December 1, 2022

Letter to House Subcommittee on Natural Resources: RE: Wolf Management

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September 29, 2016
The Honorable Louie Gohmert, Chairman
House Natural Resources Subcommittee on Oversight and Investigations
1324 Longworth House Office Building
Washington, DC 20515
The Honorable Debbie Dingell, Ranking Democrat
House Natural Resources Subcommittee on Oversight and Investigations
1324 Longworth House Office Building
Washington, DC 20515
Dear Chairman Gohmert and Congresswoman Dingell:
We write today to submit this letter for the record of the Subcommittee hearing of September 21, 2016, on “Federal Government Management of Wolves”. Our organizations represent millions of wildlife and hunter conservationists, wildlife scientists, and wildlife enthusiasts who strongly support management of wolves by the State fish and wildlife agencies.
Wolf populations in the northern Rocky Mountains and Great Lake States have far exceeded recovery objectives established by the US Fish and Wildlife Service (FWS) in cooperation with the states, under the Endangered Species Act (ESA). It is now time – and the FWS attempted – to return management of these populations to the exclusive authority of the states.
We support the FWS decisions to de-list the Rocky Mountain and Great Lake States wolf populations and we support Congressional action that directs the FWS to reinstate these decisions. Congress did so in 2011 for wolves in Montana and Idaho. It is time for Congress to do so again for Wyoming and the Great Lake States’ wolf populations.
Other wolf populations in the lower 48 states are establishing themselves outside the official administrative boundaries of the recovered wolf populations. Still other wolf populations – the Mexican wolf and red wolf – are still officially in the recovery process under ESA.
We urge the FWS – and not Congress – to reconsider its policy toward other wolves in the remaining lower 48 states so that future expansion and care for wolf populations of any species or subspecies be the responsibility of the states. We recognize that the outdated provisions of the ESA and the more recent FWS policies on defining populations will make such a re-consideration difficult, which is one of many reasons to update and modernize the ESA.
Congress can best assist nationwide wolf policy by working with the FWS and state fish and wildlife agencies to update and modernize the ESA, by reinstating FWS wolf decisions overturned by the courts, and by not superseding FWS on other wolf matters. The State fish and wildlife agencies have demonstrated great success in managing gray wolves in the Rocky Mountain West and Great Lake States populations, all of which far exceed recovery goals. Uninformed litigation, however, continues to impede the delisting of many of those populations by the FWS. 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. It is far past time for wolf populations in Wyoming, Michigan, Minnesota, and Wisconsin to be delisted and assumed back under exclusive state management jurisdiction.
The Mexican wolf is on the periphery of its range in the southwestern United States. The majority of Mexican wolves are in Mexico, and the species cannot be biologically recovered only in the southwestern United States. The states of New Mexico and Arizona, working in cooperation with the FWS, are assisting Mexico in assessing habitat suitability and restoration success probabilities of its Mexican wolf population.

Once a population goal agreed-to by the states of New Mexico and Arizona and the FWS is achieved, the United States population must be delisted and exclusive authority returned to the states for managing this species in the US, and through working with the government of Mexico to restore the core population.
The genetics of the red wolf, currently found only in North Carolina, substantiate that the “species” is now hybridized with coyotes and feral dogs, and thus no longer satisfies the definition of “species”. This hybridization is unavoidable due to the high coyote population in the state and the inability to prevent hybridization of free-ranging red wolves across the landscape, further diluting red wolf genetics. The red wolf, because of its now diverse genetic character, must be delisted and returned to exclusive state authority to manage, thus addressing depredation problems, and improving human social tolerance of a large predator.
Our system of fish and wildlife conservation in the United States is the envy of the rest of the world. Based on the North American Model of Wildlife Conservation, the states are key and integral in delivering science-based on the ground conservation of fish and wildlife, which are managed as a public trust resource for our citizens and the benefit of future generations. The states’ have demonstrated their ability to sustainably manage wolves and the predator-prey relationships on which they depend to meet the needs of all of their citizens. If the FWS is unable to delist all US populations because of uninformed litigation, then Congress needs to remedy this and return the management of wolves exclusively to state fish and wildlife agency jurisdiction.
Thank you for the opportunity to provide this letter for the hearing record.
Archery Trade Association
Association of Fish and Wildlife Agencies
Boone and Crockett Club
Catch a Dream Foundation
Congressional Sportsmen’s Foundation
Council to Advance Hunting and the Shooting Sports
Dallas Safari Club
Delta Waterfowl
Houston Safari Club
Masters of Foxhounds Association
Mule Deer Foundation
National Rifle Association
National Shooting Sports Foundation
National Trappers’ Association
National Wild Turkey Federation
Orion the Hunters’ Institute
Pheasants Forever
Professional Outfitters and Guides Association
Quail Forever
Quality Deer Management Association
Rocky Mountain Elk Foundation
Ruffed Grouse Society
Safari Club International
Shikar Safari Club
Sportsmen’s Alliance
Tread Lightly
Wild Sheep Foundation
Wildlife Forever
Whitetails Unlimited