Policy Memo: Gray Wolf Conservation in the Lower-48 States

MEMORANDUM

To: Secretary of the Interior Sally Jewell

From: Adrienne Mathis—Davidson College, United States

Date: April 2015

Subject: Conservation of Gray Wolves in the Lower-48 States

Gray wolf populations must be protected throughout the contiguous United States.

Wolves are a keystone species that maintain the health and balance of their ecosystem.[1] All gray wolves (Canis lupus) in the lower-48 states have been protected under the Endangered Species Act (ESA) since 1978, but in June 2013 the U.S. Fish and Wildlife Service (USFWS) proposed to delist all gray wolves within the lower-48 states from the ESA.[2] Delisting strips federal conservation and recovery plans entitled to species under the ESA[3] and leaves species management to state governments.[4] Once delisted, two factors most threaten gray wolf survival: humans’ use of lethal methods to protect livestock[5] and excessive trophy hunting or commercial trapping.[6] The USFWS has already delisted wolf populations in the Northern Rocky Mountain [7] and Great Lakes regions.[8] This trend suggests a ruling to delist all Canis lupus within the contiguous United States is likely. Therefore, I have proposed three strategies to prevent gray wolves from being relisted under the ESA assuming they are delisted. In this memo I analyze each strategy using a weighted decision analysis to determine the most effective option. I have found the most feasible and beneficial option is incentivized educational workshops for livestock owners.

Five Strategies for Gray Wolf Conservation in the Lower-48 states

1. No change: This strategy assumes gray wolves have been delisted from the ESA. State management plans will be monitored and approved by the USFWS control population recovery and conservation.[9]
2. Collaborate with USDA’s Wildlife Services: This option would establish a relationship between the U.S. Fish and Wildlife Service and the Wildlife Services branch of the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service to ensure Wildlife Services uses non-lethal methods to deter and manage gray wolves that lurk near human and livestock dwellings. Wildlife Services will have permission to kill a gray wolf only if it is caught in the act of predation.
3. Request that President Obama Propose a Gray Wolf Protection Act (GWPA): Based on the Bald and Golden Eagle Protection Act established in 1940[10], the Gray Wolf Protection Act would prohibit all trophy hunting and commercial trapping of wolves within the contiguous U.S without a permit issued by the Secretary of the Interior.
4. Develop an Education and Incentives Program (EI): This option would establish annual educational workshops for livestock owners to learn the importance of gray wolves within the regional ecosystem and the latest technology in non-lethal methods to protect livestock.[11] Participating members who use non-lethal methods taught in workshops to deter wolves from livestock would be offered greater financial depredation compensation.

Five Criteria for Decision Analysis

I have used the decision analysis tool to determine overall effectiveness of each strategy using five criteria: political feasibility, administrative and technological feasibility, social costs and benefits, environmental costs and benefits, and economic costs and benefits.

Political Feasibility

Delisting gray wolves is highly feasible because it has already been proposed and passed two regions.[12] Although both regions have faced numerous judicial appeals due to suspicions of a premature delisting, [13] the decision to delist remains.[14] Collaborating with Wildlife Services is also politically feasible because USFWS would be working within the United States government, and this collaboration has been executed in the past to preserve bald eagle populations.[15] Suggesting President Obama draft and pass a Gray Wolf Protection Act is moderately feasible because it would take time and effort to pass, especially because many people in Congress are from states that have created species management plans and financially benefit from auctioning wolf permits.[16] Yet the Bald and Golden Eagle Protection Act[17] demonstrates this is not a novel law.[18] Additionally, the Federal District Court has already banned trophy hunting and commercial trapping in the Great Lakes region, suggesting a broader plan would also be politically feasible.[19] Providing education and incentives is highly politically feasible because it would not require legislative action or collaboration.

Administrative and Technological Feasibility

If delisted, although state management plans from all 48-states may not be submitted in a timely manner,[20] delegating control to state governments is highly feasible. Collaboration is moderately feasible because the agencies have previously worked together to conserve migratory birds,[21] but switching to non-lethal methods will require more research and technology and could result in inter-agency disputes. GWPA would have low administrative feasibility because it is difficult to enforce a law in 48 states and may increase illegal hunting. Also, tensions between state and federal governments may develop because states typically support permit hunting.[22] EI would be very feasible because it would not require many resources even if it were difficult to attract farmers to workshops and determine correct depredation compensation.[23]

Social Costs and Benefits

Delisting gray wolves could have high social costs because it might result in citizen backlash because over 100 million Americans have openly opposed delisting the emblematic species.[24] Collaboration may evoke an initial uproar from livestock owners, but is very beneficial because inter-agency efforts could lead to better national communication regarding the management of other endangered species. It could also teach livestock owners the efficacy of non-lethal methods. The GWPA would have more social benefits than costs because it would gain the support of the 100 million Americans petitioning delisting.[25] EI has equal costs and benefits because it would educate community members, but they may resist.

Environmental Costs and Benefits

Delisting wolves is very environmentally costly because USFWS claims the wolves have reached adequate recovery populations,[26] but many scientific reports claim wolves still need federal protection.[27] State governments also aim to meet the needs of the people before animals, resulting in looser hunting and trapping restrictions.[28] Collaboration has equal costs and benefits because it would save wolves from predation and provide both agencies with an opportunity to create innovative technology in non-lethal wolf management, which would help the ecosystem, but it would not prevent wolf hunting.[29] GWPA is very beneficial because it would ensure wolf populations are not depleted due to incidents such as the 2013 hunting season in the Rocky Mountain region where approximately thirty percent of the regional population was killed under state supervision.[30] Yet rising wolf populations require monitoring of prey species to ensure a balanced ecosystem.[31] EI would be moderately beneficial because it would decrease wolf killing among livestock owners and provide environmental education, which may decrease hunting.

Economic Costs and Benefits

ESA is very expensive to enforce. In 2012, the U.S. federal and state governments spent $1.7 billion to conserve species listed on the ESA.[32] While delisting does not eliminate costs,[33] it would delegate species management to state governments and decrease USFWS expenditures, leaving more money for the recovery of other endangered species. Collaboration may be expensive because Wildlife Services would need to purchase non-lethal technology. GWPA would be costly because it would require extensive resources to enforce and will cost states revenue they would have earned from auctioning permits because only the Secretary of the Interior will have the power to grant permits.[34] Yet fining violators could make up for some of these costs. EI workshops would not be expensive, but providing depredation compensation for participations could be costly because the USFWS would pay for all instances of predation.

Recommendation: Education and Incentives is the Most Feasible and Beneficial Option

Education and incentives has the highest weighted option score. It is moderately socially, economically and environmentally beneficial and has very high political, administrative, and technological feasibility, which are crucial in the implementation of a conservation strategy. Education will not stop gray wolf hunting in the lower-48 states, but it will decrease the number of wolves killed by livestock owners and teach community members the importance of wolves in their ecosystems. Note that collaboration with Wildlife Services has a similar option score, so perhaps both strategies should be used to prevent wolf populations from being relisted under the Endangered Species Act.

I have used the decision analysis tool for each strategy to determine overall effectiveness using five criteria: (1) political feasibility, (2) administrative and technological feasibility, (3) social costs and benefits, (4) environmental costs and benefits, and (5) economic costs and benefits. In the table, I have assigned weighted values to each criterion based on its significance in the decision-making process. To analyze the strategies in a realistic manner, I have assigned greater weight to political and administrative and technological feasibility and environmental costs and benefits because these are typically the most immediate concerns associated with the efficacy of national policies. I rate each option using a 1-3 scale: 1 represents low feasibility and high costs, 2 represents moderate feasibility and equal costs and benefits, and 3 represents high feasibility with high benefits. The weighted option score is the average of all criteria after being weighted within the decision-making process and the overall feasibility and effectiveness of each strategy.

[1] Alderman, J. Crying Wolf: The Unlawful Delisting of Northern Rocky Mountain Gray Wolves from Endangered Species Act Protections. Boston College Law Review. 50, 1195-1241 (2009)

[2] Department of the Interior, Fish and Wildlife Service. Endangered and Threatened Wildlife and Plants; Removing the Gray Wolf (Canis lupus) From the List of Endangered and Threatened Wildlife and Maintaining Protections for the Mexican Wolf (Canus lupis baileyi) by Listing it as Endangered. Federal Register (2013). at http://www.gpo.gov/fdsys/pkg/FR-2013-06-13/pdf/2013-13982.pdf

[3] Alderman, J. Crying Wolf: The Unlawful Delisting of Northern Rocky Mountain Gray Wolves from Endangered Species Act Protections. Boston College Law Review. 50, 1195-1241 (2009)

[4] Refsnider, R. The Federal Process of Reclassification and Delisting the Gray Wolf, Canis lupus. International Wolf Center (2013). at http://www.wolf.org/wow/united-states/e-recovery-and-management-2-2/

[5] Treves, A. & Bruskotter, J. Gray Wolf Conservation at a Crossroads. Bioscience. 61, 584-585 (2011)

[6] Pacelle, W. Breaking News: Federal Court Restores Protections for Great Lakes Wolves, Ends Trophy Hunting and Commercial Trapping. The Human Society of the United States (2014). at http://blog.humanesociety.org/wayne/2014/12/court-says-wolves-are-protected-under-esa.html?utm_source=feedblitz&utm_medium=FeedBlitzRss&utm_campaign=humanenation

[7] Timeline: Wolves in Danger. Earthjustice (2015). at http://earthjustice.org/features/campaigns/wolves-in-danger-timeline-milestones

[8] Gray Wolves in the Northern Rocky Mountains. U.S. Fish and Wildlife Service (2014). at http://www.fws.gov/mountain-prairie/species/mammals/wolf/

[9] Treves, A. & Bruskotter, J. Gray Wolf Conservation at a Crossroads. Bioscience. 61, 584-585 (2011)

[10] National Bald Eagle Management Guidelines. U.S. Fish and Wildlife Service (2007). at http://www.fws.gov/southdakotafieldoffice/NationalBaldEagleManagementGuidelines.pdf

[11] Musiani, M. & Paquet, P. The Practices of Wolf Persecution, Protection, and Restoration in Canada and the United States. Bioscience. 54, 50-60 (2004)

[12] Successful Recovery Efforts Prompt Service Proposal to Delist Gray Wolf and Focus ESA Protection on Mexican Wolf. U.S. Fish and Wildlife Service (2013). at http://www.fws.gov/home/wolfrecovery/

[13] Bergstrom, B., Vignieri, S., Sheffield, S., Sechrest, W., & Carlson, A. The Northern Rocky Mountain Gray Wolf is Not Yet Recovered. Bioscience (2009)

[14] When delisting has been overturned (book)

[15] Memorandum of Understanding between United States Department of Agriculture Animal and Plant Health Inspection Service and United States Department of the Interior Fish and Wildlife Service. (2001). at https://www.fws.gov/migratorybirds/Partnerships/APHIS%20MOU.pdf

[16] Treves, A. & Bruskotter, J. Gray Wolf Conservation at a Crossroads. Bioscience. 61, 584-585 (2011)

[17] National Bald Eagle Management Guidelines. U.S. Fish and Wildlife Service (2007). at http://www.fws.gov/southdakotafieldoffice/NationalBaldEagleManagementGuidelines.pdf

[18] Treves, A. & Bruskotter, J. Gray Wolf Conservation at a Crossroads. Bioscience. 61, 584-585 (2011)

[19] Pacelle, W. Breaking News: Federal Court Restores Protections for Great Lakes Wolves, Ends Trophy Hunting and Commercial Trapping. The Human Society of the United States (2014). at http://blog.humanesociety.org/wayne/2014/12/court-says-wolves-are-protected-under-esa.html?utm_source=feedblitz&utm_medium=FeedBlitzRss&utm_campaign=humanenation

[20] Ewing, C. & Cooley R. Gray Wolves and the Endangered Species Act. Nova Science Publishers: New York (2012)

[21] Memorandum of Understanding between United States Department of Agriculture Animal and Plant Health Inspection Service and United States Department of the Interior Fish and Wildlife Service. (2001). at https://www.fws.gov/migratorybirds/Partnerships/APHIS%20MOU.pdf

[22] Treves, A. & Bruskotter, J. Gray Wolf Conservation at a Crossroads. Bioscience. 61, 584-585 (2011)

[23] Musiani, M. & Paquet, P. The Practices of Wolf Persecution, Protection, and Restoration in Canada and the United States. Bioscience. 54, 50-60 (2004)

[24]Timeline: Wolves in Danger. Earthjustice (2015). at http://earthjustice.org/features/campaigns/wolves-in-danger-timeline-milestones

[25] Timeline: Wolves in Danger. Earthjustice (2015). at http://earthjustice.org/features/campaigns/wolves-in-danger-timeline-milestones

[26] Successful Recovery Efforts Prompt Service Proposal to Delist Gray Wolf and Focus ESA Protection on Mexican Wolf. U.S. Fish and Wildlife Service (2013). at http://www.fws.gov/home/wolfrecovery/

[27] Bergstrom, B., Vignieri, S., Sheffield, S., Sechrest, W., & Carlson, A. The Northern Rocky Mountain Gray Wolf is Not Yet Recovered. Bioscience. 59, 991-999 (2009)

[28] Treves, A. & Bruskotter, J. Gray Wolf Conservation at a Crossroads. Bioscience. 61, 584-585 (2011)

[29] Ewing, C. & Cooley R. Gray Wolves and the Endangered Species Act. Nova Science Publishers: New York (2012)

[30] Protected no longer, more than 550 gray wolves killed this season by hunters and trappers. NBC News (2013). at http://usnews.nbcnews.com/_news/2013/03/06/17213786-protected-no-longer-more-than-550-gray-wolves-killed-this-season-by-hunters-and-trappers

[31] Wolf Advisory Group. Washing Department of Fish and Wildlife (2015). at http://wdfw.wa.gov/about/advisory/wag/

[32] Platt, J. How Much id the U.S. Spend on the Endangered Species Act in 2012? Scientific American (2013). at http://blogs.scientificamerican.com/extinction-countdown/2013/11/01/endangered-species-act-2012/

[33] Doremus, H. & Pagel J. Why Listing May Be Forever: Perspectives on Delisting under the U.S. Endangered Species Act. Conservation Biology 15, 1258-1268 (2001)

[34] Ewing, C. & Cooley R. Gray Wolves and the Endangered Species Act. Nova Science Publishers: New York (2012)