The U.S. Fish and Wildlife Service (USFWS) prepared a draft environmental impact statement (DEIS) for the state of Colorado’s planned introduction of wolves. USFWS is involved because wolves in Colorado are on the federal Endangered Species Act (ESA) list. USFWS considered three alternative plans, and chose this one:
“Alternative 1. Provide the Service (FWS) and its designated agents management flexibility and provide for conservation of the species by approving a section 10(j) rule for the gray wolf population in Colorado, including any gray wolf living in, dispersing into or reintroduced to the state.”
This alternative allows Colorado to introduce wolves and manage them along with wolves naturally dispersing into Colorado. The state of Colorado can be the designated agent, and the 10(j) rule allows more management flexibility than strict enforcement of ESA regulations. A final EIS and decision will be developed in the next few months.
Submission of comments from the public ended on April 18 and will be considered by USFWS as the final EIS is prepared. It is useful to read the DEIS and the public’s comments to understand the issue of wolf introduction and management in Colorado. But finding the DEIS and the public comments requires going to websites that can be confusing. I provide website links here to make it easier for WLJ readers:
1. The DEIS is at this website: www.regulations.gov. Enter “Docket No. FWS-R6-ES-2022-0100” in the search box to read the DEIS.
2. To view the public comments, click “view related comments” on the DEIS page.
The public comments, submitted by stockmen, outfitters, county commissioners and many others, are worth reading. I submitted comments from a scientist’s perspective, summarized here. A major deficiency of the DEIS is that it did not consider the alternative of not introducing wolves to Colorado and simply allowing wolves to naturally recolonize the state. USFWS considered such a plan in assessments preceding the DEIS “…under which the gray wolf would not be intentionally reintroduced in Colorado. The recovery of the gray wolf in the state would rely on natural recolonization and population growth…” This seems like a reasonable approach and would allow the wolves and prey to adapt over time. But USFWS rejected this plan on legal grounds that are not clear to me. An alternative plan of not introducing wolves should be reconsidered by USFWS in the final EIS.
Federal land management agencies (the Bureau of Land Management, U.S. Forest Service and National Park Service) should amend their wildlife plans and assess the impacts of wolves on wildlife and livestock prior to approval of a final EIS. USFWS noted that “wolves can disperse long distances and may eventually occur throughout the state” and will certainly occur on federal lands.
The state of Colorado and USFWS should agree in the final EIS that they will cooperate to manage wolves, including lethal and non-lethal take of wolves to protect people, dogs, livestock and game populations. Wolf management by the state of Montana, including lethal take with hunting and trapping, has been effective in maintaining viable wolf populations and can provide guidance for Colorado (see the references at wlj.net). The DEIS should consider all of the available science regarding the potential numbers of wolves and prey that will be killed in Colorado. This includes my reports and articles with analyses that predict the numbers of wolves that might populate Colorado, and the numbers of prey animals they will kill (see the references).
The DEIS addresses impacts on livestock, but does not address potential impacts on the mining, oil and gas, and timber industries. It is likely that environmentalist lawsuits with speculative claims of impacts on wolves will attempt to restrict these industries. The EIS can help prevent such lawsuits with proactive assessments. Information about wolf subspecies, including the source of wolves to be introduced to Colorado and their possible interactions with the Mexican wolf subspecies (Canis lupus baileyi) in Arizona and New Mexico, is presented in the DEIS and by the Arizona Game and Fish Department. This issue can be assessed further with rigorous science and acknowledging that subspecies designations are not scientifically definite (see the references).
In this regard, the source of wolves for an introduction to Colorado is an important consideration. Wolves in the northern Rocky Mountain states of Montana, Idaho and Wyoming resulting from introductions in the 1990s are the northern wolf subspecies (Canis lupus occidentalis), although these states and Colorado were originally populated with the plains wolf subspecies (C. l. nubilus). If the subspecies status of the Mexican wolf is a serious consideration, the subspecies in the northern Rocky Mountains and Colorado should be also.
WLJreaders might consider making your elected officials and state and federal agencies aware of your opinions and those in the comments on the DEIS, as the final EIS is prepared and implemented. — Dr. Matthew Cronin
(Matthew A. Cronin is a scientist with Northwest Biology Company LLC in Bozeman, MT. He can be contacted at croninm@aol.com. A full list of references may be found online at wlj.net.)
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