DEADLINE IS 11:59 EST DECEMBER 17. 2013
#KEEPWOLVESLISTED
GRAY WOLVES
Delisting Comment link :
#IAMESSENTIAL
MEXICAN GRAY WOLVES
Comment submission form here:
December 17. 2013
428,731
Comments Received*
December 16. 2013
342,474 Comments to USFWS to #keepwolveslisted.
(Granted, some are not pro wolf, but most of them are.)
Right on #Wolves!
We will save our Wolf Buddies.
Thank you.
Heidi
Stop Wolf Hunts Team
"ALL THAT IS NECESSARY FOR THE TRIUMPH OF EVIL
342,474 Comments to USFWS to #keepwolveslisted.
(Granted, some are not pro wolf, but most of them are.)
Right on #Wolves!
We will save our Wolf Buddies.
Thank you.
Heidi
Stop Wolf Hunts Team
"ALL THAT IS NECESSARY FOR THE TRIUMPH OF EVIL
IS FOR GOOD MEN TO DO NOTHING"
Edmund Burke
Irish orator, philosopher, & politician
(1729 - 1797)
Please.
Tell the United States Fish and Wildlife Services that delisting the Gray Wolves from the Endangered Species Act is a mistake.
All folks, not just U.S.A. residents can leave comments, and you can leave more than one.
And:
Tell the United States Fish and Wildlife Services that classifying the Mexican Gray Wolves as "Non Essential" is a mistake.
Read of what is important to say when you submit your comments to the Fish and Wildlife Service here for the Mexican Gray Wolves:
The Proposed Revision to the Nonessential Experimental Population of the Mexican Wolf:
Comment submission form here:
COMMENTS FROM OTHER FOLKS TO #USFWS TO USE + ALTER TO LEAVE ONE OF YOUR OWN
#KEEPWOLVESLISTED PETITIONS NEED TO BE SIGNED BEFORE DECEMBER 17. 2013
MEXICAN GRAY WOLVES
#IAmEssential
10 COMMENT SAMPLES THAT YOU CAN USE. COPY AND PASTE, HOPEFULLY ADD YOUR OWN THOUGHTS
NEW YORK CITY
BAR ASSOCIATION COMMITTEE
OPPOSES NATIONWIDE
GRAY WOLF DELISTING
The Committee on Animal Law of the New York City Bar Association (an independent non-governmental organization of more than 23,000 lawyers, law professors and government officials, predominantly from New York City and also from throughout the United States and fifty other countries) opposed U.S. Fish and Wildlife Service’s nationwide gray wolf delisting proposal in an October 24th letter to USFWS Director Daniel Ashe.
The Committee argues that gray wolves should remain listed as endangered because:
1) It is in danger of extinction throughout all or a significant portion of its range
2) It is over utilized for recreational hunting and trapping in the lower 48 states
3) Its population suffers substantially from both disease and human predation
4) The existing state regulatory mechanisms are inadequate to protect the Gray Wolf from extinction.
The Wolf Conservation Center sends howls of thanks to the Committee on Animal Law for adding its voice of support at this critical time. You can add your voice to this discussion. Please tell USFWS that you #StandForWolves today by submitting your comment via the link below:
• Delisting Comment link
http://www.regulations.gov/#!submitComment;D=FWS-HQ-ES-2013-0073-30560
• Talking points
http://nywolf.org/components/com_wordpress/wp/wp-content/uploads/2013/10/Gray-Wolf-Toplines-and-Commenting-instructions.pdf
Thank you!
Reposted from Wolf Conservation Center
http://nywolf.org/?option=com_wordpress&Itemid=48
#SpeakForWolves Petitions:
ARTICLES ABOUT THE USFWS PROPOSED DELISTING OF GRAY WOLVES FROM THE E.S.A.
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MEXICAN GRAY WOLVES
Only 70 Mexican gray wolves remain in the wild, making them one of the most endangered animals. (Photo: Joel Sartore)
My brother, Mexican wolf M806, was the alpha-male of the Bluestem pack. He thrived in the wild for 6 yrs before he was illegally shot & killed. Today, only 75 Mexican wolves live in the wild & the USFWS designates them as an "experimental, nonessential" population. This designation means that their recovery is trumped by the wishes of industry &/or recreation.
Please tell USFWS that these wolves ARE essential to the recovery of their rare species. Our friends from Mexican gray wolves offer useful talking points here: http://bit.ly/1b7czl9
THANK YOU!
http://www.mexicanwolves.org/index.php/news/1046/51/Take-Action-Comments-Needed-to-Ensure-Mexican-Wolves-Future
Take Action: Comments Needed to Ensure Mexican Wolves' Future!
Proposed USFWS Rule changes regarding reintroduction into the wild of the Mexican Gray Wolf
Recently the U.S. Fish and Wildlife Service (USFWS) proposed changes to the rules guiding the Mexican gray wolf reintroduction.
The proposed rule is very important to the future of Mexican wolves in the wild. Please comment, using the following points:
One very good and many very bad changes are proposed:
The good change is to allow direct releases of Mexican wolves into parts of New Mexico and additional areas in Arizona. This change has been recommended by experts for over 10 years and can be made faster and with less bureaucratic delay than any other part of the proposed rule
TELL USFWS TO PUT THE REST OF THEIR PROPOSED RULE ON HOLD AND SPEED UP APPROVAL FOR MORE DIRECT RELEASES INTO ADDITIONAL AREAS.
The bad changes include:
By labeling all of the wild wolves as “nonessential” the USFWS ignores science and the reality of 15 years of experience with reintroducing wolves
The USFWS claims that even if all of the 75 wolves in the wild are wiped out this is not “likely to appreciably reduce the likelihood” of recovery of Mexican wolves in the wild.
When the current rule declared wolves in the wild “nonessential” there were only 11 wolves, recently released from a captive breeding program and they made up only 7% of all Mexican wolves in the world.
Now the 75 wolves in the wild have up to four generations of experience in establishing packs and raising pups and are over 22% of all of the Mexican wolves in the world.
After four more generations of captive breeding with few releases (only one in the last five years), scientists warn that there may be serious genetic problems making captive wolves less able to thrive in the wild.
TELL USFWS THAT THE FOURTH GENERATION WILD LOBOS ARE NOT EXPENDABLE AND ARE AN ESSENTIAL PART OF RECOVERING THIS UNIQUE SUBSPECIES OF WOLF
The proposed rule puts the cart before the horse and should come with or after – not before – an updated recovery plan
USFWS admits that their present, typewritten, 1982 recovery plan is not scientifically sound and does not meet current legal requirements – yet in its proposed rule USFWS continues to emphasize a woefully inadequate population of only 100 wolves in the wild
When USFWS published the current rule in 1998 they said they expected to put out a new recovery plan for the public to comment on later that year; 15 years later, there still is no scientific or legally adequate recovery plan!
TELL USFWS TO QUIT STALLING AND COMPLETE A COMPREHENSIVE RECOVERY PLAN – AND LET THE PUBLIC SEE IT – BEFORE DOING ANY TINKERING WITH THE CURRENT RULE (except for allowing wolves to be reintroduced into additional suitable places)
USFWS’s decision on the proposed rule can help Mexican wolves finally thrive or can push them closer to extinction. Please submit your comments here and ask others who care about Mexican wolves to do the same.
Thank you!
http://www.mexicanwolves.org/index.php
Contact us at:
info@mexicanwolves.org
http://www.mexicanwolves.org/index.php/news/1046/51/Take-Action-Comments-Needed-to-Ensure-Mexican-Wolves-Future
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WOLVES, THE ENDANGERED SPECIES ACT, AND WHY SCIENTIFIC INTEGRITY MATTERS
Andrew Rosenberg, director, Center for Science & Democracy
August 19, 2013
Shark week has come and gone, and as a marine scientist I feel most at home with these top predators, but it is another, equally charismatic predator species that is in the news. You can guess that because I said “charismatic” I wasn’t referring to Congress.
The possibility that the federal government would remove conservation measures for gray wolves and decide that they are no longer at risk of extinction is in the news not because of some new finding that wolf populations are recovering, but because of apparent political interference in the process of reviewing the science that is the basis for that determination.
HOW THE ENDANGERED SPECIES ACT WORKS
The U.S. Fish and Wildlife Service (FWS) in the Department of Interior is responsible for administering the Endangered Species Act (ESA) for most of the flora and fauna of the U.S. For marine species, the National Marine Fisheries Service (NMFS) in the Department of Commerce has the responsibility. I used to work as a scientist, and then as a lead regulator for the NMFS and have first-hand experience with implementing the ESA.
In a very real sense, the ESA is the protection of last resort for species of unique plants and animals that are determined to be in danger of extinction, in other words, lost forever from our natural heritage. ESA protections that should only come into play when all other conservation and management measures have not been successful at protecting that natural heritage.
Endangered species are often controversial, as you might expect. In every case that I am aware of, endangerment is due to the actions and activities of people. So removing threats to the continued existence of a species means that someone, somewhere will have to change their behavior.
While we might like to think we manage species and natural ecosystems, in reality we manage people and their impacts upon nature. For the marine species I worked with, from salmon to sturgeon to turtles, sea lions, seals, and whales there was incredible controversy on all sides, with some who wanted more protection and others who wanted less or none at all.
A species is “listed” as threatened or endangered under the ESA when a scientific review has determined its continued existence is in jeopardy. The law clearly lays out that science should determine the conservation status of the species — not economic considerations or political positions. These other factors can be taken into account when regulators develop a plan to protect the species.
If we are to protected biodiversity, that is how it should be, a decision based on science, not politics. This is why UCS continues to work with biologists and other scientists with relevant expertise to explain to Congress and the media that for the Endangered Species Act to be most effective, it must be grounded in the best available science.
But unfortunately, wolves are proving to be an exception.
SO WHAT IS HAPPENING WITH THE WOLVES ?
Wolves are among the most controversial of endangered species, and are being considered for de-listing, that is, a conclusion that they are no longer threatened or in danger of extinction and ESA protections are no longer needed. Not only does the law require a full, objective scientific assessment, in such a controversial setting, common sense demands it.
That means the FWS should follow the best process of developing scientific advice. Do the analysis, present the data and conclusions, have it independently peer reviewed by experts in the field. Ensure that all conflicts of interest are disclosed. Make the information public as far as possible while respecting any privacy concerns. And when determining what action to take, be clear about its reasoning, without trying to manipulate the facts to support a pre-conceived position.
While these basic steps in developing the scientific advice were underway, the agency intervened in the process of selecting peer reviewers, excluding some that had already been critical of the scientific basis of the proposed rule on wolves. A significant number of leading experts in the field joined this group to criticize the agency in an open letter. Excluding critics from a peer review when they are highly qualified and respected in the field, and when they raise serious methodological and scientific issues, undermines the very purpose of a peer review. The whole point is to make sure that key methodological, theoretical or empirical errors are caught and addressed so that the agency acts on the best science available. Furthermore, and critical in this case, if the policy-makers manipulate the review process to try to influence the result, the integrity of the advice is lost.
Fortunately, the FWS has backed away from that position. What needs to happen now is to take the time to do a full assessment complete with a comprehensive, independent peer review, adhering strictly to the agency’s science integrity policy. It is vital to include a range of experts in the review and address the scientific issues that they raise. Let’s not endanger scientific advice in the name of trying to declare victory for species recovery. When that happens we should all howl.
Posted in: Science and Democracy, Scientific Integrity Tags: Endangered Species Act, Scientific Integrity
About the author: Andrew Rosenberg is the director of the UCS Center for Science and Democracy. He leads UCS's efforts to advance the essential role that science, evidence-based decision making, and constructive debate play in American policy making. Subscribe to Andrew's posts
http://blog.ucsusa.org/wolves-the-endangered-species-act-and-why-scientific-integrity-matters-212#.UhKEKonzFIw.google_plusone_share
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THE UNSAVORY TRUTH BEHIND THE MOVE TO TAKE WOLVES OFF THE ENDANGERED LIST
The feds have dismissed three scientists from a wolf panel for, guess what, raising concerns about wolf delisting.
August 16, 2013 Tracy Ross
Just weeks after calling for the removal of gray wolves from the Endangered Species List, the U.S. Fish and Wildlife Service is now under fire for allegations that it intentionally excluded three prominent scientists—whose views diverged from the Service’s on delisting—from an upcoming peer review process.
In June, Fish and Wildlife called to delist gray wolves across the Lower 48 states, leaving an exception for the struggling Mexican wolf in the Southwest. Agency director Dan Ashe told the media that the gray wolf had recovered to the point that it could thrive and even enlarge its territory without federal oversight. Several wolf advocates and some members of Congress disagreed. Once wolves are delisted, their management will fall to individual states.
But in order for the delisting process to continue, federal law requires that a team of scientists evaluate the basis for the motion. As such, Fish and Wildlife hired a private contractor to select and oversee the peer review panel. According to Fish and Wildlife spokesman Gavin Shire, the agency isn’t supposed to know who the panelists are. But the Associated Press revealed that the contractor chosen to assemble the panel had provided a list of candidates that redacted their names but included their professional resumes. Armed with this information, the Service found three esteemed wolf biologists, who—and this is the key part—had expressed concern with the gray wolf delisting plan. They also, along with 16 other prominent scientists, had signed a letter expressing this concern. Shortly thereafter, Fish and Wildlife effectively “delisted” the three scientists from the panel.
The three are identified as Dr. John Vucetich, Dr. Robert Wayne, and Dr. Roland Kays. All have published extensively on the wolf and are considered preeminent experts. Yet the Center for Biological Diversity’s Bret Hartl reports that the Service rescinded their invitations because, in the agency’s words, they have an “unacceptable affiliation with an advocacy position.”
Op-Ed: What We Learned From Living With Wolves for 6 Years
Vucetich and Wayne told the AP that they had received emails from the contractor saying they were being excluded from the review team because they had signed the letter. Kays said he had been “solicited as a possible panelist” but later told he wouldn't be needed.
Vucetich, a biologist and wolf specialist, told the AP it was “absolutely wrong” to disqualify an expert from a peer review team because of previous statements about a proposed policy. Any competent scientist will approach such an assignment with an open mind and be willing to alter his or her opinion if new information justifies it, he said.
According to the AP, Shire declined comment on the dealings with the three scientists, saying the matter was under review. But he said the Fish and Wildlife Service “wanted to be particularly sure that the people we got for this process were objective and unbiased” because the wolf is such a “highly polarizing subject.”
Brett Hartl, however, says that “peer review of the whole delisting question is complicated because the Service has injected so many improper policy considerations into this delisting proposal.” As Dan Ashe, Fish and Wildlife Service director, told the AP, “Science is an important part of this decision, but really the key is the policy question of when is a species recovered. Does the wolf have to occupy all the habitat that is available to it in order for it to be recovered? Our answer to that question is no.”
Yet under Section 4 of the Endangered Species Act, the decision to delist a species is required to be based on the best available science. “Had the Service followed this mandate, the best course of action would have been to develop a nationwide recovery plan for wolves using the best available science,” Hartl said. “Instead, the Service basically asked the States whether they wanted wolves or not and based its decision to delist the wolf on these political considerations.“
According to the AP, the contract with the outside firm has been put on hold and the peer review procedure will start anew. It's unclear whether the delay will affect the timetable for making a final decision on removing wolf protections, which is expected by June 2014.
But Hartl says that by injecting itself so deeply into the peer reviewer selection process, the entire peer review of the wolf delisting is likely to be tainted. “If the Service continues to oversee the review, then no matter how it comes out, one side or the other will be suspicious about whether the peer reviewers were objective.” Hartl recommends that the Service take a different course and have a scientific society, such as the American Society of Mammalogists or the Society for Conservation Biology, take over the peer review process and conduct it without Service involvement.
http://www.takepart.com/article/2013/08/16/wolves-endangered-species-list-delist-panel-scientists?cmpid=organic-share-googleplus
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