Mech et al. vs. ESA protections for the Gray Wolf

Post date: Nov 25, 2015 6:22:24 PM


To: U.S. Secretary of the Interior, Sally Jewell. (

From: Scott Slocum. (

Cc: Director of the USFWS, Dan Ashe. (

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."

One of the many facts that's ignored here is that Judge Howell's 2014 federal court opinion (Howell 2014) was based in part on the critical biological point (in its discussion section, C4) that the Minnesota Wolf Management Plan for Zone A and Zone B effectively established "an unregulated killing zone for wolves" in Zone B (a killing zone of the type that was successfully challenged in Wyoming). The extent of this problem with the Plan and its implementation in Zone B made it unnecessary for the court to address other problems with the Plan and its implementation in Zone A.

Misstatement #2: if a species is not delisted once it meets its recovery goals, it "creates public resentments toward the species and the ESA."

As if those "resentments" weren't there from the beginning. I know that in Minnesota, they were there from the beginning.

Granted, the signers of Mech et al. have certainly had many, many personal communications upon which they could base a statement like this. At least, they could have made it more supportable: something like "there is a great deal of resentment, in certain segments of public opinion, that the Gray Wolf remains listed under the ESA in the Western Great Lakes States." Indeed, with a more-supportable statement, they might have gotten away without having any scientific survey results at all (which, of course, they don't have).

This ends up to be only another unsupportable element of a short letter with little in the way of support.

Misstatement #3: the authors list their credentials as a way of making up for their lack of work on the letter itself.

By far, the most substantial part of this letter seems to be the listing of the credentials of its signers. This seems to be an attempt to "pull rank" on the presumably younger and arguably more accountable and responsible scientists who wrote open letters on the subject to the people and the U.S. Congress on 2/18/2015 (Vucetich et al. 2015) and 11/23/2015 (Treves et al. 2015) in support of continued protection for the Gray Wolf under the ESA.

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.


Scott Slocum


Howell, Beryll A. 2014. Federal Protections Restored for Great Lakes Wolves. U.S. District Court. December 19. MPR News article:

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:

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.

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: