Last November, the U.S. Fish and Wildlife Service (USFWS) finalized a deeply flawed recovery plan for the Mexican gray wolf that scientists and conservationists fear will prevent the species from thriving, if not surviving, in its historic homelands.
Bowing to objections from state officials, the plan limits recovery efforts to south of Interstate 40, cutting wolves off from essential habitat in and around Grand Canyon National Park and the southern Rocky Mountains of Colorado and New Mexico. The plan also sets population targets of only 320 wolves in the United States and 200 in Mexico to remove protections—well below what scientists have determined are needed for Mexican gray wolves, or Lobos, to be considered stable.
After decades of engaging the USFWS in the on-again, off-again Mexican wolf recovery effort, conservationists genuinely alarmed over the flagrant shortcomings of the “Final—First Revision” plan to restore the Lobo to the wild followed the only recourse available—we took the agency to court.
After decades of engaging the USFWS in the Mexican wolf recovery effort, conservationists genuinely alarmed over the flagrant shortcomings of the plan to restore the Lobo to the wild followed the only recourse available—we took the agency to court.
The lawsuit will be working its way through the judicial system for months. In the meantime—and well after it concludes one way or the other—there is plenty of work to do on the ground. While flawed, the recovery plan is a start in that it provides some direction for both the USFWS and other federal agencies, including Mexican agencies, to move forward in recovering the Mexican wolf. Any recovery plan is, in reality, just a blueprint—it can be helpful to provide an outline of actions and hopefully allocation of funding—but it also requires the work of partners outside the agencies and coordination between the states and other stakeholders.
That’s where we come in. Wildlands Network hopes to play a key role in these next steps by working with the Forest Service to design management strategies for public lands that will give Mexican wolves a better shot at recovery.
Taking Advantage of Land Use Planning to Promote Recovery
Congress passed the Endangered Species Act (ESA) in 1973 “to provide a program for the conservation of…endangered species and threatened species” and “to provide a means whereby the ecosystems upon which endangered…and threatened species depend may be conserved.”
The ESA establishes an affirmative obligation for the federal government to use “all methods and procedures which are necessary to bring any [listed] species to the point at which the measures provided in this [act] are no longer necessary,” and states that “all federal departments and agencies shall seek to conserve endangered … and threatened species.” “Conserve” and “conservation” are defined by the statute as using “all methods and procedures which are necessary to bring any endangered …or threatened species to the point at which the measures provided” by the statute are no longer necessary.
Scholars persuasively argue that the ESA and its regulations clearly intertwine the fate of species and ecosystems. The two are linked together under the law, and the statute mandates that all federal land agencies utilize their authorities to effectuate the purposes of the Act. So, even though a recovery plan exists, federal land management agencies, like the Forest Service and Bureau of Land Management, must also take action to protect Mexican wolves and preserve their habitat, with the goal of facilitating their recovery.
Many laws, such as the National Environmental Policy Act (NEPA) and the National Forest Management Act (NFMA), provide us the significant opportunity to engage in decision-making and land use planning to help federal agencies meet these obligations.
For example, seven national forests lie within the Mexican Wolf Experimental Population Area. These forests provide significant habitat and connectivity value critical to the conservation and recovery of Mexican gray wolves (Carroll et al. 2014). Two of those forests—New Mexico’s Gila and Arizona’s Tonto national forests—are currently undergoing revisions in forest plans, which provide direction for land managers on all aspects of resource management for decades, and all national forests are subject to forest plan amendments, which can be added later.
While these forests are undergoing forest plans revisions, we have an opportunity to help designate how they are managed, including for the recovery of Mexican wolves. What’s especially promising is that forest plans revised and amended under the new 2012 Planning Rule include a new set of substantive requirements for management of wildlife. This means that the federal government cannot jeopardize the continued existence of listed species, or destroy or adversely modify any critical habitat that has been designated, or result in prohibited incidental take.
Forest plans may also be viewed as the primary means by which the agency is “carrying out programs for the conservation of” listed species, in accordance with the ESA. Therefore, it’s especially critical that forest plans and other land use plans consider the recovery of ESA-listed species that call those lands home. For the Lobo, forest plan components (e.g., desired future conditions, objectives, standards, and guidelines) must provide the “ecological conditions necessary to contribute to” their recovery.
Coordinating with Environmental Agencies and Stakeholders
Other agencies have shown interest in taking a more proactive approach on this issue. For instance the National Park Service has called for consideration of public lands with plenty of Mexican wolf prey species north of the current Mexican Wolf Experimental Population Area (MWEPA) within the context of recovery planning. Such lands could include Grand Canyon National Park and other park units.
At least 11 NPS units lie within the MWEPA and there are at least 18 NPS units within the recovery area north of I-40 and south of I-70 recommended by the USFWS’s own Mexican Wolf Recovery Team’s scientific subgroup in 2012.
Unfortunately, however, we don’t expect most federal land managers to take proactive action without a push from the public and wolf supporters. So, we’re focusing on providing information and suggestions, based on the best available science and some new analysis we’re working on (stay tuned!), that we think will help Mexican wolves on the ground and those still to come.
Some possible recommendations the agency might consider include:
- The agency works to lower road density below one mile per square mile.
- The agency collaborates with adjacent and nearby government and private landowners to maintain and restore Mexican gray wolf habitat connectivity.
- The forest or park serves as a core and connectivity area for Mexican gray wolves that allows for the establishment of wolf packs, provides the conditions for sustained occupancy, and protects habitat connectivity to enable wolf movement through the forest and to other areas beyond forest boundaries.
- The agency provides secure denning and rendezvous sites for wolf packs that are avoided by management activities and permitted uses during critical biological periods, including whelping and rearing.
- The agency maintains a prey base for Mexican gray wolves that enables their sustained occupancy of the forest.
- The agency works with grazing permittees to improve husbandry practices, especially during high-risk time periods (e.g., calving/lambing). The revised plan should provide livestock management flexibility to allow grazing permittees to alter the timing or location of livestock movement within an allotment in order to reduce potential wolf-livestock conflicts.
- The agency enables grazing permittees to voluntarily relinquish or retire all or portions of allotments and close allotments to future grazing as opportunities arise under applicable regulations, where removal of livestock grazing would enhance the ability to contribute to Mexican gray wolf recovery.
Issuance of the “Final” Mexican wolf recovery plan does not end our obligation to continue efforts to return the wolf to its rightful place in the American West. Land use planning affords us one effective opportunity to achieve that goal, even in times as uncertain as these. We have our community of concerned citizens. We have friends even in the beleaguered federal agencies. We have compassion for the wild denizens whose fates lie in our hands. We have laws on our side. And we are determined to prevail.