There was a time when wolves lived in every part of North America. Today, they are a mere shadow of their former numbers, found in less than 10% of their historic range. Despite this, the U.S. Fish and Wildlife Service (the Service) recently proposed to remove the gray wolf from the list of threatened and endangered species. This premature and misguided proposal comes at a time when gray wolf recovery is incomplete and fails to incorporate sound science, bioethics, and public opinion.

On the Prowl - courtesy

On the Prowl – courtesy

The Endangered Species Act (ESA) requires that listed species are recovered such that they no longer meet the definitions of “threatened” or “endangered” and are no longer in danger of extinction now or in the foreseeable future. This is clearly not the case. The original intent of the ESA to recover endangered species and the ecosystems upon which they depend is not reflected in the decision to delist gray wolves when only a fraction of suitable habitat is occupied by wolves throughout the United States. Despite significant gains for wolves under ESA protection, from the reintroduction of wolves to Yellowstone and throughout the Northern Rockies to the recovery of populations in the western Great Lakes states, wolf recovery is far from over. Scientists caution that wolves need connected populations for genetic sustainability. Delisting could prevent the return of wolves to California, Colorado and Utah where scientists have determined there is excellent suitable habitat.

Wildlife policy decisions should be based on the best available, peer-reviewed science in order to ensure decisions are based on scientifically sound data, assumptions, and analyses. The Service has based its decision on a biologically inadequate recovery standard. Scientific evidence does not support the claim that federal protection for wolves is no longer necessary, but rather that they’ve just begun to recover as they face increased killing in Idaho, Montana, and Wyoming.

In a letter written to Secretary of the Interior Sally Jewell in May 2013, a collective of esteemed scientists, including Dr. Bradley Bergstrom, Project Coyote Science Advisory Board member, expressed their serious concerns with the delisting proposal. The scientists, many of whom were responsible for the research referenced in the proposal, cautioned the decision makers:

A Good Shake - courtesy

A Good Shake – courtesy

“The gray wolf has barely begun to recover or is absent from significant portions of its former range where substantial suitable habitat remains. The Service’s draft rule fails to consider science identifying extensive suitable habitat in the Pacific Northwest, California, the southern Rocky Mountains and the Northeast. It also fails to consider the importance of these areas to the long-term survival and recovery of wolves, or the importance of wolves to the ecosystems of these regions.”

In a new study published in the journal Conservation Biology (Carroll 2013) researchers have found recovery of gray wolves in the western US may depend on wolves being able to successfully disperse between widely separated populations. According to Dr. Carlos Carroll of the Klamath Center for Conservation Research, “This study is the first time that scientists have taken a detailed look at what biology suggests is needed for long-term wolf recovery. Our findings imply that we can’t restore formerly widely-distributed species like the wolf to isolated populations in a few parks and expect them to remain genetically healthy.”

In an analysis of wolf DNA, UCLA ecologist and evolutionary biologist Robert Wayne found mitochondrial DNA from pre-extermination wolves had twice the genetic diversity compared to DNA from wolves today (Woolston 2013). According to Wayne, wolves need broad ranges and large populations to return to the healthy levels of genetic diversity found historically. These findings have direct implications for the current proposal to remove federal protection for wolves, effectively challenging the proposal.

The benefits of wolves on complex ecological systems have been documented in numerous studies. As a keystone species, the wolf’s presence is critical to maintaining the structure and integrity of healthy and balanced native ecosystems. In Yellowstone National Park, landscape health is being restored, as documented in multiple studies. Furthermore, a growing body of scientific literature supports the claim that top predators like wolves play critical roles in maintaining a diversity of wildlife species, benefitting songbirds, fish, and beavers, only to name a few.

Northern Lights Howl - Courtesy

Northern Lights Howl – Courtesy

The Service has expressed its confidence in the ability of state wildlife agencies to successfully manage wolf populations, yet state conservation and management plans have proven detrimental in maintaining wolf recovery efforts. Under the management of state wildlife officials, wolf numbers have declined significantly. The wolf population in the original three-state recovery area is now at its smallest size in five years. The aggressive management of wolves that commenced in Wyoming, Montana, and Idaho following the loss of federal protection, highlights the hostile anti-wolf policies of states charged with wolf management and protection.

According to the American Society of Mammalogists, a professional, scientific, and educational Society, “34% of the absolute minimum Northern Rocky Mountain Distinct Population Segment estimated wolf population was removed due to human-causes” (USFWS 2013) in 2012, potentially threatening the long-term viability of the population. Project Coyote Science Advisory Board member and Minnesota resident Dr. Michael W. Fox states, “the plight of one of the largest populations being exploited in Minnesota is illustrative of the fate of this species when not given publicly endorsed protection by the federal government” (Fox 2013). Looking into the future of state-sanctioned wolf management, Utah’s legislature has already tried to make Utah a “wolf-free” state if federal protections are removed.

History teaches us safeguards for wolves must be maintained in a country that remains hostile toward this vital keystone predator. As we know, gray wolves were extirpated from most of the Lower 48 states by the middle of the 20th century, requiring the reintroduction of wolves from Canada into Yellowstone National Park and central Idaho. The Service has given inadequate consideration to the continued threats posed by illegal poaching of wolves and excessive state-sanctioned killing.

DC Rally For Wolves 9.7.13 - Michele Chandler photo

DC Rally For Wolves 9.7.13 – Michele Chandler photo

The greatest threats to wolf recovery and expansion are human-caused mortality, including trophy hunting, commercial/recreational trapping and killing by the federal government at the behest of ranchers. Despite programs that help farmers and ranchers coexist with wolves, a war continues to be waged against them. And despite the hostility toward wolves from some stakeholders, opinion polls show the vast majority of Americans favor maintaining the protection of wolves under the ESA.

As history and science demonstrate, it is critical the Service maintain the wolf’s endangered species status to ensure the full recovery of this vital keystone predator throughout their historic range. With the premature delisting of wolves, a dangerous precedent could be set that disregards science, ethics and public opinion and which could ultimately impact recovery efforts for other endangered species.

The public comment period remains open until October 28th. Comments may be submitted to the Service at


Carroll, C. 2013. New study forecasts risks to wolves in western US unless dispersal can connect isolated populations. Available from: (accessed September 20, 2013)

Carroll, C., Fredrickson, R. J. and Lacy, R. C. (2013), Developing Metapopulation Connectivity Criteria from Genetic and Habitat Data to Recover the Endangered Mexican Wolf. Conservation Biology. doi: 10.1111/cobi.12156

Fox, M.W. 2013. Why the federal & state governments should protect the gray wolf from hunters & trappers. Available from: (accessed September 30, 2013)

United States Fish and Wildlife Service, USFWS. 2013. Gray wolves in the northern Rocky Mountains. Available from: (accessed May 17, 2013)

Woolston, C. 2013. Grey Wolves Left Out in the Cold. Nature (September 11, 2013) Available from: (accessed October 4, 2013)

(The article above was written by Karina Jelincich Grasso and originally published by Project Coyote)

Project Coyote is a national non-profit organization based in Marin County, California promoting compassionate conservation and coexistence between people and wildlife through education, science, and advocacy. For more information visit: