Gray Wolf Emergency Relisting PDF
Gray Wolf Emergency Relisting PDF
We write to ask that you immediately issue an emergency listing to temporarily restore federal
protections through the Endangered Species Act (ESA) to the gray wolf.
The gray wolf is a keystone species whose native range spans much of North America. Once
extirpated from the lower 48 states, when the gray wolf was reintroduced to the Yellowstone area
it caused a trophic cascade of regeneration throughout that ecosystem, demonstrating the
fundamental importance of the species for critical ecosystem services that support human health
and the economy.i As we tackle the existential threat of climate change, the gray wolf can help to
mitigate climate effects on the ground, and to improve the climate resilience of communities in
its range.ii At the same time, gray wolves undoubtedly face new challenges as a result of climate
change, further straining the specie’s ability to survive.iii
While we appreciate the Fish and Wildlife Service’s (FWS) decision to conduct a 12-month
status review to revisit the listing of the gray wolf in the Northern Rockies, we are extremely
concerned that wolves around the country will continue to be needlessly killed in the interim,
further jeopardizing the species. We have already seen evidence of mass killings in several states
after the gray wolf was delisted, and more, larger hunts are planned as of now.iv Such actions
warrant an emergency listing to protect the species from dangerous reductions in population size
that could lead to extinction. Additionally, the FWS delisting rule for the gray wolf in the
Northern Rockies states that meaningful changes in state law or management objectives that
increase the threat to the wolf population can lead to not only the reconsideration of listing but an
emergency relisting at any point.
An emergency listing for gray wolves is also necessary given FWS’s own response to petitions
that there is substantial credible information that human-caused slaughter poses a threat to the
species. FWS found that regulations in at least two states may be inadequate to address human
threats posed to gray wolves.v Further, more than 800 scientists have called on the Biden
Administration to take immediate action crediting laws in various states that threaten gray
wolves and ignore science. They state the laws in several states go against scientific literature on
wolf biology management and could threaten recovery efforts.vi Additionally, tribal leaders and
representatives have also voiced their concerns regarding the danger facing gray wolves as they
are sacred to many American Indian Tribes. They write that the decision to delist gray wolves
without their consultation has eroded tribal sovereignty, and not only do they request an
emergency relisting for gray wolves, but to also be included in decisions that affect their cultures
and traditions.vii
Any emergency listing is temporary, lasting only 240 days. During that time, FWS will be able
to continue its own evaluation and review that is already underway. We believe the facts on the
ground support such a request and ask that you implement an emergency relisting of gray
wolves.
We appreciate the work of the Administration thus far and look forward to the consideration of
our request. We request a response back by Wednesday, December 22nd.
Sincerely,