May 6, 2013
CWF submitted public comment on May 3 to the U.S. Fish and Wildlife Service in support of the agency's published proposal to list the wolverine as a threatened species under the Endangered Species Act. We thank Board Member and wildlife biologist Gary Miller for his hard work on this matter.
Below is the CWF letter:
Public Comments Processing
Electronic Submission via Federal e-Rulemaking Portal
Division of Policy and Directives Management
U.S. Fish and Wildlife Service
4401 N. Fairfax Drive, MS 2042-PDM
Arlington, VA 22203 03 May 2013
Re: Wolverine Listing Proposal Comments
We submit this letter in strong support of the Fish and Wildlife Service’s February 4, 2013 published proposal to list wolverine (Gulo gulo luscus) as a threatened species under the Endangered Species Act (ESA). The Colorado Wildlife Federation independently reviewed the proposal and supporting documents and attended the informational and public input meeting in Lakewood on March 19, 2013. We generally concur with the proposal, including the stipulations of the proposed 4(d) and 10(j) rules. We have concluded that the proposal will allow wolverines to be adequately protected without undue restrictions upon traditional human activities and, more importantly, to become re-established in their former Colorado habitats.
We concur with the proposal’s finding of no need to further restrict activities such as snowmobiling, backcountry skiing, timber harvesting, common private land practices, public land usage, developed ski areas, etc. These activities, because they are very small relative to wolverine habitat requirements, constitute negligible risk to the species’ recovery and viability. The listing as Threatened, with the 4(d) and 10(j) rules, presents an opportunity to demonstrate compatibility between human activities and conserving at-risk species, and the value of diverse interests cooperating to conserve and restore this native species.
In particular we support the 10(j) designation for the Southern Rocky Mountains (primarily Colorado) upon, but not before, the initiation of a viable restoration effort, and request this stipulation be clarified in the final rule. A 10(j) designation clearly is the most realistic, efficient means to most rapidly restore wolverines as a member of Colorado’s high country wildlife heritage once again. A major contributor to their extirpation from the state was likely past anti-predator campaigns that, as an unintended consequence, also eliminated these scavengers to the point they could not sustain population viability. Such campaigns are a thing of the past on Colorado’s public lands (comprising over 90% of expected Colorado wolverine habitat), and a 10(j) designation allows correction of this past error. The 10(j) designation significantly reduces potential objections to our state’s Legislature’s approval of a restoration effort, aiding them in meeting their own commitment to …” insure their (nongame wildlife’s) perpetuation as members of ecosystems…” and “… assist in the protection of … wildlife which are deemed to be endangered or threatened elsewhere…” (Colorado Revised Statutes 33-2-101, Nongame, Endangered, or Threatened Species Conservation Act). Hence, the Threatened with 10(j) rule facilitates Colorado Parks and Wildlife’s ability to lead the wolverine restoration effort and we encourage their aggressive implementation of that effort. Similar to the 4(d) rule, the 10(j) designation allows the many compatible human activities and land uses (private lands, ski areas, snowmobiling, etc.) to continue absent unnecessary restrictions of the full Endangered Species Act (once a restoration project is implemented), and thus facilitates collaboration by a wide array of interests, to their mutual benefit, in the restoration of wolverines to Colorado and the southern Rocky Mountains.
In evaluating other options for listing, our fundamental consideration must be “What is best for wolverines?” The preponderance of our human knowledge, including wolverines’ demonstrated (albeit slow) population extensions following more regulated trapping and predator control, wide tolerances for many of their life requirements (e.g., a eurytopic species), justifies threatened, not endangered, status. In fact, such options as an ESA-Endangered classification or Threatened absent the 10(j) rule would, in this case, more likely be counter-productive. These options would increase the expense and, especially, the time involved in correcting human mistakes of the past. Most likely they would needlessly hinder restoration of the species to its former ranges, a key strategy in giving wolverines their best chance to adjust and adapt to ever-changing conditions. Consequently, we do not consider these options to be “what is best for wolverines.”
The Colorado Wildlife Federation (CWF) is Colorado’s oldest statewide wildlife conservation organization, a 501(c)(3) nonprofit whose members consist of a broad spectrum of wildlife conservationists, who appreciate wildlife not only through pursuit, but for wildlife’s role in our state’s natural heritage. CWF’s mission is to promote the conservation, sound management and sustainable use and enjoyment of Colorado’s wildlife and habitat through education and advocacy. We strongly encourage support of the Threatened listing proposal and the 4(d) and 10(j) rules by any individuals and organizations who value wild country, who share the Colorado Wildlife Federation’s commitment to “all things wild” in Colorado and elsewhere.