July 26, 2019—The gray wolf has far exceeded recovery numbers and wolves in the Northern Rocky Mountains have been managed by state wildlife agencies for two or more years, thus delisting the species nationwide is long overdue, the Wyoming Farm Bureau Federation (WyFB) recently told the U.S. Fish and Wildlife Service (USFWS). Wyoming Farm Bureau joined the American Farm Bureau Federation and State Farm Bureaus and Farm Bureau members representing 39 states in responding to the USFWS proposal to delist the gray wolf nationwide. “The Wyoming Farm Bureau Federation supports the USFWS proposal to delist Canis lupus throughout the conterminous United States,” wrote Ken Hamilton, WyFB Executive Vice President. “We concur with the Agency that current wolf numbers are adequate to sustain the population of wolves in the United States.” “For decades, the numbers in the Northern Rocky Mountain area have been well above the level established for wolf recovery. Current management practices by the states in the area have shown wolf numbers remaining stable or increasing,” Hamilton continued. “In addition, dispersing wolves travel between areas which contribute to the genetic interchange between populations.” The process which resulted in wolves being trans-located from Canada to Wyoming had several components. One of those components was the “recovery goal” established by scientists to achieve a viable population of wolves in Montana, Idaho and Wyoming identified as the Northern Rocky Mountain Experimental Non-Essential population area. “The goal was established to also let those impacted by wolves know when wolves were recovered and placed back under state control,” Hamilton explained. “Unfortunately, the judicial branch began a game of “legal gotcha” that delayed state control for over a decade after achieving the recovery goal. Congress recognized that the judicial branch was playing this game and authorized state management in Idaho and Montana, but left Wyoming out of this Congressional action. After several more attempts to delist wolves within the state of Wyoming, the legal process eventually resulted in allowing wolf management by the State.” Hamilton noted that wolves have also exceeded recovery numbers in the Western Great Lakes area. “Like the Northern Rocky Mountain area, once wolves reached recovery numbers, the Agency was supposed to return management to the various states,” he wrote. “The court in overturning the decision to delist wolves in the Western Great Lakes area cited concern over the impact on wolves outside of the Western Great Lakes which wasn't adequately analyzed by the Agency.” Farm Bureau referenced the issues created when the Agency moved recovery at the species level by trying to identify species territory. “Because of this, trying to segment the United States into areas to establish separate recovery zones has always been problematic because of the ability of wolves to travel those long distances and then inter-breed with other wolves. This issue has been acknowledged in the Federal Register Notice,” he wrote. Farm Bureau noted the mitigation of losses caused by wolves is a critical component in any management process for wolves. “Wolf impacts to livestock producers was a critical component considered when wolves were trans-located into Wyoming. The Agency understood that absent effective methods to reduce wolf impact on livestock, the acceptance of the wolves would be limited in the area,” Hamilton said. “The Agency also understood that as wolves moved farther away from areas with habitat for wolves, the likelihood of wolves creating conflicts with people increased.” Additionally, Farm Bureau said the direct costs to citizens affected by wolf depredations need considered. “Acceptance of losses by wolves can be increased through effective compensation programs,” Hamilton stated. “The federal government should actively work with states to fund, develop and promote compensation programs.” “In all of the wolf recovery programs, the federal government has avoided the direct costs to citizens affected by wolf depredations by moving that cost to state or private entities,” he said. “This cost shifting has created an imbalance between the states and federal government where the states have shouldered this economic responsibility while the authority has remained with the federal officials. Delisting wolves in the lower states addresses this imbalance to some degree but doesn't address the past imbalance issues.” The economic impact on the Agency also needs addressed in the delisting. The purpose of the Endangered Species Act is two-fold: to recover species that are in danger of becoming extinct and to determine when a species has recovered, Farm Bureau noted. “If this recovery function is not observed, the ESA becomes nothing more than a cumulative list of species without regard to their status. Recovered species that are not delisted siphon scarce and valuable resources from species that really need them,” said the American Farm Bureau Federation. “Not only that but failing to remove a recovered species from the endangered species list prevents farmers and ranchers in the regions in which that species lives from fully using their land,” the American Farm Bureau stated. “It also blocks them from protecting their animals. As the wolf population has grown, so has the number of wolf attacks on sheep, cattle, other livestock and even family pets.” “Wolves in the Northern Rocky Mountains have been managed by state wildlife agencies for two or more years and we feel it is important to allow the states in the Western Great Lakes region the opportunity as well,” Hamilton concluded. “We feel that delisting of Canis lupus nationwide is warranted.”