Review of Proposed Rule Regarding Status of the Wolf Under the Endangered Species Act

This paper by the National Center for Ecological Analysis and Synthesis (NCEAS) is an independent scientific review of the US Fish and Wildlife Service’s (USFWS) proposed rule regarding the status of gray wolves in the lower 48 states. In it, a group of experts give their opinions on four key questions: 1) Did the service consider the best available scientific information, including the scientific literature, in developing this proposal? 2) Are the assumptions, analyses, and conclusions reflected in the proposed rule reasonable in light of the best information available? 3) Does the proposed rule draw reasonable and scientifically sound conclusions from Chambers et al., 2012? And 4) Does the proposed rule utilize the best available scientific information and draw reasonable and scientifically sound conclusions concerning the status of wolves? Their conclusions are presented individually, as well as through a full in-person discussion included in the paper.

This publication looks at the current USFWS rule regarding the status of gray wolves in the lower 48 states, and brings together a range of experts to assess the merits of the rule and propose changes where needed. The experts were brought together by NCEAS to give both individual opinions and to discuss the issue together as a group. Special attention was paid to the impartiality of the group, and NCEAS took numerous steps to create an environment of impartiality, including allowing the experts to submit individual statements before holding a group discussion, and making sure that panelists only had a single point of contact to the USFWS.

The experts used four guiding questions to assess the merits of the USFWS policy, with particular focus on whether the current rule (largely informed by research from Chambers, et al., 2012) used the best available science and drew reasonable conclusions based on their sources. The rule essentially looks to remove the gray wolf from the List of Threatened and Endangered Wildlife but to maintain endangered status for the Mexican wolf by listing it as a subspecies. Across the panel there were concerns that the rule relied too heavily on Chambers, and that the evidence that has led to the USFWS rule is still evolving and needs to be followed more closely before making conclusive determinations.

Though the point of the discussion was not to reach consensus, there was an overall sentiment that seemed to be shared by the panel that the USFWS should continue to evaluate the evidence and not rely on Chambers as their primary source. During discussion the panel also came to an agreement that the issue is scientifically controversial, and that any further policy discussions on the subject need to recognize that the evidence is fluid and not fixed.

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