what producers would do if they were required to pay 

for lethal control of wolves on public land. Would they continue to 

request lethal control and incur those costs, or would they try nonlethal and prevent or reduce depredation in the first instance? 

In my experience, sheep and cattle producers that operate on 

public lands believe two things that are relevant to this subcommittee. Number one, their Federal congressional delegations 

have been largely successful over many decades in protecting their 

grazing preferences on public lands, and are likely to continue to 

be effective going forward. Number two, they need not be concerned 

about economic backlash from consumers of their products if they 

request lethal control. I believe that the latter is largely true. 

In most circumstances, it would be exceedingly difficult and timeconsuming for the concerned consumer to boycott protein products 

derived from livestock raised by producers who elect to request 

74 

1https://www.fws.gov/mountain-prairie/es/species/mammals/wolf/2016/FINAL_Table7b-7c_DepState_2015%20(1).pdf. 

lethal control actions on wolves. The former, however—that is, 

Federal congressional delegations continuing to be effective in protecting grazing preferences—bears closer examination. I think that 

we are increasingly at risk of a disenfranchisement by the public 

in terms of our public grazing use; and that disenfranchisement 

would be catastrophic for producers, because nearly every operator 

that I know would not be able to continue to operate on their deeded lands alone. 

Thank you again for the opportunity to testify. 

[The prepared statement of Mr. Bean follows:] 

PREPARED STATEMENT OF BRIAN S. BEAN, PRESIDENT, LAVA LAKE LAND & 

LIVESTOCK, LLC 

I co-founded and co-own Lava Lake Land & Livestock, which raises sheep and 

cattle on 875,000 acres of public and private rangeland in south-central Idaho near 

Craters of the Moon. I co-founded and co-own Lava Lake Lamb, which sells 100% 

grass-fed and grass-finished lamb nationally. I serve as President of the Lava Lake 

Institute for Science & Conservation, an Idaho 501(c)(3) which serves as the fiscal 

agent for the Wood River Wolf Project, a collaborative whose mission is to reduce 

or eliminate wolf depredation on sheep and consequently reduce or eliminate lethal 

control requests on wolves in our Project Area. 

WOOD RIVER WOLF PROJECT

Collaborative approaches to preventing wolf depredation on livestock, like the 

Wood River Wolf Project (a sheep-centric project in south-central Idaho), reduce the 

effort and cost attendant to protecting livestock from apex predators. 

To date, there have been few landscape-scale trials of nonlethal deterrents in 

overlapping wolf and livestock range, and none that involved thousands of sheep in 

rugged national forest conditions. Because wolves kill nearly double the number of 

sheep than any other type of livestock in the northern Rockies, including in Idaho 

(USFWS 2015) 1, the goal of the Wood River Wolf Project was to determine if we 

could proactively and adaptively use nonlethal tools and techniques to significantly 

reduce losses of sheep to wolves while reducing lethal control of wolves across a 

large, rugged and primarily forested landscape. Based on data generated by the 

Project, we compared the rate of sheep lost to wolf depredation in a project area 

where nonlethal preventative measures were implemented, and a non-protected 

area, over 7 years starting in 2008. The Project Area and adjacent Non-Protected 

Area were comparable in that both were on National Forest lands in areas occupied 

by wolves and with a history of wolf depredation on sheep. 

Our goal was not to evaluate any single tool but rather to evaluate the holistic 

strategy of increasing the presence of humans, more diligent management of sheep 

and utilizing a variety of nonlethal techniques in a proactive and adaptive fashion. 

As such, we used a range of common-sense nonlethal deterrents including multiple 

livestock guardian dogs, temporary fencing, lighting, sound devices and more, depending on the situation. 

Over the 7-year study period, of the 10,000 to 20,000 sheep grazed annually in 

the Demonstration Project Area, on average fewer than 5 sheep were killed by 

wolves per year—less than 30 sheep in total. Furthermore, sheep depredation losses 

to wolves were 3.5 times higher in the Non-Protected Area than in the Project Area. 

In addition, no wolves were lethally controlled within the Project Area and sheep 

depredation losses to wolves were just 0.02 percent of the total number of sheep 

present, the lowest loss rate among sheep grazing areas in wolf range statewide. 

The Wood River Wolf Project provides evidence that proactive use of a variety of 

inexpensive nonlethal techniques used adaptively can help significantly minimize 

livestock losses on large open rangeland operations. As such, the Project has been 

endorsed by Blaine County and is ongoing today (the ninth season) under the fiscal 

agency of the Lava Lake Institute for Science & Conservation. 

If a coalition consisting of local sheep producers, county commissioners, wildlife 

conservation organizations, Federal land managers, the state wildlife management 

agency and Federal biologists working collaboratively with limited resources can 

75 

produce these results on the ground, then I believe similar outcomes are possible 

in other states where wolf and livestock conflicts exist. 

SHEEP

Clearly, based on the results of the Wood River Wolf Project as outlined above, 

nonlethal preventive measures, including tools and behaviors, can be effective in 

western states to prevent or reduce wolf depredation on sheep. 

CATTLE

Figuring out how to prevent wolf depredation on cattle on western rangelands has 

proven more difficult and has taken longer than similar efforts with sheep. 

Nevertheless, much progress has been made over the last 4 or 5 years. 

Sheep exhibit a banding instinct and are typically accompanied by herders on 

western rangelands. Cattle do not have the same banding instinct and are typically 

pastured, not herded. Over the course of 80 years or so of raising cattle in country 

that no longer supported wolves, cattle largely lost their defensive behaviors when 

confronted by that reintroduced or re-colonizing predator. In addition, polled 

(hornless) cattle breeds are preferred by most producers today, reducing the ability 

of cattle to defend themselves against wolves. 

‘‘Re-wilding’’ cattle refers to the reinforcement of defensive behaviors, including 

bunching, in the face of wolf depredation. In addition, range riding has proven effective in the Tom Miner Basin and Centennial Valley in Montana. (In the latter location, range riding also involves protecting cattle from depredation by grizzly bears.) 

As with sheep, the costs per head associated with nonlethal control may be reduced 

through collaborations involving several producers. 

Range riding is yielding an unexpected additional economic benefit: sick or injured 

cattle, including calves, are typically found and treated earlier, reducing normal 

death loss. In addition, range riders, if properly trained, are able to move cattle and 

make better use of forage resources, resulting in fewer ‘‘hot spots’’ and more even 

range utilization. 

BEHAVIORAL ECONOMICS

Generally speaking, livestock production is a low margin business. Participants in 

low margin businesses typically have limited capacity to assume incremental risk 

and are therefore more risk averse, generally, than participants in high margin 

businesses. Producers perceive changes in production protocol to be inherently risky. 

Learning how to effectively deploy nonlethal deterrents to wolf depredation is clearly a change in protocol. As a consequence, nonlethal buy-in is seen as risky and is 

resisted by many producers as a consequence. 

Why should a producer be interested in learning about nonlethal techniques, 

training his herders, or cowboys (including range riders), investing in equipment 

and deploying tools in the field? Why, indeed. The phone call to request a lethal 

control action is essentially free to the producer. The costs of lethal control are considerable but are not borne by the producer, but by Federal and, in at least one 

case, state taxpayers. Although there are disturbing exceptions, a lethal control request is legitimized if livestock have been killed. Hasn’t the producer then incurred 

an economic loss? Certainly. But Federal funding, typically administered by state 

agencies, is available to compensate the producer for those livestock losses. If fully 

compensated, the producer has not incurred a net economic loss for livestock killed 

by wolves, and has not participated at all in the cost of lethal control. 

In essence, then, from the producer’s perspective, it is low-risk, easy and free to 

request lethal control. 

EMPHASIS ON LETHAL CONTROL

After Federal (legislative) delisting (under ESA) of the northern Rockies’ (tristate) ‘‘experimental, nonessential’’ (reintroduced) gray wolf population, the emphasis on ‘‘managing wolves’’ has been a de facto emphasis on killing wolves—as 

opposed to the implementation of nonlethal control measures. For example, in 

Idaho, the Wolf Depredation Control Fund, administered by a Board consisting 

largely of members appointed by Idaho’s governor or by those appointed by the 

governor, expressly stipulates that every dollar of this $2,000,000 appropriation (involving $400,000 authorized by the state legislature every year for 5 years) must 

be used to kill wolves. In other words, the Wolf Depredation Control Fund can not 

be used to support the use of nonlethal measures. 

There are several sources of funding for the Wolf Depredation Control Fund; I 

note that some funding comes from producers’ livestock and wool sales, so that even 

76 

those operators who have found nonlethal deterrents to be effective, and prefer to 

use them, such as Lava Lake Land & Livestock, for economic or ecological reasons, 

find that they do in fact economically support killing wolves in response to depredation events whether they wish to or not. 

Notwithstanding the above, some states recently colonized by gray wolves do place 

more emphasis on the implementation of nonlethal measures to reduce or prevent 

wolf depredation on livestock. 

Oregon has been among the most progressive states in wolf conservation and 

management in the United States. ‘‘Under the Oregon Wolf Plan, in all phases of 

wolf management, nonlethal preventive measures to prevent wolf-livestock conflict 

remain the first choice of Oregon wildlife managers. These nonlethal preventive 

measures are required in all phases of wolf management before ODFW [Oregon 

Department of Fish and Wildlife] would consider lethal control of wolves due to livestock depredation.’’ See: http://www.dfw.state.or.us/wolves/faq.asp. 

The Oregon Wolf Plan ‘‘mandates focusing on nonlethal efforts before lethal removal is considered. Though the wolf population has increased significantly over the 

last 7 years, depredation events and livestock losses have stayed relatively stable.’’ 

The 2015 Oregon Wolf Annual Report states: ‘‘Overall, confirmed incidents of depredation decreased in 2015 from the previous year (9 vs. 11), and the number of losses 

also decreased . . . Confirmed losses in 2015 were 3 cattle, 10 sheep, and 1 livestock 

working dog . . .’’ (2015 Oregon Wolf Annual Report). 

The Department’s dedication, hard work and genuine transparency have demonstrated that wolves and livestock can co-exist with minimal losses when nonlethal 

methods and strategies are effectively implemented. 

LETHAL CONTROL ON PUBLIC LANDS

In my experience, sheep and cattle producers that operate on public lands believe 

two things that are relevant to this testimony: (i) that their Federal congressional 

delegations have been largely successful over many decades in protecting their grazing preferences on public lands and are likely to continue to be effective and (ii) they 

needn’t be concerned about economic backlash from consumers of their products if 

they request lethal control. 

The latter is true, in my opinion; despite USDA’s Source Verification program, 

which theoretically allows a consumer or FSIS (USDA’s Food Safety and Inspection 

Service) to retrace a T-bone steak back to the rancher who raised the steer, this is 

usually quite difficult, at least for the consumer. Ask yourself, ‘‘How would I go 

about finding out where the cut steak in the meat case in my local market or butcher shop came from? ’’ It’s one thing for Michael Pollan to trace steer No. 534 downstream, quite another to swim back upstream and finger the producer that raised 

the animal. As a consequence, it would in most circumstances be exceedingly difficult and time consuming for the concerned consumer to boycott protein products 

derived from livestock raised by producers who elect to request lethal control actions 

on wolves—unless those producers are publicly associated with a particular brand, 

which would likely be economic suicide. 

The former, however, bears closer examination. It is true that the congressional 

delegations of western states have been largely effective in protecting the interests 

of public lands grazers since the Taylor Grazing Act was passed in 1934, or earlier. 

In my opinion, it is not necessarily the case that that support will continue to be 

as effective. At the end of the day, public lands grazers operate on the public domain at the discretion of the public. This isn’t the early 19th century when most 

Americans lived on the farm, nor the early 20th century when 30 percent of 

Americans were still tied to agricultural pursuits. Today, in the early 21st century, 

fewer than 2 percent of Americans are farmers or ranchers. 

Notwithstanding the fact that tens of millions of Americans have never stepped 

foot on a farm or ranch and some believe that milk comes from a carton, the majority of Americans like wildlife and believe that predators deserve a place on the landscape. These Americans will stand up for wildlife—including wolves and other apex 

predators—and vote their beliefs. 

The shrewd producer, in my opinion, recognizes the risk of public lands grazing 

disenfranchisement by a public that in frustration concludes that the only way to 

eliminate behaviors they find objectionable is to dismantle the whole shebang— 

politically. The facts that a lethal control request is free to the producer and that 

producers in many states are compensated for livestock lost to wolves in no way 

make up for the risk of losing it all, because most public lands grazing operations 

could not survive solely on their deeded (privately owned) lands. 

77 

DEPREDATION AND LETHAL CONTROL ECONOMICS

The Profanity Peak Pack (Washington State) kill order contemplates the lethal 

control of all 11 wolves in the pack. From July 8 to September 16, 2016, 13 cattle 

were killed or injured by wolves (8 confirmed and 5 probable). Six wolves (5 adults 

and 1 pup) have so far been killed. 

A steer or heifer at a finished slaughter weight of roughly 1,350 lbs on average 

was worth $1,553 per hd at $1.15 per live-weight lb (as of August 25). The cost of 

killing a wolf varies. If a USDA APHIS Wildlife Services trapper tasked with executing the kill mandate requested by an affected producer and authorized by the 

cognizant state wildlife management agency is lucky and kills a wolf on the ground 

with a rifle, the expense is salary and benefits, fuel, overhead and the cost of a bullet, a few hundred dollars to a few thousand. If, as is often the case, a wolf is killed 

via aerial gunning, costs would include roughly $1,500 per hour for the aircraft, plus 

the cost of the pilot and sharpshooter, etc. The cost of lethal control by aerial gunning can be $11,000 per wolf. A reasonable estimate of cost is $7,000 per wolf killed, 

but can be much higher. $7,000 (paid by the taxpayer) divided by $1,553 (when 

reimbursed, also paid by the taxpayer) is 4.5×. Let’s reduce that to 4×. 

In practice, depredation events involving wolves that result in the loss of a few 

head of livestock increasingly result in kill mandates, typically executed by Wildlife 

Services, that contemplate the removal of entire packs. I refer to this phenomenon 

as ‘‘disproportionate response.’’ To illustrate, if seven sheep are killed by wolves in 

a single depredation event or multiple events involving the same operator, and those 

sheep (running-age ewes or lambs, as the case may be) are worth $200 each, for 

a total of $1,400 in economic loss, the kill order may involve all seven wolves in 

a pack and may cost taxpayers as much as $50,000 or more. The dollar ratio in this 

illustration is 35:1. 

Continuing the illustration, let’s say that the same producer has 10,000 breeding 

ewes which produce, on average, 1.4 lambs. Thus, the producer is managing about 

24,000 animals during the spring and summer grazing season. It is not unreasonable to assume a disappearance loss (lambs only) of 4.5 percent (630 lambs) during 

the grazing season, mostly from predators and most of that from coyotes. In this 

illustration, if 85 percent of the disappearance loss is due to depredation and 

70 percent of the depredation loss is inflicted by coyotes, that producer has lost 375 

lambs to coyotes before weaning. If that producer suffered as many as 20 lambs 

killed by wolves that same season, the ratio of loss due to coyote depredation to loss 

due to wolf depredation would be more than 18 to 1. The uncomfortable reality is 

that depredation by coyotes on sheep (including ewes) is a much greater economic 

issue for most range sheep operators than depredation by wolves. 

Pause to consider what producers would do if they were required to pay for lethal 

control of wolves on public land. Continue to request lethal control? Or try nonlethal 

and prevent or reduce depredation in the first place? I assume here that producers 

would still be compensated for livestock lost to wolves. 

I raise these questions because a debate is raging in the media today about killing 

wolves on public land. As is usually the case where the gray wolf is concerned, the 

debate is dogmatic, polarized and frequently vitriolic. The topics of discussion vary 

from the rationale and legitimacy of killing wolves in a congressionally-designated 

wilderness—to reduce the number of ‘‘huntable’’ wild ungulates killed by wolves— 

to the acceptability of providing expensive predator management services gratis to 

public lands grazers who are seen by many citizens to benefit already from what 

are assumed to be subsidized grazing fees on Federal lands. 

  

I am grateful to be able to provide this testimony. When I return to Idaho, I will 

doubtless have the results of the forensic analysis conducted by our Wildlife Services 

trapper on the depredation of one of our slaughter-weight steers at Lava Lake 

Ranch last weekend. Lion or wolf? For us, whatever the answer, it will be a 

reminder that we need to maintain vigilance, and that evolving the efficacy of nonlethal control measures will benefit Lava Lake and others committed to the 

proposition that predator co-existence is not only possible, but also risk mitigating. 

Mr. GOHMERT. Thank you. 

Mr. Paterson, you are recognized for 5 minutes. 

78 

STATEMENT OF TOM PATERSON, OWNER, SPUR RANCH 

CATTLE COMPANY LLC, LUNA, NEW MEXICO 

Mr. PATERSON. Chairman Gohmert, Ranking Member Dingell, 

members of the subcommittee, the Spur Ranch Cattle Company is 

located on both sides of the Arizona-New Mexico State line. It is 

about a third of the way up from Mexico to Colorado. We are on 

what is known as the Outlaw Trail. This is rough, mountainous 

country. Our elevation ranges from 4,500 feet to 9,000 feet. 

We now run about 500 head of mother cows on 125,000 acres of 

Federal grazing leases. That is about a fifth the size of 

Rhode Island. Our pastures range in size from a 1,000-acre breeding traps to our largest pastures, which are about 20,000 acres. We 

run commercial cows and registered black Angus, Simmental, and 

some Angus bulls. We endeavor to give our cattle the best care 

possible. 

I am here today to address the Mexican gray wolf program as experienced in Mexico and Arizona. I wouldn’t pretend to speak about 

the wolf experience elsewhere. 

This year, 2016, has been a wreck because of losses to our cattle 

from the wolves. So far this year we know we have lost four cows 

and five calves to the wolves. But the practical challenge that we 

face is that we will never really know how many other wolf kills 

we have had. The kills that we find are in our smallest pastures. 

You do not find them in pastures that are many thousands of acres 

large. By the time the varmints are done with a carcass, we don’t 

even find the plastic ear tag. Research results vary, and individual 

situations will differ, but an estimate from the Fish and Wildlife 

Service is that for every wolf kill you find, there are at least five 

that you don’t. 

On top of that is the loss we suffer from reduced conception rates 

on our cows. Based on research from the University of Nebraska, 

we estimate that our conception rate is about 10 percent less than 

what it should be, given the condition on our cows. That, we believe, is a result of wolves running our cows and keeping them out 

of estrus. 

In the prepared remarks that we have submitted, I have tried to 

give you detail about the wolf kills we have had during 2016. In 

paragraph 22(a) of my written testimony you will read about a kill 

we reported on June 4. It is up on the monitor. That episode shows 

that the Fish and Wildlife Service does a poor job helping ranchers 

haze wolves away from our cattle if it is on a weekend, when the 

wolves work but Fish and Wildlife Service employees do not. 

The wolf, in that case, most likely went after a young calf. The 

cow intervened. The wolf bit the cow under her armpit and immobilized her. She went down, paralyzed. The wolf ate on her from 

the rear end forward, while she bled to death. That wolf killed a 

cow and orphaned her calf. The baby calf is too young to survive. 

We lost both the cow and the calf. We get paid for the cow. Last 

Friday, I was told we do not get paid for the calf, because the wolf 

only orphaned the calf, it did not kill it. 

In paragraph 22(b) of my testimony, you will read about two 

other kills we get no compensation for. That experience demonstrates a willingness on the part of the FWS investigators to fiddle with the truth. It also shows the incredible burden on ranchers 

79 

to prove that we have a wolf kill. That is what you call a conflict 

with livestock. That is actually a wolf kill. 

And, there is more. As we report in paragraph 22(c) of our materials, a week after we had a number of wolf kills on our south 

ranch, we had another kill on our north ranch. A wolf from the 

Buckaloo Pack killed a cow/calf pair in that pasture. 

Could we go to the last slide? They confirmed the calf was a wolf 

kill, but the cow which the wolves chased into a bog hole where it 

died was only a probable kill. That is the cow. That is the bog hole. 

She had two creeks running right beside her, and she headed for 

the bog hole. That is where she died. 

Let’s go to the next picture. Upper left, that is the calf. That is 

what a calf looks like. That is a wolf conflict with livestock. That 

is what a calf looks like after a wolf’s got it. 

I ask that you would review the specific examples we have 

shared with you, the cost to us this year, over $116,000 uncompensated cost to the Spur Ranch Cattle Company, before you include 

what it is costing us for decreased weights on our calves. 

Mr. GOHMERT. Thank you. 

[The prepared statement of Mr. Paterson follows:] 

PREPARED STATEMENT OF THOMAS W. PATERSON, SPUR RANCH CATTLE CO. LLC 

WHO WE ARE, WHERE AND WHAT WE DO

I represent the Spur Ranch Cattle Co. LLC. The owners are my wife, Callie, our 

daughters, Lindsay and Caroline, and myself. Majority rules, and I don’t control a 

majority. Callie has a BBA in accounting and an MBA in Tax from the University 

of Texas. She’s a CPA. Lindsay was graduated from Yale in 2014. She’s an associate 

with Riverstone Holdings in New York City doing energy private equity. Caroline 

was graduated from Sewanee: the University of the South last May. She’s an economist with Alvarez & Marsal in Houston. I’m from Clifton, Arizona. I was graduated 

from high school in Silver City, New Mexico, did my undergraduate in Agricultural 

Economics at Texas A&M, got my masters and Ph.D. in Ag Economics and a law 

degree from the University of Wisconsin. I’ve practiced law for going on 32 years. 

I’m a partner with Susman Godfrey in Houston. I’m licensed in Texas and New 

Mexico. I practice oil and gas. I’m at the ranch about a week each month. When 

I’m not, I spend about 25 hours a week on ranch business. Our ranch crew includes 

our south ranch foreman, Clint Fischler. He lives with his family on the South 

Ranch 6 miles west of Alma. Clint has years of experience working cattle. We’ve got 

a couple fellows helping Clint. The foreman position for the north ranch near Luna 

is currently open. 

We are located on both sides of Arizona/New Mexico line, about a third of the way 

up from Mexico to Colorado. This is rough, mountainous country. Our elevation 

ranges from 4,500 feet to 9,000 feet. It’s easy for cattle to hide. Geronimo was born 

not far away. According to Captain French in his book Recollections of a Western 

Ranchman, it’s where the Apache went when they jumped the reservation at San 

Carlos in the 1800s. It’s also on what’s known as the Outlaw Trail. Think Butch 

Cassidy and the Sundance Kid. They once worked on the WS Ranch in this area 

before the Pinkerton agents swooped in. 

We now run about 500 head of mother cows on 125,000 acres of Federal grazing 

leases. To put that in perspective, that’s about a fifth the size of Rhode Island. We 

have a north ranch for summer grazing and a south ranch for year-long and winter 

grazing. Much of our south ranch is formally designated primitive. It is part of the 

Blue Range Primitive Area. It is administered as if it is Wilderness. We also use 

about a section or 640 acres of private land. The pastures range in size from our 

smallest, which are a couple section breeding traps to our largest, which is over 30 

sections or about 20,000 acres. The pastures on the south ranch in primitive area 

are accessible only by horseback or on foot. 

We run our cattle near the communities of Luna and Alma, New Mexico and 

Alpine and Blue, Arizona. When you stand on top of Maple Peak in the southwest 

corner of our south ranch, you can see the tailings dam at Morenci, Arizona, about 

30 miles away. 

80 

We are active and aggressive conservationists. The Spur Ranch Safe Harbor 

Agreement was among the first in our region between USFWS and a private landowner. Through the Spur Ranch Project, we have done close to $1 million in erosion 

control projects on a tributary to the San Francisco River as well as forest thinning 

and burning. 

We obtained our Forest Service grazing permits in 2008, 2009 and 2012. Each 

allotment was in very poor condition. Fences were down, stock tanks were filled 

with forest trash and silt, water distribution pipelines were in disrepair, wells were 

nonfunctional and there were no facilities for working cattle safely or for our employees. Feral cattle ran on the south ranch. 

Things are different today. We haven’t finished our building work by any stretch 

but we are well on our way. We have put in tens of thousands of stays to fix existing 

fence. We’ve built many miles of new fence to replace what didn’t exist or couldn’t 

be fixed. We’ve cleaned stock tanks. We’ve replaced those pipelines. We’ve expanded 

their coverage extensively. We’ve fixed the wells and drinkers. Professor Temple 

Grandin and her colleagues designed our working facilities, which are safe for cattle 

and the people working them. Our employees and their families have modern housing. There is an occasional feral animal that shows up. By and large, they are gone. 

We don’t raise cattle the way grandpa did 100 years ago. We are committed to 

best practices for our cattle. We routinely get and rely on input from our extension 

veterinarian, Dr John Wenzel, and from our extension beef cattle specialist, Dr. 

Marcy Ward. Both are excellent resources. We have commercial cows and registered 

Angus, Simmental and Sim-Angus bulls that we buy from throughout the West. 

During breeding seasons, we figure we need 1 bull for every 10 to 15 cows. I’m 

dickering on some now. Last year the price was $6,000 a head. Trich is a sexuallytransmitted disease. It causes abortions. It has been a terrible, wide-spread problem 

in our area. We test our bulls for it annually. To date, we have been negative—a 

testimony to the diligence our staff shows in keeping out neighbor cattle. 

We endeavor to give our cattle the best care possible. We are in country that is 

deficient in some minerals. Our cattle have salt and loose minerals year round. 

When the grass is dry, we cake and put out tubs to supplement the protein the cattle get from the dry grass. We routinely check in with our extension veterinarian 

for any changes in our vaccination protocols. We vaccinate the cows each spring for 

black leg and bovine respiratory disease, among other things. We preg test fall 

calving cows in the spring. We preg test spring calving cows in the fall. Last year 

we tested the herd for bvd, bovine viral diarrhea, which causes abortions. The results were negative. When we bought replacement heifers last year, they cost $2,500 

each. Each cow has an ear tag and an electronic identification button. We use Cattle 

Sense for our electronic record keeping. 

We are getting just under an 80 percent calf crop. That’s not good enough. Given 

the body condition scores on our cattle when they are bred, research from the 

University of Nebraska indicates that we should be at 90 percent. Calves are born 

in the spring or in the late summer and early fall. Calves are vaccinated at branding, which happens twice a year. Each gets an ear tag with its mother’s ear tag 

number on it. It is rare for any animal to get an antibiotic, which means we’re all 

natural. We sell calves in the spring and fall. Spring calves average about 500 

pounds. Fall calves are about 40 pounds lighter. Before they are sold, we precondition the calves for 45 days. That means they are weaned, have their vaccinations current and are trained to eat at a bunk and water at a drinker. For the past 

couple years, we’ve sold our calves to a feedlot near Dodge City, Kansas. A year ago, 

we sold our calves for over $300 a hundred weight. This past spring, they sold for 

two-thirds of that. The current market shows we’ll get significantly less this fall. 

We are waiting for our grazing fees to follow suit. 

EXPERIENCE WITH WOLVES

Since we began running stockers in 2009, we’ve never had a year when each 

animal is accounted for. From 2009 through 2011, we weren’t able to account for 

about half a dozen head each fall when we gathered. We don’t know what happened 

to those cattle. Did wolves, bear or lion kill them? Did they die of natural causes? 

Did a hunter shoot them? Did someone rustle them? 

We switched from a stocker operation to a cow/calf operation in 2012. When we 

did, we made some significant changes from how our neighbors operate in order to 

accommodate the wolves. Most of our neighbors have calves born year round. 

There’s a problem. Having baby calves in the area where the wolves are denning 

in the spring means we’re more likely to have calf kills. The wolves go after those 

calves. The cows intervene. The wolf tends to kill the cow and orphan the calf. For 

this reason, we have elected to manage our herd to have a late summer/early fall 

81 

calving season. In the fall, the concern with wolves is still present but somewhat 

less because the pups are larger and elk hunters leave gut piles starting around 

September 1. What happens though if the fall calving cow isn’t bred when we preg 

test in the spring? Do we wait to breed her the following fall and lose a full year 

or go ahead and breed her for a spring calf? We typically opt to breed them, which 

means we will have cows calving in the spring. Research recommendations on 

calving only in late summer/early fall sometimes don’t seem to get that point. 

We’ve suspected wolf kills since we switched to running cows in 2012. Each year, 

a certain number of cows didn’t come back in at gathering time. We’d find some on 

the next cycle. Some we never have. Were they killed, did they die of natural causes, 

did hunters kill them, did someone steal them or are they still out there? We don’t 

know and that’s not for a lack of trying. 

Some of our suspicions about the wolves’ role in our losses were confirmed during 

2015, when we had our first confirmed wolf kill. This year, 2016, has been a wreck 

because of our confirmed losses. We have found where wolves have attacked our 

spring calving cows in a two section breeding trap and in a small pasture on our 

north ranch. This year we know that we’ve lost seven cows to various causes, all 

but one of which we found because they were in very small pastures. The seventh 

cow was killed in a large pasture but near a stock tank we regularly monitor. The 

wolf investigators confirmed that one cow was a wolf kill and one was a probable 

kill. Of the other five, we think one died of natural causes, two were also wolf kills 

the investigators couldn’t or wouldn’t confirm, one was a bear kill and one was too 

far gone to know what killed it. We know of two calf kills; the investigators confirmed these as wolf kills. 

The practical challenge we have is that we will never really know how many other 

wolf kills we’ve had. The kills we find are in our smallest pastures. You don’t find 

them in pastures that are many thousands of acres large. By the time all the 

varmints are done with a carcass, we don’t even find the plastic ear tag. The research results vary and individual situations differ but an estimate from USFWS— 

that we think is conservative—is that, for every wolf kill you find, there are at least 

five that you don’t. 

IMPACT FROM THE WOLVES

Death loss on cattle is not the only impact wolves have on us. We get lower body 

condition scores on our cows. That translates into reduced conceptions. We have 

lower weaning weights on our calves than we should. We spend many precious daylight hours moving our cattle to other pastures to avoid wolf concentrations. We also 

spend those precious hours monitoring for predators and looking for dead cattle. We 

spend time administratively dealing with the USFWS in New Mexico or the Arizona 

Game & Fish on reporting and compensation requests. Every kill consumes time on 

the ground—a couple hours to a half day—to meet with investigators and a couple 

hours administratively to request reports, submit reports and do followup. 

There are other, perhaps less obvious impacts from the wolf. One is employee retention and safety. Some cowboys will endure threats from bears, lions, coyotes, rattlesnakes and scorpions. The wolf is different. It doesn’t run away. We’ve had guys 

quit because they don’t want to deal with the wolf. 

The wolf has an impact on our communities, My 85-year-old friend Howard in 

Luna lives on the edge of the woods with his three dogs. He has seen a pack of nine 

wolves from the Escudilla Pack cross behind his house. His dogs would be an appetizer for that pack. They go inside. We don’t want to be stalked. Does using the 

forest now mean that people have to carry a pistol for protection? That goes for 

hikers, campers, off-road enthusiasts and hunters. To the extent those people stop 

coming to our communities, we lose tax receipts and our businesses become even 

more marginal. I’ve asked about wolf tourism. The response I’ve received is that the 

notion is a farce. 

PROBLEMS AND FRUSTRATIONS

The apparent objective of the radical environmental community is to remove man 

from landscape. The wolf is one mechanism they are using to do that. That is not 

multiple use management of our public lands. 

These wolves are not the majestic animals on pet food commercials. Please look 

at the photos on my exhibits. Wolves are ruthless killers who are preying on our 

livestock. 

They are costing us time and money. 

Don’t fool yourselves. There isn’t a real compensation program in place. The current rules require Wildlife Services to confirm the wolf has killed an animal to be 

eligible for compensation. Dig deeper. These kills occur on pastures that are 

82 

thousands of acres large. The rancher is charged with finding the kill. He has to 

do so before the carcass deteriorates or is otherwise fully consumed by the wolf and 

other varmints. Indeed, if it is so hot that a carcass will deteriorate quickly, he’s 

got to be on top of finding that needle in the hay stack almost immediately. If 

Wildlife Services does confirm the wolf kill, we have to wait for a depredation report. The one from a kill the summer of 2015 didn’t show up until March 2016. Once 

we have the depredation report, we have to request reimbursement. We wait. Often 

for months. Here are real examples: 

In May of this year, we branded calves that had been born this spring. We 

paired them up with their mothers and gave each an ear tag that had the same 

number as on its mother’s tag. We then branded and vaccinated the calf. We 

vaccinated the mother. We then took them to our Cradle Mesa Breeding Trap, 

a fenced in pasture of about 1,280 acres and put them with the bulls to breed 

them so they’ll have a calf next spring. In early June, I got a call from the 

USFS on a Friday afternoon that a lone, male wolf number 1388 was in our 

area. I asked the USFS to have someone from USFWS come out and haze that 

wolf away from our cattle. He called back, told me he had tried but, because 

it was the weekend, no one was available to help. Wolves work on weekends 

even if government employees don’t. That weekend we had a wolf kill on a cow 

in that pasture. Wildlife Services confirmed it. I’ve attached a copy of that June 

4 depredation report as an exhibit. The wolf had immobilized the cow under her 

front legs. She went down and couldn’t get up. The wolf began eating her from 

the rear end forward. She was still alive for part of that until she bled to death. 

We got a depredation report. We submitted it for payment. We got payment on 

that cow in early September, which was record speed. But what about that calf? 

It was too young to survive on grass on its own and we’re not equipped with 

the help to bottle feed it. Do we let it die? No. Do we slit its throat? No. What’s 

humane? We donated it to the FFA kids to raise. Is that calf an economic loss 

to us? Absolutely. Who is responsible for it? The wolf. Will we get compensated 

for it? No. I found out on Friday that we won’t because the wolf only orphaned 

it; the wolf didn’t kill it. That’s what we call a stupid rule. 

There’s more. Early that next week, on June 8, we found two more cows dead 

in that pasture. We called Wildlife Services. They came the next day with personnel from USFWS. They reported that these two cows had been dead for 5 

to 6 months and they couldn’t say what killed them. No confirmation, no compensation. We were furious. Those cows hadn’t been dead for 5 to 6 months. If 

they had been, then they had a miraculous resurrection experience. That is, 

they rose from the dead, finished out their pregnancies, calved, allowed us to 

gather them, take them to our processing facilities, and brand and vaccinate 

them. What’s more, we paired them up with each’s calf, put the mother’s tag 

number on the calf’s ear tag and then hauled them out to that breeding trap. 

That’s where they were when, apparently, those cows died from some unknown 

cause and miraculously looked like they’d been dead for 5 to 6 months. When 

we pointed this out, the response we got was dismissive: ‘‘Regardless of how 

long the cows had been dead, Wildlife Services couldn’t detect the cause of 

death.’’ No compensation. Not for the two cows. Not for the two calves. I’m disappointed to report that, contrary to what they told us on the ground, by the 

time we got the depredation reports after we’d confronted them on their proposed dates of death, they changed their estimate to say one cow had been dead 

for 2 weeks and the other dead for 3 weeks—not for 5 to 6 months. I’ve attached 

a copy of that report. What about lone male wolf 1388 that was in that area 

at that time? This is one of those genetically diverse wolves that USFWS 

treasures. They wouldn’t pin the kills on him. The USFWS did agree to pick 

him up and move him to Grant County. That wasn’t a perfect solution when 

a wolf can travel many miles a day but it was better than having him on top 

of us while we were now gathering the cattle out of that pasture a month early 

and moving them to our north ranch. The problem: USFWS called me back a 

couple days later to tell me that a Federal district court judge had ruled that 

USFWS could not release any more wolves in New Mexico until further order 

of the court. If USFWS couldn’t release Wolf 1388 in Grant County, they 

weren’t going to pick him up. I called them out on that. The Court’s order didn’t 

tell them they couldn’t pick that wolf up. They could do that and put him in 

a zoo or they could adopt him out to live with people who advocate for wolves. 

Nothing doing. Wolf 1388 is a desirable wolf. It is genetically diverse. It mysteriously disappeared into Arizona. As far as we know, it is still killing stock. 

The only good thing that came of this: The USFWS stopped having a young guy 

call me up periodically to extol the virtues of the wolf program. Now, the senior 

83 

administrator, John Oakleaf, does the calls and he, fortunately, knows how to 

give me a straight answer. 

There’s still more. A week later, a different wolf from the Buckaloo Pack killed 

a cow/calf pair in that pasture on our north ranch. Wildlife Services confirmed 

the calf and went out on a limb to say the cow was a probable kill, which cuts 

any compensation in half. Please look at the photos of that kill we called in on 

June 20. That’s what a calf looks like after a wolf gets it. 

And, most recently, we know that a wolf killed one of our baby calves near 

Alpine, Arizona. How’d we find it? Someone was out hiking. They saw the dead 

calf. They took a photo and posted it to Facebook. The USFWS saw it and called 

us. Clint went to find it on August 22. He did. At least, all that was left—one 

back leg. He took the leg in to the wolf people in Alpine. They confirmed it was 

a wolf kill. We got that depredation report on September 14. I must say that 

speed on my depredation reports has improved over the past several months. 

And yes, there’s more. During the summer of 2015, we had a confirmed wolf 

kill near Alpine. The wolves killed the cow as she was calving. We lost the cow 

and the calf. We didn’t get the depredation report until March 2016. We got 

payment in mid-August 2016, about a year later. That delay cost me another 

calf. You see, by last fall we’d have had that cow in a breeding pasture with 

bulls. There’s an 80+ percent chance she’d have conceived. That cow would have 

calved late this summer and we’d have a calf to sell next spring. The delay on 

administering the program ended up costing me two calves, not one. 

Last, there’s a wolf presence program in Arizona and in New Mexico. This is 

compensation for wolves generally. It doesn’t depend on confirmed kills. It 

should reflect the cost to a rancher of lower pregnancy rates and lower weight 

gain on our calves. Both are a reality. When wolves are running down cows, 

they’re less likely to go into estrus or stand to be bred. When wolves are running stock, they are running body condition off the cows and they are running 

weight off the calves. I applied for payment in 2014. When I didn’t get paid, 

I asked and was told the Wolf Council didn’t get my applications. OK. My mistake, I didn’t send them registered mail. I applied for payment before the June 

deadline this year. I got a call in late August that they didn’t have my application. I went through my files, found the application and emailed them in. 

What’s the problem here? Aside from no payment for 2014, there’s an attitude 

that the rancher has unlimited time to respond to bureaucrats who can’t get 

their paperwork straight. I called on Friday, September 16 to find out if we are 

getting paid this year. The answer is yes. The amount, I was told, is at the high 

end. It is $7,048. That doesn’t come close to compensating us for a very conservative 10 percent decrease in weaned calves, which is how we compare to what 

we think our weaning rates should at least be. The loss of 50 calves at USFWS 

rates is about $53,000. The $7,048 is 13 percent of what we think our losses 

are. The net loss to us is $45,952. 

Let me put the wolf compensation program in perspective for you. There isn’t 

one. For just this past summer, we know that wolves have killed four cows, 

three on our south ranch and one on the north ranch. They’ve killed two calves. 

They’ve orphaned three other calves, all of whom are being raised by the FFA 

kids. At $2,500 a pop for a cow and $1,060 for a calf, that’s a $15,300 loss to 

us. Of that, we qualify for payment on one and a half cows and two calves or 

$5,870. The net loss to us is $9,430. That’s what we know about. Based on published research, we believe that for every confirmed wolf kill, there are at least 

five kills we never find. I’ll know more about our actual experience by the end 

of October when we finish gathering. If it were true, however, this year alone 

we’ve lost 20 cows and 25 calves. The cost to us would be $76,500, of which we 

will get $5,870 back. That’s a net loss of $70,630 before we include the decrease 

in conception rates. When we add that net loss of $45,952 in, we get a net loss 

of about $116,582. Who, we ask, is bearing the brunt of the cost of the wolf program on the ground? The rancher is. This is a business. Our profit is on the 

revenue we receive from the last calves we sell. How do you expect us to stay 

in business with those losses? We can’t stay in business to feed wolves. Our cattle are not wolf food. The rules don’t reflect reality. They don’t reflect the size 

of our pastures. The burden of proof is completely and undeniably on the rancher. That’s not a fair compensation program. If the American people want wolves 

on the ground, they should pay for the privilege. They aren’t. 

It is certainly legitimate to turn the tables and ask, as between the rancher and 

the wolf, what benefit does the American public receive from having ranchers on 

84 

public lands? Here are some data points: We are the ones consistently on the ground 

in much of this country. We have a vested interest in wise management of the resource. If the land or water fails, we don’t survive. We spot forest fires and report 

them. We remind hunters that they can’t camp next to where our cattle and wildlife 

go to water. Our presence is a deterrent to illegal wood cutters. Wildlife poachers 

don’t want to be observed, so we are a threat. We are also a deterrent to the crazies 

who don’t want to be seen in the woods. These include the people who mutilate animals—cats, dogs, and cattle. When the game and fish has a question or a concern, 

they call us. We are the ones who keep up the fences that have been there for decades so there can be rotational grazing. Without those fences, feral cattle become 

a problem, especially in riparian areas. The XXX Allotment in Arizona is a persistent example of feral cattle hammering riparian areas on an allotment that is in 

non-use. We enhance and maintain the water resources that wildlife use right 

alongside our cattle. Our cattle are not the only ones that use the salt, minerals 

and protein we put out. Elk, for example, are routinely at our salting grounds. Our 

ranch families have children who go to our local schools. We and our employees support local businesses. We produce a grass-fed, all natural product that enters the 

food system. Consumers around the world want that protein. Their demand will 

only continue to grow in the decades to come. Those are benefits from ranching on 

public lands. People whose intention is to use the wolf program to remove us from 

the landscape should consider carefully what the resource costs will be if they are 

successful. If the American people are truly committed to multiple use management, 

please stop trying to use the wolf to drive ranchers away. Give us a fair compensation system for the economic cost to us of the wolf. 

RECOMMENDATIONS

1. Remove the wolves. In life we have to do cost/benefit analyses. What have we 

genuinely gained from the wolf program? What has it cost? The last estimate 

for the Mexican Gray Wolf Program is approaching $37 million. That cost is 

increasing at about $3 million per year. For the 97 wolves now estimated to 

be on the ground, that’s about $30,000 per wolf per year. The cost far exceeds 

any benefit from them in this settled region. The program has failed. We 

should stop spending money on a failed program. 

2. If you’re not going to remove the wolves, do more than pay lip service about 

the rancher. We don’t need a pat on the head. 

— Get serious about compensating ranchers fairly for the cost the wolves 

impose. That’s all the costs—direct and indirect. 

— At the very least, give ranchers in wolf country a discount on their grazing 

fees. It costs us more to operate with the wolf than those who don’t have 

varmints. We currently pay the same as everyone else. 

— You should authorize the USFS to stream line NEPA so we can manage 

around the wolves. Don’t make us wait years on NEPA to do the improvements we need to manage cattle around the wolves. That means fences and 

water projects get reviewed and authorized on an expedited basis. 

— Allocate the money to the USFS to use to put allotments in non-use back 

in functional status and hold them open for ranchers to use when wolves 

are attacking his or her cattle. 

— When a wolf has two confirmed kills on cattle, it has likely killed a lot 

more. Track the wolf down and kill it or remove it permanently from the 

wild. 

— Encourage communication with ranchers so we know where the wolves are. 

— Compensate ranchers for costs of moving cattle to unscheduled locations to 

avoid wolf conflicts. That’s wages to gather the cattle at $125 a day per 

cowboy, hay most recently at about $200 per ton to feed the cattle in the 

holding pen during gathering and trucking at $4 a loaded mile. 

— Tie compensation to wolf numbers in and around allotments rather than 

just to specific kills. Compare data from pre-wolf release predation losses 

to current losses and compensate accordingly. Paying a couple thousand 

dollars for a 10–20 percent decrease in conception rates doesn’t come close 

for us. 

85 

3. Wolves do not fear man. Why should they? We are threatened with jail if we 

shoot them. Change that. Teach them to fear man and his environment to 

keep the wolf away from us and our livestock. 

— Have a special permit hunting season on them. 

— Allow private landowners to kill wolves whenever they are on private 

property and regardless of whether they are attacking livestock, pets or the 

owner. 

— Allow anyone to shoot wolves with rubber bullets on Federal lands. 

4. Things you can do to help wolves be successful but minimize their impact on man. 

— Train wolves to eat elk by wounding elk in seasonal pastures not then in 

use by livestock so they can then kill and eat the animal. 

— Provide early and timely suspected den locations so livestock can be moved 

away prior to whelping. Don’t wait to tell us until after we move in. 

— Allow permittees and our agents to use rubber bullets or paint guns to 

dissuade wolves from hanging around livestock during calving seasons. 

** *** 

The documents that were submitted as supplements to Mr. Paterson’s testimony are 

part of the hearing record and are being retained in the Committee’s official files. 

Mr. GOHMERT. I will recognize myself for 5 minutes for 

questioning. We appreciate everybody’s testimony. I want to go to 

Mr. Guertin. 

How many red wolves did the Fish and Wildlife Service 

originally plan to introduce into North Carolina? 

Mr. GUERTIN. Twelve, Mr. Chairman. 

Mr. GOHMERT. How many did they end up actually introducing? 

Mr. GUERTIN. Well over 100, Mr. Chairman. 

Mr. GOHMERT. Last week Fish and Wildlife announced that your 

captive breeding population was unsustainable at its current level. 

Is that your understanding? 

Mr. GUERTIN. Yes, Mr. Chairman. 

Mr. GOHMERT. So, by reintroducing between 132, as I understood, and 165 wolves from your captive breeding program into the 

wild, instead of 12, you have effectively decimated your own captive 

breeding program. Correct? 

Mr. GUERTIN. Well, Mr. Chairman, it is a little more complicated 

than that. Many of the wolves that have been reintroduced into the 

wild have not survived. They have been hit by cars or trucks, they 

have been shot— 

Mr. GOHMERT. Can you check your microphone, please. 

Mr. GUERTIN. Mr. Chairman, just for clarification, many of the 

wolves that were reintroduced to the wild did not survive. They 

were either shot, they were killed by trucks, they died of natural 

causes. 

So, over time, what we found out through rigorous analysis of the 

available science is that the seed stock we have maintained in 

these captive breeding programs was not adequate to ensure 

genetic integrity, going forward. What was announced was this 

vision of bringing a refocus to the red wolf recovery program by focusing on rebuilding a larger, more robust captive breeding program, and, at the same time, pulling wolves back on to Federal 

lands in North Carolina. 

86 

Mr. GOHMERT. Well, is it true that you plan on doubling the size 

of your captive breeding program? 

Mr. GUERTIN. We are envisioning increasing the number of 

wolves in the captive breeding program up to about 400. Yes, sir. 

Mr. GOHMERT. And, by the way, when I was asking about the 

captive breeding program being decimated, I guess that anticipated 

that the wolves were being killed. That is how it would—— 

Mr. GUERTIN. Yes, sir, I understand. 

Mr. GOHMERT [continuing]. Decimate a program. Tell us what 

Fish and Wildlife plans to do with the red wolves once the captive 

breeding population is increased to over 400 wolves. 

Mr. GUERTIN. Sir, over the next several years, as we work with 

the partner organizations throughout the country on the captive 

breeding program, we are also re-looking at the larger status of the 

species. We are looking at, over time, the potential to work with 

partners on additional release sites for wolves. None have been determined, no conversations have taken place yet. And we are going 

to manage the few remaining wolves in the wild as part of this 

larger metapopulation, coupling those wolves in the wild with those 

held in the captive breeding program. 

Mr. GOHMERT. Well, I hope that you will take a moment at some 

point and think about how it sounds to some of us if you introduce 

far more wolves than you anticipated introducing, and the program 

ended up being a terrible failure, so you are going to double that 

number. It would seem to some of us that perhaps you would be 

better off maybe halfing or quartering that number, so that the 

wolves have more area in which to survive on. 

Yes, sure, maybe trucks hit them, there are always going to be 

natural causes. But, for heaven’s sake, doubling the number? It 

seems like you are going to ensure a double devastated program. 

Have you considered that possibility? 

Mr. GUERTIN. Yes, sir. I understand your perception of what we 

are doing. What we are doing is looking at the underlying science. 

The underlying science has issued us a warning that the wolves 

held in the captive program are not enough to ensure we have the 

strength, at a biodiversity level and a genetic level, to fully achieve 

our recovery goals for—— 

Mr. GOHMERT. Well, isn’t it possible, Mr. Guertin, that you have 

dramatically under-estimated the habitat size needed in order to 

sustain one red wolf? 

Mr. GUERTIN. Yes, sir. We recognize that the original release 

area centered on the Dare Bombing Range and Alligator River was 

not large enough to sustain the larger wolf population that we envisioned, and that is one of the underpinnings for our decision to 

re-look at the entirety of the program. 

Mr. GOHMERT. And double it. 

Mr. GUERTIN. Double the number of animals in captivity. 

Mr. GOHMERT. After you have learned that the habitat is much 

larger than you anticipated. 

I see my time is expired, and I will now yield to the Ranking 

Member, Mrs. Dingell, for 5 minutes. 

Mrs. DINGELL. Thank you, Mr. Chairman. 

Mr. Bean, in his testimony, Mr. Moore claims that since 

Congress delisted gray wolves in Idaho, state management has 

87 

been far superior to management under the Endangered Species 

Act. However, the Idaho legislature has codified a shoot-first-askquestions-later approach through its wolf depredation control fund, 

spending $2 million to kill wolves with no consideration of nonlethal control measures. This has led to trapping and aerial 

gunning of wolves on U.S. public lands, including in federallydesignated wilderness areas. 

Do you believe this constitutes sound wolf management? 

Mr. BEAN. I believe that the state of Idaho, Representative 

Dingell, uses a variety of techniques in approaches to manage. And 

yes, it is true that every cent of that $2 million that you referred 

to, which is the Idaho Wolf Depredation Control Fund, must be 

used for killing wolves, and that none of it can, by statute, be used 

for nonlethal. 

It is also true that in the state of Idaho many more wolves are 

killed by the IDFG managed hunting season by hunters with 

licenses and wolf tags. But many wolves are still killed in Idaho 

as a consequence of depredation. I believe that that number, in 

fact, could be substantially less if there was a greater emphasis in 

our state in underscoring the benefits, and certainly supporting 

nonlethal. If we had more nonlethal commitment, I believe that 

fewer wolves would need to be managed lethally by virtue of livestock depredations that would be fewer and less extreme. 

Mrs. DINGELL. So, what impact do wolf killing subsidies like 

this—and I am going to need you to go a little faster, because I 

have a short period of time—and the lethal control actions of 

USDA’s wildlife services have on taxpayers and on the development 

and adoption of clearly superior wolf-livestock conflict avoidance 

techniques like those you employ? 

Mr. BEAN. Well, if you are asking what it costs to kill a wolf, that 

can be a matter of a few hundred to a few thousand dollars, or it 

can be, in one case, $30,000 for a single wolf. But not in Idaho. 

Seven to eleven thousand is a reasonable estimate. That is entirely 

borne by the taxpayer, typically, and usually the Federal taxpayer, 

and in some cases state. 

Mrs. DINGELL. Quick, quick, could you contrast what your 

management is to Oregon’s, please. 

Mr. BEAN. Yes, Oregon’s management places nonlethal in a priority position. The Oregon Department of Fish and Wildlife has on 

their Website the statement that lethal control will not be considered unless nonlethal is implemented first. So lethal control is on 

the table, but an operator that is affected by wolf depredation, to 

be able to get lethal control must have tried nonlethal. It is the 

preferred preventative management tool in Oregon, and it is said 

explicitly that that is the case. 

Mrs. DINGELL. OK, thank you. 

Dr. Vucetich, I am sorry we are running out of time, but a study 

released last month has been widely reported to show that red 

wolves are not a distinct species, but instead are some type of 

coyote hybrid. While hybridization with coyotes is certainly a 

threat to red wolf recovery, you state in your testimony that there 

was widespread agreement among experts that the red wolf is a 

listable entity under the Endangered Species Act under any plausible scenario describing its evolutionary history. Will you please 

88 

clarify for the committee why the red wolf is not a coyote hybrid, 

even though the two animals share common ancestry? 

Dr. VUCETICH. The best way to understand the answer to that 

question is to introduce a piece of jargon that is known as 

‘‘admixture.’’ Admixture refers to an organism that has parts of its 

genome from two different species. A really interesting example of 

this would be that most Europeans—human beings, now—have a 

portion of their genome that came from Neanderthals. This does 

not mean that Europeans are hybrids between Neanderthals and 

humans. 

A similar thing, an analogous thing, is likely to be the case for 

Mexican wolves. It is possible to have genes from more than one 

source and not be a hybrid. 

Mrs. DINGELL. Were the FWS’s efforts to reduce hybridization 

risks to red wolves in North Carolina effective before being 

discontinued? 

Dr. VUCETICH. They were impressively effective. The best estimates are that less than 4 percent of the wolves in the population 

in the wild are hybrids, and that is more than manageable to 

preserve the genome of red wolves. 

Mrs. DINGELL. Thank you. 

Mr. GOHMERT. At this time the gentleman from Idaho, Mr. 

Labrador, is recognized for 5 minutes. 

Mr. LABRADOR. Thank you, Mr. Chairman. First, I want to thank 

both of our Idaho witnesses for coming out here today to testify. 

Quick question for you, Mr. Bean. I know you are an advocate 

for nonlethal control, but you are not opposed to lethal control of 

wolves, correct? Just yes or no. 

Mr. BEAN. The answer is I am not opposed to lethal control. 

Mr. LABRADOR. OK. 

Mr. BEAN. It has to be on the table, or you will not get producers 

to participate. 

Mr. LABRADOR. Thank you very much. As Director Moore stated 

in his written testimony, the population of wolves in Idaho continues to thrive under state management, far exceeding the recovery levels set by the Fish and Wildlife Service when it reintroduced 

them in 1995. 

It is clear from our witnesses and from our attendance today that 

wolf management is a critical issue for people throughout our 

Nation; and I would like to draw the committee’s attention to this 

photo, which was taken in 2013, after a wolf in Idaho drove 176 

sheep over a cliff to their death. 

[Slide] 

Mr. LABRADOR. While I apologize for the disturbing nature of this 

photo, it is an accurate illustration of what so many people are 

dealing with, and why oversight of wolf management is so 

important. 

Director Moore, Idaho is successfully managing a thriving wolf 

population. How many wolves are in Idaho now, and what was 

Fish and Wildlife’s original wolf population goal? 

Mr. MOORE. We have, as of this year, 786 wolves in the state of 

Idaho. That is our best minimum estimate. And the recovery goal 

was 100 wolves for the state of Idaho. 

89 

Mr. LABRADOR. What has made Idaho’s wolf management so 

effective? 

Mr. MOORE. I believe it is because we had a lot of open space and 

a lot of forage. Wolves are not a habitat-dependent species. They 

are dependent more on human tolerance and on availability of 

forage. 

Mr. LABRADOR. OK. How does Idaho respond to cases of wolf 

depredation on livestock? 

Mr. MOORE. As Director, I authorize those activities. When a 

landowner notifies us and is verified by USDA wildlife services 

that we have a wolf problem, we will issue a variety of control actions. Those control actions can be to the landowner or through 

wildlife services for either lethal take—generally it is lethal take, 

that is the preference of the landowner or the operator. 

Mr. LABRADOR. Director Moore, in your written testimony, you 

describe the path to state management of a robust wolf population 

was tortuous, and that you are deeply disappointed that an Act of 

Congress was necessary to reinstate state management of wolves 

in Idaho and Montana. 

Even though Idaho has proven without a doubt that state management of recovered species works, do you feel confident that the 

Federal Government will allow state management of other recovered species without a similar process? 

Mr. MOORE. No, I do not. We are suffering from that with several 

other species right now. 

Mr. LABRADOR. Do you think that we could actually handle other 

species in Idaho? 

Mr. MOORE. Absolutely. 

Mr. LABRADOR. Do you believe that Federal mismanagement of 

wolves is a contributing factor for higher levels of depredation in 

states like Wyoming? 

Mr. MOORE. Yes, our information clearly shows that we have had 

a decline of 70 percent in depredation since delisting by the use of 

hunting and trapping, and that we have reduced the number of 

wolves killed during that same time period from 2009 to 2015 by 

43 percent. 

So, controlled hunting and trapping has reduced the need for further dependencies. That is not true in Wyoming, where they do not 

have regulated hunting. 

Mr. LABRADOR. Thank you. 

Mr. Bean, again, thank you for being here today. You play an active role in working with county, state, and Federal officials, as 

well as conservation groups and other ranchers to successfully 

manage wolf populations in Idaho. Correct? 

Mr. BEAN. That is correct. 

Mr. LABRADOR. That is what is great about state management. 

States have the flexibility to work with stakeholders to develop 

local solutions to management issues. Would you agree with that? 

Mr. BEAN. Well, I think that state management and its effectiveness depends on the state management plan, and that varies state 

by state. States have very different implementations and perspectives on how wolves should be managed. 

90 

Mr. LABRADOR. Based on your experiences, what 

recommendations do you have for Congress to better facilitate 

recovery and management of species? 

Mr. BEAN. Of the gray wolf, specifically, sir? 

Mr. LABRADOR. Or in general. 

Mr. BEAN. I think that the cognizant wildlife management agency operates within the framework of the ESA. As long as that 

framework is flexible and enables them to adjust and manage properly without interference, then they should be allowed to do that 

as the professionals on the ground. 

Mr. LABRADOR. So you are asking for flexibility? 

Mr. BEAN. I am asking for or suggesting that the act provides the 

flexibility that would enable the agency to do its job. 

Mr. LABRADOR. And you have had some successes. How are you 

sharing what you have learned and what works with other 

ranchers? 

Mr. BEAN. We have an outreach program through the Wood 

River Wolf Project. We have our Website up for the first time. We 

are adding resources to that Website that would allow people to understand what we do. I have personally participated in discussions 

with the fully assembled wolf advisory group in Washington State, 

and am often asked, including remotely, in the case of California, 

to discuss what we have done in terms of nonlethal wolf management in Idaho for the benefit of those that are just now coming to 

a realization that wolves are in their backyard. 

Mr. LABRADOR. Thank you very much. 

Mr. BEAN. You are welcome. 

Mr. GOHMERT. Thank you. The gentleman from Arizona, Mr. 

Grijalva, is recognized for 5 minutes. 

Mr. GRIJALVA. Thank you, Mr. Chairman. 

I want to go back to you, Mr. Bean. In his written testimony, Mr. 

Paterson makes a number of claims and assertions. One of the 

troubling ones to me are the statements saying that his grazing 

fees should be reduced because wolves are present, and that the 

American people should pay for the privilege of having wolves on 

the ground. 

To be clear, I think we need to clarify that, because the American 

people are already heavily subsidizing the privilege of grazing cattle on U.S. public land, and are paying millions of dollars each year 

to help recover threatened and endangered species like the 

Mexican wolf, while also paying for programs designed to protect 

Mr. Paterson’s cattle and compensation for livestock loss. However 

inadequate Mr. Paterson believes it is, it is still additional taxpayer 

subsidy. 

So, Mr. Bean, do you believe Mr. Paterson and others have a 

responsibility to protect their own investment as you have done, instead of relying on the government to do it for them? 

Mr. BEAN. Congressman Grijalva, I believe that all livestock producers have an ethical and moral responsibility to do what they 

need to do to protect their animals in the wild. And remember, at 

least in most states, or at least states where the delisting has occurred, what you have is lethal control actions that are only legitimately possible after livestock have been killed. If you prevent the 

91 

killing in the first place, then a lot of the subsidies do not need to 

come in to play, and you have protected your animals. 

Mr. GRIJALVA. Are you aware of any nonlethal control measures 

that a person such as Mr. Paterson could employ to reduce wolf 

predation on cattle? 

Mr. BEAN. Cattle have proven to be a little bit more problematic, 

but a lot of advances have been made in the last 4 to 5 years, 

Congressman. These include range riding, and they include rewilding. 

Remember that cattle in most western states lived for 80 years 

or more without the depredation pressure of wolves. As a 

consequence, they have lost a lot of their instinctive defensive behaviors in the face of this apex predator. So, what we have is a situation where we are learning the tools and techniques for cattle. 

But range riding has proven very effective, and actually has a 

very important solidary and unanticipated benefit, which is sick 

animals, like calves or cows, are able to be seen and treated earlier—that death loss is prevented, death loss can go down, overall— 

more even range land utilization, and protected cattle. We have 

seen that in the Centennial Valley in Montana and in the Tom 

Miner Basin. So, there are existing proofs of both those assertions. 

Mr. GRIJALVA. And by not leaving cattle unattended for long 

periods of time, is that the point? 

Mr. BEAN. Well, that is certainly one of the points. If you pasture 

your cattle and come back in 2 weeks, well, you get what you get. 

Mr. GRIJALVA. Do you believe the attitude that wolves have no 

value and should be eradicated is one that is compatible with the 

continuation of ranching on U.S. public lands in the long run? 

Mr. BEAN. I do not believe that that is compatible with ranchers’ 

best interests. I think that the attitude that the only good wolf is 

a dead wolf, or that wolves should be killed and that killing paid 

for by taxpayers on public land, including in congressionallydesignated wilderness is problematic. I think it places our public 

grazing preferences at risk. 

As I had mentioned previously, if those grazing preferences go 

away, then those ranching operations will fail, typically because 

they cannot survive on the deeded properties alone. 

Mr. GRIJALVA. OK. I yield back, Mr. Chairman. 

Mr. GOHMERT. Thank you. At this time the gentleman from 

Arkansas, Mr. Westerman, is recognized for 5 minutes. 

Mr. WESTERMAN. Thank you, Mr. Chairman, and thank you to 

the panelists for being here today. 

Director Sandoval, while the wolves in your state remain in the 

specific geographic area set forth for their reintroductions, they are 

managed as experimental populations under their own set of rules 

and under this 10(j) rule. However, wolves tend to move out of 

those areas onto private or state lands, where they are governed 

by the ESA. 

Do you think it would be better, or more appropriate, for states 

to manage wolves that have wandered outside of their geographic 

recovery area? 

Ms. SANDOVAL. Mr. Chairman, Congressman Westerman, absolutely. When you think about the burden that comes with that ESA 

designation as being fully endangered on that wolf, and it walks 

92 

outside of that geographical area defined by the 10(j) rule, it becomes extraordinarily problematic to be able to measure how you 

are going to manage that. 

If the state has the ability, and we are far more flexible than the 

Federal Government out there, just by the fact that we operate in 

those areas on a daily basis. The ability for the state to be able to 

manage without having that ESA designation would be extraordinarily helpful for the state. 

Mr. WESTERMAN. OK. Mr. Guertin, as my colleague from 

Michigan mentioned earlier, there is a recent study out—I believe 

the one that I saw was by Princeton and UCLA—that raised some 

serious questions about wolf genetics. I believe it actually said 

there is only one species of wolf, the gray wolf—and the red wolf 

is 25 percent gray wolf and 75 percent coyote, and the eastern wolf 

is 75 percent gray wolf and 25 percent coyote. 

But, nonetheless, it seems that the scientific community is unable to reach a consensus as to whether a red wolf should even be 

regulated. And just for the record, your Agency is moving forward 

as if it is a listable entity. Is that correct? 

Mr. GUERTIN. Yes, Congressman. We believe there is enough 

scientific evidence that the red wolf has been treated as and will 

continue to be treated as a separate species. That is based on both 

genetics, behavioral, taxonomic, and other criteria. 

Mr. WESTERMAN. Director Myers, are releases of red wolves 

allowed on private property in North Carolina? 

Mr. MYERS. Congressman, under the Federal rules that were promulgated by the Fish and Wildlife Service, releases were only to 

occur on Federal lands. 

Mr. WESTERMAN. OK. And, Mr. Guertin, the red wolf recovery 

program required that red wolf populations be self-sustaining and 

contained to Federal lands. Did your Agency release wolves onto 

private property in North Carolina in violation of both state and 

Federal requirements? 

Mr. GUERTIN. Yes, Congressman. Wolves were released onto 

private land, but they were released under the larger tenets of the 

Endangered Species Act. 

Mr. WESTERMAN. Were there any agreements with the private 

landowners? 

Mr. GUERTIN. Yes, Mr. Congressman. We had worked to the best 

of our ability with private landowners to make these releases. I believe, looking at the historical record, there were a couple of instances where that was not hammered out. It may have been 

talked about in concept. But going forward, we are intending to do 

all of these with some type of contract with private landowners. 

Mr. WESTERMAN. So, do you have any written agreements that 

you can provide to the committee with the—— 

Mr. GUERTIN. Yes, Congressman. We can and we can provide 

similar documents in other regions in the country, where we work 

on endangered species restoration and recovery efforts for species 

including black-footed ferret or other—— 

Mr. WESTERMAN. Can you do that in North Carolina? 

Mr. GUERTIN. Yes, we can. 

Mr. WESTERMAN. All right. 

93 

Director Myers, what is the general attitude about wolves in 

North Carolina, particularly in regards to wolves on private 

property? 

Mr. MYERS. Congressman, it is hard to characterize the general 

attitude. I will say that, given the removal of opportunities for 

landowners in the reintroduction area to address concerns with 

coyotes on their property, the attitude toward the red wolf program 

has diminished significantly. 

Mr. WESTERMAN. I believe there was a program that was tried 

in Tennessee that failed back in the 1990s. This program in North 

Carolina does not seem to be too successful. 

So, Mr. Guertin, what makes the Service confident that other red 

wolf introductions will be successful throughout the region between 

Texas, Pennsylvania, and the Atlantic? 

Mr. GUERTIN. Congressman, we have learned a lot the last few 

years, both with the red wolf recovery program and our experiences 

particularly with the gray wolf on how to have a successful reintroduction and recovery program. 

The vision, going forward for the red wolf, is to first cement our 

seed stock by focusing on genetic integrity of animals in both the 

captive population maintained by a number of institutions, as well 

as some interchange with the wild population remaining on the 

Federal estate there. Second, doing a 5-year review to make sure 

we are track. Third, exploring the possibility for additional release 

sites with willing partners. There have been no conversations, 

other than a concept at this point. And fourth, building on some 

of the hard lessons learned in other regions of the country. 

I, before coming back here to Washington, served as regional director for our Mountain Prairie Region, and was intimately involved in our ongoing efforts for recovery with wolves in Montana, 

Idaho, and Wyoming, including leading our team to write those 

delisting rules so we could move management of the species to 

state control. We want to take those type of lessons learned and 

apply those, as well, to the red wolf recovery program. 

Mr. LABRADOR [presiding]. The gentleman’s time is expired, and 

the gentleman from Virginia. 

Mr. BEYER. Thank you, Mr. Chairman. I would like to just begin 

by trying to create a sense of context and proportion. I don’t want 

to minimize Mr. Paterson’s experience in New Mexico or Arizona, 

but to make the case that wolves do have an insignificant impact 

on the cattle industry in the United States. In the eight states with 

gray wolves, less than 1 percent, or nine-tenths of 1 percent, of the 

cattle deaths are from wolves. 

In contrast, 8 percent are from weather, 74 percent from other 

health issues. Last year, we slaughtered almost 29 million cattle in 

the United States, and gray wolves killed 6,777. Basically, we 

slaughter 5,000 cows for every 1 that is killed by a gray wolf. I just 

think it is very important to put this overall in proportion. 

And there are multiple programs for reimbursement: the 2009 

Omnibus Public Lands and Management Act, the Mexican Wolf 

Introduction Trust Fund, and the Livestock Indemnity Program. As 

Mr. Paterson suggests, perhaps those programs could be improved 

if you are only getting reimbursed for nine—what was it, four 

calves and five cows—when perhaps you had $116,000 worth of 

94 

losses? But clearly, this Congress again and again has said that 

they are willing to pay for depredation losses in order to have a 

balanced approach to our natural resources. 

Let me just look at Wyoming in 2015—134 livestock were killed 

last year by wolves: 72 cattle, 62 sheep. The average reimbursement was $2,500. In contrast, there were 77 wolves killed by predation. So we actually killed more wolves than wolves killed cattle 

last year. 

Let me move on. Mr. Guertin, the recent population viability 

analysis shows that there is less than a 1 percent chance of extinction of the captive red wolves based on the current population over 

the next 100 years, but 100 percent possibility of extinction of those 

red wolves living in the wild. 

So, why have you chosen to focus on the captive wolf population, 

while ignoring the larger wild wolf population? In the statistics I 

show, there are only 29 known wild red wolves right now. Doesn’t 

the population viability analysis show that forcing them to live on 

only the Alligator River National Wildlife Refuge, as proposed by 

Fish and Wildlife, will ultimately result in the extinction? 

Mr. GUERTIN. Congressman, that is a very astute observation. 

There are very few wild red wolves on the landscape right now in 

North Carolina. At the same time, the science is clearly showing 

us that there are not enough wolves in the captive breeding program to ensure species survival, going forward. The health of the 

species is at risk. 

We have made a policy choice to focus on rebuilding that seed 

stock via the captive program using zoos, aquaria, and other partners throughout the country. We believe firmly in ongoing restoration recovery of the wolf in the wild, and will manage both the 

remaining wolves in the wild and those in the captive breeding program with selective interchange and replacement to keep the 

behavioral characteristics we are looking for intact in the species. 

We are coupling this with a larger strategy, a larger vision, to 

look at potential areas to rebuild wolves in the wild, but we come 

back to the underlying science, which points to us the peril the 

species is in and the aggressive intercession we need to make to 

ensure viability, going forward. 

Mr. BEYER. Thank you, Mr. Guertin. My friend, Mr. Labrador, 

put up a slide of the sheep run off the edge of the cliff. I think it 

was 136. 

Dr. Vucetich, you had written and thought a lot about making 

the argument that wolves don’t kill for fun, they kill for food. How 

do you reconcile—and I know you have written about that—your 

perspective with the picture? 

Dr. VUCETICH. Well, a wolf is able to live to be about 10 or 12 

years of age, but most wolves are dead by age 4. This is even true 

under normal circumstances. The most common causes of death are 

starvation and fighting with other wolves over food. This is the 

case when humans are not involved with killing them. The point 

of those statistics is that getting food is extremely difficult for 

wolves. They are always trying as hard as they can to get food. And 

when they do so, they are lucky to make it about to half or a third 

of their life span. So wolves are programmed to essentially try 

hard. 

95 

Then what happens on occasion, occasions like this, wolves run 

into a situation where food is much easier to get than other circumstances. They follow their instincts, and then, of course, unfortunate incidences like this occur. That is the biology behind it, sir. 

Mr. BEYER. So this is still survival of the species, rather than 

killing for fun? 

Dr. VUCETICH. One hundred percent correct, yes. 

Mr. BEYER. Great. Mr. Chair, I yield back. 

Mr. GOHMERT. Thank you. We are honored to have with us the 

Senator from North Carolina. 

Senator Tillis, you are recognized for 5 minutes. 

Senator TILLIS. Thank you, Mr. Chairman, Ranking Member, for 

having this hearing and allowing me to participate. 

Mr. Myers, it is good to see you. It was good to work with you 

when I was Speaker of the House and the Wildlife Resources 

Commission of North Carolina. In less than a minute, can you describe the red wolf program and the captive breeding program, 

your perspective, your assessment of it? 

Mr. MYERS. Thank you, Senator. Mr. Guertin just spoke of the 

peril that the red wolf faces. Forty years ago, that peril was the 

coyote. Today, that peril is again the coyote. And the Service’s 

recommendation to maintain a small population of intensively 

managed red wolves on Federal lands in Dare County is simply inconsistent with their newly prioritized captive breeding population 

objectives. 

Today, 30 years after the first reintroductions, and despite intensive management practice, and very intensive management practices of tubal ligations and vasectomies to coyotes, releases of more 

than 165 animals, 58 in Dare County alone, there is only one 

known wolf pack that currently occupies Federal lands. 

Meanwhile, in the 10-year period from 2002 to 2012, the reported 

numbers of coyotes trapped across our state has increased 2,600 

percent. I point that out because much of the information relative 

to the success of the adaptive strategy of sterilizing coyotes, a lot 

of that data dates back prior to this escalation and proliferation of 

coyotes. So, you can just imagine the intensity and the intensive 

effort that would be required to continue that practice to avoid the 

threat of hybridization. 

Senator TILLIS. Mr. Myers, didn’t you mention—I am sorry, just 

in the interest of time, they are a lot more strict over here than 

they are in the Senate, so I am going to keep tight on my time— 

I met with you earlier today and met your lovely wife in my office. 

Did you say that there are 30,000 takings of coyotes in North 

Carolina a year? 

Mr. MYERS. Our current hunter harvest estimate ranges between 

25,000 and 35,000 per year. 

Senator TILLIS. I am not a specialist in this wildlife management, but I know a little bit about math. So, it probably means 

that we have a lot of coyotes in North Carolina, a lot of coyotes out 

in Dare County, a lot of coyotes out in the counties where these 

species were released before. How on earth can you ever overcome 

those numbers and think that the agency has a credible strategy 

to prevent hybridization? 

96 

Mr. MYERS. Senator, I do not believe there is a strategy that 

avoids this conservation reliance. I think it is a self-sustaining 

component. I do not think it can be achieved—— 

Senator TILLIS. It is a numbers issue. I would love to see a thriving red wolf population, I just don’t see how you accomplish it, 

given the challenges that we have. 

Mr. Chair, I have some statements from various farmers and 

landowners if I may submit for the record. 

Mr. GOHMERT [presiding]. Without objection. 

Senator TILLIS. And I would love to ask questions of Mr. Guertin. 

I will follow up with you. 

But one thing I would urge this committee to look at is the failure of this program. The fact of the matter is, even by their own 

estimate, a report that was issued in September of this year says 

it is a failure. This comes from the Fish and Wildlife Service. 

The Office of the Inspector General back in February of this year 

said that it was a failure. They said that they did not follow their 

own rules. They released wolves well beyond the number that they 

were supposed to, some on private lands. 

I would love to find a credible way to sustain a wild population 

of red wolves; but I have to say that this agency has no credibility, 

based on the lack of respect that they have had for the landowners, 

the numbers that are pretty compelling, and an independent report 

by the Office of the Inspector General. 

And now we are talking about a cessation of the program, and 

relocating some of these breeding pairs to Dare County out of the 

five-county area that they are today. Are we going to do some sort 

of orientation to make sure that they stay on the Federal lands 

there? What is the likelihood some of those are going to try and 

migrate back to where they came? 

And we have studied that. I know that Mr. Myers has studied 

that. They have proven that if you catch them and put them in one 

area, they try to get back. We discussed an example of a wolf and 

coyote in my office today. So there does not seem to be any credible 

basis for doing what we are talking about doing. 

And it is odd to me, because we are talking about moving the 

pairs, but then we are talking about increasing the number. How 

is that a ramping down of the program? 

It seems to me that there should be a reset to figure out an appropriate way to do it, to make sure that the captive breeding population program is able to sustain the species. But before we do 

anything more in North Carolina, I think it makes more sense to 

shut it down, figure out how to do something right, build some 

credibility with the landowners, the property owners, and the other 

people that—quite honestly, there is a pretty long history of lessthan-respectful dialogue between the folks at least in North 

Carolina—I won’t speak for the other regions that may have concerns—and the Fish and Wildlife Service. 

This is going to be something our office is going to stay focused 

on for as long as I am a U.S. Senator, and that is at least another 

4 years. We will reach out to your office and speak more, but we 

have to get this program that has zero credibility under control. 

Mr. GUERTIN. May I respond to the Senator, Mr. Chairman? 

Mr. GOHMERT. Yes. 

97 

Mr. GUERTIN. Senator, thank you for your offer, and we would 

be honored to come up and sit down with you and your key staff 

to discuss this further. Thank you. 

Mr. GOHMERT. All right, thank you. 

And Senator, we have been honored to have you here. 

The Chair recognizes the gentleman from Michigan, Mr. 

Benishek, for 5 minutes. 

Dr. BENISHEK. Thank you, Mr. Chairman. Thank you for 

allowing me to participate here. 

I have to, unfortunately, contradict my colleague from Michigan, 

Mrs. Dingell, in that, in your opening statement, you mentioned 

that hunting deer in Michigan has not suffered under the wolf. 

That is not really the case in my district. You know, there has been 

a dramatic drop in the deer population and in the hunting results, 

as well. As a matter of fact, they canceled the doe permits in my 

district last year. 

I want to ask Mr. Guertin a couple questions. 

How would you categorize the status of the gray wolf population 

in the Western Great Lakes Region right now? 

Mr. GUERTIN. The Fish and Wildlife Service’s view of the population of wolves in the Western Great Lakes is that they are recovered, Congressman. There are over 3,600 wild animals in the three 

states, and we wrote a rule to delist those animals, remove 

Endangered Species Act protection, and return management to the 

state. That rule was overturned on judicial review. The Department of Justice is appealing that overturning in a hearing that is 

set to begin oral arguments in—— 

Dr. BENISHEK. What was the number you used, 3,600? Is that 

what you said? 

Mr. GUERTIN. Yes, Congressman. 

Dr. BENISHEK. OK. 

Mr. GUERTIN. In the three states. 

Dr. BENISHEK. In the opinion of the Fish and Wildlife Service, 

what is the impact of the continued Federal management of the 

gray wolf population in the Western Great Lakes Region, both on 

the wolf population itself and the great ecosystem? 

Mr. GUERTIN. Do you mean the biological impact? 

Dr. BENISHEK. Not being able to manage the wolves. 

Mr. GUERTIN. Well, under the Endangered Species Act 

protections, the Federal agencies ourselves are the primary jurisdictional agency to manage all issues arising, whether it is recovery 

actions or whether it is depredation issues. We build a strong rapport and working relationship with the state fishing agencies at the 

same time. We have worked with them in partnership over the last 

year. Over 200 wolves were removed from that population for 

depredation-related issues that were authorized under their status. 

Dr. BENISHEK. All right. 

Now, Dr. Vucetich—is that how you say it, Vucetich? 

Dr. VUCETICH. Vucetich. 

Dr. BENISHEK. Vucetich, OK. Well, welcome. Michigan Tech, of 

course, is in my district, and I have visited many times, so it is a 

pleasure to see you. And I am happy to hear of your expertise with 

the wolf. 

98 

Can you give me an estimate of the impacts of the gray wolves 

and the population, the deer population in the Upper Peninsula? 

Dr. VUCETICH. Yes, it has not been demonstrated that wolves are 

negatively impacting deer in the Upper Peninsula of Michigan. 

Dr. BENISHEK. Well, I have to tell you that that sort of differs 

from my experience. I have a place in the Ottawa National Forest. 

I am sure you are very familiar with that. And, maybe not everywhere in Michigan, but in the Western and Upper Peninsula in 

Michigan, there are no deer left. Like I said to Ms. Dingell, they 

canceled the doe season last year because there are no deer. 

And that is a problem. I get this from my constituents, OK? It 

is not like I am making this stuff up, because I have people coming 

to me, complaining about the fact that there is nothing to hunt. 

Well, let me just go on a little bit. I want to talk about this lawsuit a little bit. You talked about—what is it, a DPS—I cannot 

quite remember the term there, population—— 

Dr. VUCETICH. Distinct population segment. 

Dr. BENISHEK. Yes, yes, the distinct population segment, and 

that one of the bases of the court decision was that, since the gray 

wolf has not returned to its entire habitat, that that is one of the 

bases of overturning the decision to delist the wolf. Is that my 

understanding of—— 

Dr. VUCETICH. No, I don’t think that is a fair description of what 

the judge’s decision was; and the judge’s decision was complicated. 

But, in a nutshell, what I believe that is related to is a requirement by the Endangered Species Act which suggests—not in legal 

terms, but in laymen’s terms—that a species needs to be well distributed throughout its former range. 

Dr. BENISHEK. Well, see, that part I don’t understand. Because, 

for example, the city of Detroit and Wayne County was the former 

wolf range. So, we are not going to treat it as recovered if Wayne 

County is no longer populated with wolves? 

I don’t understand what you are going to use as the new range 

that the wolf is there. I mean there are lots of wolves in the Upper 

Peninsula, I will tell you that. 

Dr. VUCETICH. No, there is no requirement, and no one has ever 

suggested that there is a requirement for a species to occupy all of 

its former range. That has never been suggested by anyone who 

studies the problem. 

But what is clear from congressional intent and from a series of 

judicial decisions, is that it seems that a species needs to be—and 

again, some of these things are difficult, because they have not 

been sorted out adequately, and so I know I am using the term 

loosely—but well distributed throughout its former range. 

If we can refer to what the law says, what the law says is that 

if a species is at risk of extinction throughout all or a significant 

portion of its range, that is the definition of endangered, and you 

are not recovered until you no longer fit that definition. 

Dr. BENISHEK. I am out of time, but I would enjoy talking to you 

more about this issue, so thank you. 

Mr. GOHMERT. Thank you. The gentleman from New Mexico, Mr. 

Pearce, is recognized for 5 minutes. 

99 

Mr. PEARCE. Thank you, Mr. Chairman. I appreciate the testimony from each one of you here today. I have several documents 

here I will submit for the record as we go through. 

But first, we have had, through my 12 years of service, continual 

references from local ranchers and local elected officials as to the 

misconduct of the Fish and Wildlife Service regarding the Mexican 

gray wolf program. So, 3 years ago we asked for an IG report. That 

IG report came back earlier this year. I would like to submit that 

IG report fully for the record. 

Mr. GOHMERT. Without objection. 

Mr. PEARCE. It is fairly complex, and so our office took the liberty 

of breaking out the major, major problems that were identified by 

that. So, in numerous instances, the IG finds where the Fish and 

Wildlife Service is falsifying information. They falsified about a 

wolf bite. That is critical, because you have to euthanize the wolf 

when it bites. 

They have falsified the location of wolf kills, they have falsified 

reports over a dozen times. That is page 11 of the report. They 

have falsified the wolf attributed to the kill, because you have to 

euthanize wolves after a certain number of kills. And if they 

change which wolf killed it, then they do not have to euthanize the 

genetically pure wolves. 

The IG report contains numerous instances of lies. The Fish and 

Wildlife Service lied in a press release about the wolf biting a volunteer. The employee lied directly to the IG. That was on page 5. 

They lied about the wolf not being a nuisance. Then the IG found 

many instances of mismanagement: first of all, they hired someone 

incompetent to head the IFT team, a team member states to the 

IG that the former IFT coordinator was unprepared to assume the 

coordinator role and that that team leader could not even correctly 

identify which wolf breed they were working with. He didn’t know 

the differences between the Alaskan wolf and the Mexican gray 

wolf; poor communications with the public; never met with county 

employees; and then, the fourth major area—so, again, we have 

identified in the IG report falsification, lies, mismanagement—and 

then the final major area of finding was the manipulation of scientific data. The employee admitted to manipulating data, a former 

IFT coordinator. Denied consciously manipulating it, and then later 

admitted that, well, maybe she did treat those wolves just a little 

bit differently than other wolves, if they are genetically pure. 

She also refused to fill out the required nuisance reports, and encouraged other Federal employees not to fill out these nuisance reports. I would like to submit for the record this kind of general 

breakdown. So, if I could submit that for the record, thank you. 

Mr. GOHMERT. Without objection. 

Mr. PEARCE. I also have an email from Alan May—he works with 

APHIS and he is talking about trying to get him to alter his report, 

or trying to get Mike to alter his report. He finds that very disturbing. That was a practice that continued and was never brought 

into check. 

The next thing that I have, the person who was on the initial 

wolf recovery program, a Roy McBride, raises questions, even to 

the genetic purity. And I would like to submit that letter for the 

record. 

100 

Mr. GOHMERT. Without objection. 

Mr. PEARCE. Also, Mr. Chairman, if I could, one of the outcomes 

of today’s hearing, we asked the IG to report to us on the genetic 

purity of the strain, because there are significant findings that indicate maybe there is not a pure strain at all, and maybe we are 

just practicing something we can never get to. 

So, if I could request that you all consider asking the IG to do 

that, and then also go ahead and figure out the answer to the depredations and reimbursement issues that we have heard, both sides 

of the issue today; if the committee could do that. If you don’t find 

that to be useful, then we will submit that request again. 

And just to kind of put things into context, I have a document 

by Jack Woody, U.S. Fish and Wildlife Service. He was on the 

March 1986 program, and he is talking about how the founding female of the ASDM-GR line was said to have been captured as a 

pup near Sonora, Mexico in 1961. She was donated to the ASDM 

by tourists passing through Tucson, Arizona on a motorcycle trip. 

The tourist was concerned the pup would not survive the motorcycle journey. So, when you go all the way back to the beginning, 

we have a dadgum motorcyclist going through Tucson, carrying a 

wolf—I mean this stuff is—yet we are supposed to believe the 

science and all of this validity and verifications? 

I would yield back the balance of my time, Mr. Chairman. 

Mr. GOHMERT. At this time the Chair recognizes the gentleman 

from California, Mr. LaMalfa, for 5 minutes. 

Mr. LAMALFA. Thank you, Mr. Chairman. Of course, this is a 

very important issue, as I represent the very northern part of 

California, where wolves are being introduced or pushed into the 

state now. I find it fascinating that the comfort level with which 

urban legislators can just dismiss what the impact is when they 

don’t have to worry about them in their backyard, in their parks, 

or they don’t have to put their kids in a cage at a bus stop in order 

for them to be protected while the bus comes—OK? This is a fascinating attitude to me. 

Earlier, we heard about the depredation happening in the cattle 

industry being not a big deal, because it is only 1.5 percent. If you 

have a million head of cattle that is consumed per year, and you 

lose 6,000 of them—I wonder what General Motors would think of 

that, if they produced a million cars per year and somebody stole 

6,000 off the end of the line. Or let’s say for a politician in a tight 

district, what if 6,000 votes were filched away from their election? 

I think it would get people’s attention. It certainly does the rancher 

who has the losses on that. 

Director Guertin, in 2009, the U.S. Fish and Wildlife Service 

acted in order to remove the gray wolf from the endangered species 

list. The lawsuits from extremist groups continued to keep the wolf 

on the list, because the Service evidently does not want to make 

a move on it. 

Despite all contrary data, this is essentially providing guidance 

to state agencies, such as California, who has moved to list it in 

California, and now that the wolf is being introduced to the states, 

or pushed down from Oregon, et cetera. So, we are just leading the 

states astray on something that the Service has already provided 

for to be removed from the list, kind of what we are dealing with 

101 

in California. The Valley elderberry great-horned beetle should 

have been delisted, as recommended, years ago, and we cannot do 

levee projects because there might be elderberries in the habitat. 

They have been fooling with that for 8 or 9 years. It is a very frustrating process that we hear delisting, and then it does not happen. 

So, if they have already reached the population goals set by the 

Service—I heard over 5,500 wolves in the Upper Midwest—what 

criteria will they eventually rely upon to say they do not need to 

be on this list any more? 

Mr. GUERTIN. Congressman, the Northern Rocky Mountain Wolf 

population is about 1,800, 1,900 animals, largely in Montana—— 

Mr. LAMALFA. Is it a gray wolf? 

Mr. GUERTIN. Yes, those are the gray wolf. Of those animals, two 

of the states manage them now under state control, because they 

were delisted by the U.S. Fish and Wildlife Service. That also included the eastern third of Oregon and Washington. Wyoming was 

subsequently delisted by the Fish and Wildlife Service. That 

delisting was overturned by a court, but we actually have oral 

arguments to appeal that Friday. 

Mr. LAMALFA. Why is it a state-by-state listing? We have a gray 

wolf, we have 6,000 of them in North America. Why do they have 

to be distributed through every state, otherwise it is delisted state 

by state? 

Mr. GUERTIN. These animals that are starting to show up in 

Northern California came from the Northern Rocky Mountain 

population. There are now—probably six or seven have been 

documented in the state of California. 

Mr. LAMALFA. Approximately seven. 

Mr. GUERTIN. They are an endangered species at this point. We 

are working proactively—— 

Mr. LAMALFA. But they are not endangered if they are across the 

line and—a couple lines in Colorado or something. 

Mr. GUERTIN. They would be endangered in Colorado—— 

Mr. LAMALFA. OK, whatever state you listed, we don’t have time 

for, they would not be endangered in the other state, but they happen to travel, so it is endangered in California. 

Mr. GUERTIN. Congressman, what I would also state for the 

record is we have proposed to delist gray wolves in the remainder 

of the Lower 48, except for the Mexican gray wolf subspecies. That 

was also overturned by a court. Our hope is that we get a favorable 

outcome for these two legal cases in Western Great Lakes and in 

Wyoming—— 

Mr. LAMALFA. So, we may have some project down in the Southwest, but we can still anticipate California will continue to have an 

endangered status? 

Mr. GUERTIN. No, Congressman. We anticipate, if we are successful in getting a Federal court to delist the wolf in Wyoming and 

delist it in the Upper Midwest, we would then proceed with a rulemaking to delist the wolf in California and the rest of the Lower 

48. 

Mr. LAMALFA. All right. Thank you for that. 

Mr. Moore, I am going to run out of time here again. Quickly, 

in California right now there is zero compensation for the takings 

of wildlife. They don’t even want to admit when it is one. Like they 

102 

had a calf killed in, I think in Siskiyou County, where there were 

five wolves eating on it, but they were not sure that it actually 

could be attributed to wolves. 

How would you say the compensation should work in California 

versus Idaho? 

Mr. MOORE. Idaho has only a small portion of Federal money left 

for compensation. It is the only game species that does not get compensated for depredations in the state of Idaho with sportsmen’s 

money. 

Mr. LAMALFA. Well, they do have a depredation process through 

controlling—— 

Mr. MOORE. Yes, they do. It goes through the Governor’s Office 

of Species Conservation. 

Mr. LAMALFA. OK. Thank you, Mr. Chairman. 

Mr. GOHMERT. Thank you. At this time the Chair recognizes the 

Ranking Member for closing comments. 

Mrs. DINGELL. I know we are at the end of time, and we can all 

tell that this is an emotional, complicated issue that we have to 

keep talking about. I, alone, am not an expert like any of you—- 

responding to my Michigan colleague—and have already found that 

data that says the doe hunt was not canceled because of wolves. 

But severe winters take a toll on deer because of the increased rate 

of starvation, and that was why the hunt was—so, Mr. Chairman, 

I would like—and there is another article about coyotes, not 

wolves, that we could put for the record to respond. 

Mr. GOHMERT. Without objection. 

Mrs. DINGELL. And other people who have questions could do so, 

as well. Thank you. 

Mr. GOHMERT. OK. Without objection, it will be so ordered. 

As we have heard today, management of wolves is a critical concern for citizens of a large portion of our Nation. It is appropriate, 

given our oversight role, that we ensure that the Federal Government is managing wolves responsibly and effectively. To do so, the 

Service must follow the law and its own rules. It must hold employees accountable for misconduct. It must take responsibility for its 

failing efforts, rather than expanding them without any reasonable 

expectation of a different result. It must work with the states, citizens, and other stakeholders in wolf recovery planning and efforts. 

States are, by far, the best situated and equipped entities to 

manage wildlife within their borders. Our intent has always been 

clear in this regard: management responsibilities for recovered species must be transferred to the states at the earliest possible juncture. Such management ensures the best outcome for the species 

and the stakeholders, and it is inexcusable when continuous costly 

litigation is used to undermine a process Congress clearly spelled 

out. 

At this time, we do thank you for your attendance. We know it 

is a great hassle. You have been very patient with us, and we appreciate your expertise and your experiences. They are part of the 

record that will be around as long as there is a United States of 

America. And that will enable us to take those comments, take 

your observations, and look further. 

Members of our committee and our distinguished guests may 

have some additional questions for the witnesses, and we will ask 

103 

you respond to those in writing. Under Committee Rule 4(h), the 

hearing record will be held open for an additional 10 business days 

for these responses, should there be such questions. 

If there is no other business at this time, without objection, the 

committee stands adjourned. 

[Whereupon, at 5:00 p.m., the subcommittee was adjourned.] 

[ADDITIONAL MATERIALS SUBMITTED FOR THE RECORD]

ASSOCIATION OF FISH & WILDLIFE AGENCIES, 

WASHINGTON, DC 

September 27, 2016 

Hon. LOUIE GOHMERT, Chairman, 

Hon. DEBBIE DINGELL, Ranking Member, 

House Subcommittee on Oversight and Investigations, 

1324 Longworth House Office Building, 

Washington, DC 20515. 

Dear Chairman Gohmert and Congresswoman Dingell: 

On behalf of the Association of Fish and Wildlife Agencies (Association), I submit 

this letter for the record of the Subcommittee hearing of September 21, 2016, on 

‘‘Federal Government Management of Wolves.’’ Founded in 1902, the Association’s 

mission is to support and advocate for state, provincial, and territorial authority for 

fish and wildlife conservation and to assist those agencies in promoting sciencebased resource management in collaboration with public and private partners. In 

satisfying our mission, we cooperate closely with federal agencies, conservation 

NGOs, our fish and wildlife constituency, and the general public. All 50 state fish 

and wildlife agencies are members of the Association. 

The Association strongly supports the testimony presented at the Subcommittee 

hearing on September 21, 2016, by Director Virgil Moore, Idaho Department of Fish 

and Game; Director Gordon Myers, North Carolina Wildlife Resources Commission; 

and Director Alexandra Sandoval, New Mexico Department of Game and Fish. Their 

written statements detail with great clarity the role of the states in recovering wolf 

populations and the states’ successes in sustainably managing wolf populations to 

the benefit of all of their citizens. 

Gray wolf populations far exceed established federal recovery goals for the Rocky 

Mountain West and the Great Lakes States. The U.S. Fish and Wildlife Service 

(USFWS) has repeatedly attempted to delist the gray wolf in WY, MI, MN, and WI, 

but has been thwarted by ill-advised court decisions. The Association commends and 

supports the USFWS decisions to de-list those wolf populations and the Association 

supports Congressional action to direct such an outcome for those states (in keeping 

with like action by Congress in 2011 for wolves in Montana and Idaho). Indeed, 

Idaho and Montana have demonstrated that once wolf populations are delisted, 

science-based, state-led wolf management can achieve sustainable wolf populations 

where depredation on livestock is reduced, rebalance the predator-prey relationship 

between wolves and large ungulates, provide sustainable recreational opportunities 

for hunting and wolf watching, and diminish public anxiety about the recovery of 

large predators. 

The Mexican wolf is on the periphery of its range in the southwestern United 

States. The majority of Mexican wolf historic habitat is located in Mexico, and the 

species therefore cannot be biologically recovered only in the southwestern United 

States. The states of New Mexico and Arizona, working in cooperation with the 

USFWS, are assisting Mexico in assessing habitat suitability and recovery success 

probabilities of its Mexican wolf population. The Association supports this cooperative state-federal-international collaboration, for an agreed-to population recovery 

goal, so that once achieved, delisting can occur. 

The genetics of the red wolf, currently found only within a nonessential experimental population in North Carolina, substantiate that the ‘‘species’’ is now 

hybridized with coyotes and feral dogs. This hybridization will continue to occur due 

to the high coyote population in the state, and it is not feasible to sustainably prevent further hybridization of free-ranging red wolves across the landscape, further 

diluting red wolf genetics. Coyote populations exist throughout the historic range of 

104 

the red wolf, and any reintroduction of captive-bred red wolves will quickly hybridize with coyotes. This hybridization factor and the diverse generic character of the 

red wolf raises serious questions about whether it is a listable entity under The 

Endangered Species Act (ESA), particularly given the 1983 legal opinion from the 

Department of Interior’s Solicitor’s Office regarding listing of hybrids. The USFWS 

should resolve these questions regarding genetics and hybridization and delist the 

red wolf if hybridization is indeed confirmed. 

Wolf management, like that for any large predator in this country, is complicated, 

challenging, and controversial. We appreciate the role of the USFWS in the discharge of its obligations under the federal ESA, and we acknowledge the concurrent 

management or conservation authority for federally listed species by state fish and 

wildlife agencies. Even though the complexities of wolf recovery and management 

test the limits of collaboration, we know that both federal and state agencies want 

to achieve the best possible conservation outcomes for wolves. That being said, we 

look forward to a robust discussion about future improvements or reform to the 

federal ESA in which the interests, roles, and responsibilities of state fish and wildlife agencies are more clearly recognized. 

Thank you for the opportunity to provide this letter for the hearing record. 

Sincerely, 

NICK WILEY, 

President. 

[LIST OF DOCUMENTS SUBMITTED FOR THE RECORD RETAINED IN THE

COMMITTEE’S OFFICIAL FILES]

—Letter addressed to Chairman Gohmert and Ranking 

Member Dingell with attached documents for the hearing 

record submitted by the Southern Environmental Law 

Center dated October 4, 2016. 

—Memorandum in Support of Preliminary Injunction, ECF No. 

32, Red Wolf Coal. v. U.S. Fish & Wildlife Serv., No. 2:15- 

cv-00042-BO (E.D.N.C. June 20, 2016). Submitted by the 

Southern Environmental Law Center. 

—Reply in Support of Preliminary Injunction, ECF No. 45, Red 

Wolf Coal. v. U.S. Fish & Wildlife Serv., No. 2:15-cv-00042- 

BO (E.D.N.C. July 22, 2016). Submitted by the Southern 

Environmental Law Center. 

—Order, ECF No. 63, Red Wolf Coal. v. U.S. Fish & Wildlife 

Serv., No. 2:15-cv-00042-BO (E.D.N.C. Sept. 28, 2016). 

Submitted by the Southern Environmental Law Center. 

—Heather Clarkson, Defenders of Wildlife, Op-Ed, Poor FWS 

Decision Dooms North Carolina’s Red Wolves, News & 

Observer, Sept. 20, 2016. Submitted by the Southern 

Environmental Law Center. 

—Editorial Board, Save the Red Wolf, News & Observer, Aug. 

31, 2016. Submitted by the Southern Environmental Law 

Center. 

—Editorial Board, Our View: Keep the Red Wolf Alive— 

Somewhere, Somehow, Fayetteville Observer, Oct. 23, 2014. 

Submitted by the Southern Environmental Law Center. 

—Editorial Board, A Federal Judge Acts Wisely to End Killings 

of Red Wolves, News & Observer, May 15, 2014. Submitted 

by the Southern Environmental Law Center. 

105 

—Editorial Board, Protecting Red Wolves: Rebounding Breed 

Should Not Be Collateral Damage, Winston-Salem Journal, 

Feb. 16, 2014. Submitted by the Southern Environmental 

Law Center. 

—Editorial Board, Our View: Endangered Wolves Need a 

Judge’s Intervention, Fayetteville Observer, Feb. 12, 2014. 

Submitted by the Southern Environmental Law Center. 

—Editorial Board, Deadly—Keep Red Wolves Out of Coyote 

Hunters’ Sights, Fayetteville Observer, Nov. 29, 2012. 

Submitted by the Southern Environmental Law Center. 

—Editorial Board, Fix this—Don’t Blind Coyotes in the Red 

Wolf’s Territory, Fayetteville Observer, Oct. 26, 2012. 

Submitted by the Southern Environmental Law Center. 

—Memorandum from Tulchin Research, Polling Finds North 

Carolina Voters Strongly Back Red Wolf Recovery (Aug. 17, 

2016). Submitted by the Southern Environmental Law 

Center. 

—USFWS Document, ECF No. 51, Red Wolf Coalition v. U.S. 

Fish & Wildlife Serv., No. 2:15-cv00042-BO (E.D.N.C. July 

29, 2016). Submitted by the Southern Environmental Law 

Center. 

—Letter from North Carolina Legislators to U.S. Dep’t of 

Interior Sec. Sally Jewell (Aug. 29, 2016). Submitted by the 

Southern Environmental Law Center. 

—Faust, L.J., Simonis, J.S., Harrison, R., Waddell, W., Long, 

S. 2016. Red Wolf (Canis rufus) Population Viability 

Analysis—Report to U.S. Fish and Wildlife Service. Lincoln 

Park Zoo, Chicago. Submitted by the Southern Environmental Law Center. 

—Dr. Michael J. Chamberlain Special Report, ECF No. 70, Red 

Wolf Coal. v. N.C. Wildlife Res. Comm’n, No. 2:13-cv-00060- 

BO (E.D.N.C. Mar. 31, 2014). Submitted by the Southern 

Environmental Law Center. 

—Dr. Michael J. Chamberlain’s Additional Comments for 

Consideration, ECF No. 83, Red Wolf Coal. v. N.C. Wildlife 

Res. Comm’n, No. 2:13-cv-00060-BO (E.D.N.C. May 13, 

2014). Submitted by the Southern Environmental Law 

Center. 

—Dr. Ron Sutherland, ‘‘Study Indicates Wildlife is Thriving in 

Red Wolf Recovery Area.’’ Wildlands Network. Photos of 

wildlife taken from planted cameras. 2016. 

—Letter addressed to Chairman Gohmert and Ranking 

Member Dingell from multiple groups regarding the oversight hearing in support of state management of wolves 

dated September 29, 2016. 

—Letters and emails from constituents of Representative 

Pearce expressing discontent with Federal mismanagement 

of the Mexican Wolf population. Emails dated October 4, 

2016 and October 5, 2016. 

106 

—Emails documenting correspondence between Fish and 

Wildlife officials assessing to determine the killing of a calf 

as either by a wolf or a coyote. Correspondence occurs between May 21, 2016 and May 23, 2016. 

—Report issued to Representative Pearce from the Department 

of the Interior’s Office of the Inspector General regarding the 

Mexican wolf program itself and specific allegations of misconduct by a former Field Coordinator dated June 29, 2016. 

—Letter addressed to Representative Pearce from Director of 

the U.S. Fish and Wildlife Service, Dan Ashe, regarding 

follow-up to the OIG report on the Mexican Wolf program 

dated September 2, 2016. 

—Letters documenting formal correspondence between Mr. Roy 

McBride and the U.S. Fish and Wildlife Service regarding 

inclusion of wolves from the Ghost Ranch lineage into the 

captive breeding program. 

—Woody, Jack B., ‘‘The Mexican Wolf Recovery Program.’’ U.S. 

Fish and Wildlife Service, March 1986. 

—‘‘Mexican Gray Wolves ‘Lack’ Clear Title . . .’’, Citizen’s 

Science.org. 

—Testimony of Mr. Jett Ferebee in response to the oversight 

hearing specifically regarding his dissatisfaction with the 

U.S. Fish and Wildlife Service’s Red Wolf Recovery Program. 

—List of Farms and Areas (and Counties) involved in the Red 

Wolf Recovery Project. 

Æ