On April 18, SCI submitted extensive comments in response to the proposed rule and draft environmental analysis prepared by the U.S. Fish and Wildlife Service in response to a request by the State of Colorado to designate a nonessential experimental population of gray wolves.
As a little background, the Colorado Parks and Wildlife Commission is required by voter initiative to “reintroduce” gray wolves in the State, even though wolves have already begun to establish breeding populations in northern Colorado. Gray wolves in most of the U.S., including Colorado, are listed as an endangered species under the Endangered Species Act. Thus, to “reintroduce” these wolves and obtain legal flexibility to manage conflicts between wolves, livestock, and other wildlife species, Colorado requested that the Fish and Wildlife Service issue a “10(j) rule” under the ESA. A 10(j) rule will give Colorado the authority to take management actions otherwise prohibited by the ESA, such as to control wolves that prey on livestock and domestic animals.
SCI strongly opposed the “reintroduction” of wolves to Colorado, but we support (with significant reservations) the issuance of a 10(j) rule. Our comments highlighted ways for the Fish and Wildlife Service to improve the rule. Among other things, we support inclusion of a provision to allow the State to control wolves once they negatively impact Colorado’s moose, deer, sheep, and elk populations, which are crucially important to hunters, hunting guides, and other wildlife enthusiasts. SCI also suggested inclusion of an “escape clause,” should a lawsuit threaten to change the Service’s management direction. SCI requested that the Service include clear and measurable steps for removing this wolf population from the ESA lists, once gray wolves are (again) delisted.
The Fish and Wildlife Service received over 4,400 comments on the proposed rule and environmental analysis. They must now review and respond to substantive comments and make changes as needed before finalizing the 10(j) rule.