Letter to Hon. Deb Haaland, Secretary Department of the Interior - Protecting Grey Wolves

Letter

Dear Secretary Haaland:

We are writing to urge the Department of the Interior to issue an emergency listing to restore
temporary federal Endangered Species Act (ESA) protections to the gray wolf in the western
United States.

On September 15, in response to two petitions to list the gray wolf in the western United States,
the U.S. Fish & Wildlife Service (the Service) announced a substantial 90-day finding, initiating
a status review of the gray wolf in the western United States. We applaud this announcement and
believe it is the right decision. However, we are deeply concerned that this decision, which
initiates a comprehensive review, followed by a 12-month finding on whether listing is
warranted or not, and only then potentially begins the formal relisting process, does nothing to
protect gray wolves in the interim at a time when their survival is threatened by harmful policies
that have already been enacted in several states.

Many of us wrote to your predecessor, Secretary Bernhardt, to urge against wolf delisting in July
2019. In that letter, we argued that returning wolves wholly to state management could stall or
even reverse the progress that had been made toward their recovery. Unfortunately, our concerns
were justified. After federal protections were formally removed by the Trump administration in
early 2021, several states immediately moved to establish harmful wolf management policies. In
the Northern Rockies region, where wolves were congressionally delisted in 2011, Idaho passed
a new statewide law allowing up to 90 percent of the state's existing wolf population to be killed.
In Montana, the state government has sanctioned killing up to 85 percent of its wolf population
beginning in fall 2021. These laws are already having devastating impacts on wolves and on
federally-protected ecosystems -- three Yellowstone National Park wolves were killed in just the
first week of Montana's hunting season. Further, both Montana and Idaho have authorized the
use of inhumane practices like chokehold snares with the potential to kill entire packs.

If continued unabated for this hunting season, these extreme wolf eradication policies will result
in the death of hundreds of gray wolves and will further harm federally protected ecosystems like
Yellowstone. The Department of the Interior can prevent these senseless killings, and we urge you to immediately establish emergency interim protections while the Service completes its status review.

As you know, wolves are an integral component of North American ecosystems. More than 600
scientists have written to request emergency relisting of the Northern Rockies wolf population,
precisely because wolves' role in maintaining healthy ecosystems is being jeopardized by the
policies now being implemented by Idaho, Montana, and Wyoming. As the scientists note,
"Without the presence of key species in numbers, we are merely conserving scenery and not
functioning ecosystems."

Furthermore, wolves hold spiritual and cultural significance to many Native American tribes
throughout the United States. The wolf treaty, signed by more than 120 tribes and tribal
organizations, illustrates how important wolves are in tribal culture. Unfortunately, the Trump
administration did not engage in any meaningful tribal consultation ahead of the delisting
decision, despite the fact that tribal consultation is critical to the federal government's trust
responsibility and is necessary in a true government-to-government relationship. To this end,
leaders representing hundreds of Tribal Nations, including every Tribe in Canada, wrote to you
on three occasions last month urging an emergency listing decision and requesting consultation
on future relisting and delisting measures, as required by law.

Given the above, we urge you to immediately issue an emergency listing to establish temporary
federal protections for gray wolves. An emergency listing, which extends for 240 days, will
prevent more wolves from being killed before the Service makes a determination about whether
relisting is warranted. Furthermore, as part of its status review, we respectfully request that the
Service both engage in meaningful tribal consultation and consider the impacts of state-level
policies like those in Idaho and Montana as they reevaluate the gray wolf's status.