To: U.S. Secretary of the Interior, Sally Jewell. (https://www.doi.gov/feedback)
From: Scott Slocum. (www.SS-Slocum.info)
Cc: Director of the USFWS, Dan Ashe. (email@example.com)
Re: In support of ESA protections for the Gray Wolf.
Thank you for the opportunity to comment on this controversy, as it comes to the attention of the legislative, judicial, and executive branches of the U.S. government.
I'm writing in opposition to the 11/19/2015 letter from Mech et al. to the U.S. Secretary of the Interior concerning the delisting of the Gray Wolf in the western Great Lakes States (Mech et al. 2015). I'll address three of that letter's shortcomings below.
Misstatement #1: "efforts... to delist or down-list gray wolves in the western Great Lakes states have been foiled or reversed by litigation typically based on legal technicalities rather than biology."
Misstatement #2: if a species is not delisted once it meets its recovery goals, it "creates public resentments toward the species and the ESA."
Misstatement #3: the authors list their credentials as a way of making up for their lack of work on the letter itself.
As I've written before, I see potential in the framework of federal delisting followed by State management. On the other hand, I see failings in that framework. I'd like to think that the solution would be to fix it; but until it's fixed, it would seem that the only way to continue the necessary and appropriate protections for the Gray Wolf in the U.S. (particularly in the western Great Lakes States) will be to continue its listing as endangered or threatened under the ESA.
Discussions are needed, but given the bills (and budget-bill riders) that have been surfacing in Congress with the intent to silence those discussions (and proceed directly to the failed framework of federal delisting followed by State management), they're not taking place. I hope you'll oppose the efforts to silence those discussions, and instead facilitate them and bring them to a scientifically-, legally-, and socially-acceptable resolution.
Howell, Beryll A. 2014. Federal Protections Restored for Great Lakes Wolves. U.S. District Court. December 19. MPR News article: http://www.mprnews.org/story/2014/12/19/wolves
Mech, L. David, Steven H. Fritts, Adrian P. Wydeven, Tom Heberlein, Ed Bangs, Scott Craven, Lu Carbyn, and Tim Van Deelen. 2015. “Scientists to Feds: Great Lakes Wolves Not Endangered,” November 19. Detroit Free Press article: http://www.freep.com/story/news/local/michigan/2015/11/18/scientists-great-lakes-wolves-endangered/76015486/
Treves, Adrian, John Vucetich, Jeremy T. Bruskotter, Bradley Bergstrom, William Lynn, Michael Paul Nelson, Robert Crabtree, and Paul Paquet. 2015. “Scientists to Feds: Great Lakes Wolves Should Remain Protected,” November 23. http://faculty.nelson.wisc.edu/treves/reports/Wolf_conservation_open_letter.pdf
Vucetich, John, Rolf Peterson, Adrian Treves, Lisa Naughton, Michael Paul Nelson, William J. Ripple, Daniel D. Roby, et al. 2015. “An Open Letter to Members of Congress from Scientists on Federal Wolf Delisting.” February 18. HSUS blog: http://blog.humanesociety.org/wayne/2015/02/scientists-letter-wolves-congress.html