Deadline to Comment on Feds Listing Mexican Gray Wolf as Endangered in Arizona

The deadline to comment to the United States Fish and Wildlife Service (USFWS) regarding listing the Mexican Gray Wolf as "endangered" has been extended to Thursday, March 27, 2014. It is extremely important that you oppose this ESA (Endangered Species Act) listing. If the Mexican wolf is given protected status under the ESA, it means that you as a property owner lose your fundamental property rights. The USFWS has plans to reintroduce the Mexican wolf in Arizona in a huge swath. The north border is I-40; south border is I-10; west borders California; east borders New Mexico. (See U.S. Fish & Wildlife to Introduce Wolves into Gila, Navajo, Graham, and Coconino Counties.)

See Threatened and Endangered Species and the Private Landowner:

ANIMAL PROTECTION
The Federal ESA prohibits "taking" of an endangered or threatened animal. This means that you cannot "harm harass, pursue, hunt, shoot, wound, kill, trap, capture, or collect any threatened or endangered species." "Taking" can also mean habitat alternation resulting in harm to the species. Whether on private or Federal land, whether intentional or unintentional, the "taking" of a listed animal is illegal. Protection in addition to this may be afforded through your State’s Endangered Species Act.

Both Gila Watch and Gilbert Watch have been reporting on the activities of the USFWS (United States Fish and Wildlife Service) as they have been shoving wolves down the throats of Arizonans. They have released wolves in Northeastern Arizona and in New Mexico, seriously and negatively affecting the livelihoods of people in those areas.

ACTION:

Please leave your Comment for the USFWS HERE. You will notice the large number of Pro-Wolf comments. This is because the environmental groups are very well organized, well funded with your tax dollars, and are heavily plugged in to all levels of government.

Need help with a comment? See below. Pick one or two as is or rewrite.

1. Please do NOT list the Mexican gray wolf as an endangered subspecies. It is the local government’s responsibility to protect the health, safety, and welfare of its citizens. This includes protecting local citizens from the adverse societal and economic impacts of federal actions. In 1998, the Mexican Wolf was reintroduced to Catron County, NM, and also Apache and Greenlee counties in Arizona. These citizens have been forced to bear the burden of the impacts of Mexican wolf reintroduction. They are well aware of the reality of the on-the-ground activities that have negatively affected their daily lives.

2. The management of these animals should be placed in the hands of the individual states. When management of these wolves is regulated by local governments rather than from Washington, DC, local citizens have much more meaningful input into the management of the environment they live and work in each day.

3. The USFWS has failed to provide evidence that the Mexican Wolf is endangered. “No total current Mexican wolf population count is provided anywhere in the proposed rule, and therefore it cannot be determined if, in fact, this population is at actual risk of extinction.”

4. There is no valid scientific basis for a more restrictive listing of the Mexican Gray Wolf. It has been repeatedly pointed out that the existing Recovery Plan from 1982 lacks objective and measurable criteria for recovery of the species. Further, the 1998 10(j) Rule notes that USFWS failed to submit the recovery proposal to local governments due to “legal, budget, staff and time considerations.” These deficiencies in the Recovery Plan should not be used as a basis to change the listing of the Mexican Gray Wolf. Instead, the USFWS should address those issues which are both hindering the program and creating significant negative impacts on the surrounding communities and residents. (See 12/12/13 Public Comments submitted by the Catron County Board of Commissioners, New Mexico.)

5. Should the Mexican wolf be granted ESA protection, there will likely be an increase in human-predatory animal encounters. Because these encounters may result in threats, attacks, injuries, and deaths of humans and livestock, the Navajo County, Arizona, Board of Supervisors has amended their Predatory Animal Ordinance. These supervisors take their responsibilities seriously, which include protecting the health, safety, and welfare of the people of Navajo County. Therefore, regarding Ordinance No. 01-08: 6.2. "Any individual may kill, injure or harass a predatory animal when and to the degree a reasonable person would believe that deadly force is immediately necessary to protect himself or to protect another person against a predatory animal because the predatory animal possesses an imminent threat of serious bodily harm to any individual." 6.3. "Any individual may kill, injure or harass a predatory animal that is in the act of killing, wounding, biting, or attacking livestock on private land."

6. The USFWS has failed to incorporate all factors into adaptive management. The shooting of wolves as documented by USFWS should serve as a clear indicator of the existence of a serious problem with the reintroduction program, which has proceeded forward since its inception as if these problems did not matter….USFWS has simply ignored the magnitude of the desperate situation of citizens who live and work in the BRWRA (Blue Range Wolf Reintroduction Area), and has made no effort to correct the false impression provided by pro-wolf environmental groups that the blame should be on human beings, rather than the problem wolves. People who live in rural communities cannot be forced to accept the depredation of big game and livestock by the Mexican wolf, nor should USFWS attempt to lay blame for wolf shootings on the independence and the desire for community self-rule in rural America. (See 12/12/13 Public Comments submitted by the Catron County Board of Commissioners, New Mexico.)

7. The USFWS has failed to consider the potential negative economic impacts that ESA protection to the Mexican wolf will create. This includes but not limited to depredation losses (livestock and pets, including herding and guide dogs); modifications of livestock husbandry, herding and grazing programs to accommodate wolf presence; livestock owner/manager time and travel in the course of preventing or reacting to depredations; livestock owner/manager time/travel required for coordination with wolf and land management agencies; and changes in or outright loss of business for outfitters and hunting guides. The impacts on agencies include, but again are not limited to: costs associated with meetings and other coordination with the Service on wolf-related issues; field and administrative staff required for wolf management; and large ungulate (prey) population shifts (including local changes in seasonal presence but also potential declines in herd size and hunter opportunity). There will also be an increase in costs to the State to monitor the herd size and assess impact levels to the ungulate population as wolves are reestablished on the landscape. Also, broadening wolf reintroduction and management to areas in Arizona that have significant state land holdings could cause a significant negative impact (i.e., decreased value or increased cost of managing lands leased for grazing) on the State Land Trust, which is primarily dedicated to supporting the state’s education system.” (See 9/18/2013 letter from Arizona Game and Fish Dept. to the USFWS.)

8. The USFWS has failed to incorporate all factors leading to opposition to Mexican wolf recovery efforts. The majority of those who champion the wolf as a noble and majestic animal do not have to suffer from the negative social or economic consequences of wolf reintroduction themselves, i.e., they are not true stakeholders and are only indirectly impacted or not impacted at all.

The pro-wolf non-stakeholders ignore the cold facts that the actual stakeholders are forced to experience, and which is well documented. As the pro-wolf non-stakeholders express their appreciation of the wolf, they never mention how wolves kill, or how wildlife and livestock that have been harassed by wolves are more susceptible to disease and injury, and fail to reproduce at self-sustaining rates. USFWS, too, avoids mention of how wolves run their prey until the prey is so tired it can no longer escape; how, unlike other non-canine predators such as mountain lions and bears, wolves eat their prey while the animal is still alive; how wolves may consume only the prey animal’s genitals and leave the animal to slowly die; how wolves may slash open their living prey to eat unborn fetuses and leave the mother animal to slowly die; how wolves hunt for fun and don’t even bother eating anything of the prey animals they take down.

These cold facts of how wolves hunt and kill has much to do with the opposition to the Mexican wolf in the BRWRA. When it is a person’s own livestock and pets that have been subject to the torture and agony of a wolf attack, the response is very different. When it is a person’s own family or self that risks wolf attack, fear becomes very immediate and not theoretical, regardless of interest in endangered species restoration.

9. The USFWS has failed to analyze the significance of lack of success of recovery efforts. There is a single alternative for management of the Mexican Wolf, which is to turn the settlement of the Southwest clock back at least 100 years in order to provide Mexican wolves with an environment in which they can roam freely and fill a natural niche that can support them. The problem with this alternative for Mexican wolf management is that the environmental niche for the Mexican wolf to fill no longer exists, and it would take very drastic changes in the environment to recreate such a niche.