Arizona State Sen. Gail Griffin, R-Hereford, sent the following letter to Daniel Ashe, U.S. Fish and Wildlife Service director in Washington, D.C.
Dear Mr. Ashe,
It’s with great alarm that I write to express my vehement opposition to U.S. Fish and Wildlife Service proposals to further protect and promote the Mexican gray wolf in Arizona.
From the beginning, the U.S. Fish and Wildlife Service Mexican Wolf Recovery Program has been a fundamentally flawed effort that has relied on faulty science, inadequate communication and coordination with affected local stakeholders, and a misguided premise that puts the interests of dangerous predators ahead of the public’s interest, as well as the public’s safety. It has been and continues to be a program that is loathed by local residents, unsupported by state officials and opposed by nearly every relevant Arizona-based stakeholder group in Arizona.
For these reasons and others, the U.S. Fish and Wildlife Service, rather than expanding the program, should be considering how to end it.
Faulty data
It’s difficult to understand why the U.S. Fish and Wildlife Service is considering an expansion of the Mexican Wolf Recovery Program when it is clear that it has been formed by faulty data from the beginning.
From questions about whether these wolves are, indeed, wolves, or a dog-wolf hybrid, to issues surrounding the logic (or lack thereof) of attempting to restore a wolf population whose primary habitat is outside of the United States, the U.S. Fish and Wildlife Service has consistently ignored important questions about the data upon which the service is making its decisions.
There have been documented cases of female Mexican wolves breeding with dogs and producing a wolf-dog hybrid.
Similarly, from the program’s beginning, concerns have been expressed regarding the wolves’ ability to survive in the wild after being born and bred in captivity. Indeed, the program, since its inception, has failed to reach its goal of restoring 100 Mexican Wolves in the wild.
Why should Arizona taxpayers and, more specifically, Arizona property owners be subject to a program that has shown itself incapable of success?
One must also ask, what is the service’s determination of success? Since the initiation of the Mexican Wolf Recovery Program, the Service’s population goal has consistently been 100 animals. However, the U.S. Fish and Wildlife Service has recently, in both verbal and written statements, dismissed the original population goal but is not providing an alternate objective, measureable criteria, as required by the 10(j) rule. Nor is it providing a scientific analysis to support its dismissal of the longstanding population goal.
Finally, the Endangered Species Act requires that a team of scientists evaluate the basis for the U.S. Fish and Wildlife Service’s recent proposals before a decision is made. As standard procedure to ensure that the analysis meets standards for quality and independence, the U.S. Fish and Wildlife Service hired a contractor to select and oversee the peer review panel.
In June 2013, the U.S. Fish and Wildlife Service released a peer review plan; however, the more recently ordered review is slated for completion by Sept. 11, 2013, which is the very date on which the public comment period was scheduled to be closed. Although the U.S. Fish and Wildlife Service recently announced an extension of the comment period, the agency’s obvious intent to move forward with a decision based on a scientific study that could not be evaluated by affected stakeholders raises serious questions about the agency’s willingness to consider feedback from all stakeholders. In other words, how can stakeholders be assured that their comments will be considered when the original public comment period was slated to end on the same day that the scientific study was scheduled to be completed?
These questions illustrate why Arizona policymakers and stakeholders are mistrustful of the U.S. Fish and Wildlife Service’s Mexican Wolf Program. Its reliance on questionable data and ignorance of stakeholder feedback leave the public with little reason to trust U.S. Fish and Wildlife Service actions.
Inadequate communication and coordination with local stakeholders
Again, from the beginning, the viewpoints of local stakeholders have routinely been dismissed or ignored. This remains the case with the U.S. Fish and Wildlife Service’s most recent proposals. Section 10(j) of the Endangered Species Act mandates a process of engagement with public and cooperating agencies. This process is articulated around the two concepts of:
• Full communication to the public of all the components of the proposed actions and their alternatives; • Engagement of the public and cooperating agencies at the earliest possible stage of the process, prior to the agency plans being formalized and its course of action being committed.
By any objective measure, the U.S. Fish and Wildlife Service is currently in default of these two fundamental provisions of Endangered Species Act and NEPA for the following reasons: First, several critical components of the proposed actions, such as the Mexican Wolf Management Plan for Portions of Arizona, New Mexico, and Texas outside of the Mexican Wolf Experimental Population Area; the Mexican Wolf Revised Recovery Plan; the Scientific Peer Review for the Proposed Revision to the Nonessential Experimental Population of the Mexican Wolf; and, a Bi-National Mexican Wolf Collaboration Plan, have not been released to the public, making it impossible for the public to review the complete proposed actions prior to the end of the comments periods (see subsequent paragraphs).
Second, proposed actions have been developed by the U.S. Fish and Wildlife Service without engaging the public in Arizona and New Mexico in procedural public meetings on the Mexican wolf issues since 2007, therefore relying on 6-year-old outdated scoping information inconsistent with the U.S. Fish and Wildlife Service policy on compliance with NEPA, as described in the U.S. Fish and Wildlife Service policy manual in Chapter 1 of 550 FW 1.
Third, a letter by U.S. Representative Paul Gosar, R-Ariz., expressing concerns with the U.S. Fish and Wildlife Service approach to the issue of public engagement was met with a vague answer one month later in which U.S. Fish and Wildlife Service failed to adequately respond to Congressman Gosar’s requests. The U.S. Fish and Wildlife Service declined to engage in the number and locations of meetings that Congressman Gosar requested on behalf of his constituents, who will be affected by the U.S. Fish and Wildlife Service decisions.
Fourth, procedural actions taken by the U.S. Fish and Wildlife Service (78 FR 35664; 78 FR 35719; 78 FR 47268) directly contradict the Endangered Species Act and NEPA requirements for early public engagement to take place prior to the U.S. Fish and Wildlife Service plans being formalized and its course of action being effectively decided. The actions suggest that U.S. Fish and Wildlife Service is not sincere in its calls for public comment on its proposed actions.
In view of the above, and due to the scope, complexity and controversial nature of the proposed actions, as well as the flaws discussed in the subsequent sections, the U.S. Fish and Wildlife Service should suspend the comments process and make every effort to ensure that the public, local governments and their constituents are given multiple opportunities to participate in a meaningful way in the engagement process through a series of public scoping meetings held across the entire area potentially affected by the proposed actions, which encompasses the entire states of Arizona and New Mexico.
Anything less would signal to Arizona stakeholders that U.S. Fish and Wildlife Service is not sincerely interested in the viewpoints and feedback of the public and their elected representatives.
Misguided premise
Undergirding the entire Mexican Wolf Recovery Program is the premise that these dangerous carnivores warrant protection from the public by the federal government. This is a flawed premise that must be questioned, especially in light of the U.S. Fish and Wildlife Service proposal to dramatically expand the program, thereby impacting literally millions of Arizona residents.
Mexican Gray Wolves are documented predators who feed on large-game wildlife, including deer, elk and cattle. While it’s true that documented wolf attacks on humans are rare, the mere fact that such attacks are possible — some would say inevitable — should have ended any consideration of the program’s existence decades ago. However, the possibility of such attacks was ignored and the program was created. Also ignored were concerns of local ranchers in Greenlee County, who correctly predicted that Mexican wolves would feed on their cattle, resulting in an economic impact to families that have ranched in this region for generations.
Fifteen years later, these predictions have proven true. Contrary to U.S. Fish and Wildlife Service claims that wolves would only feed on deer, released wolves have consistently depredated a large number of privately owned cattle. Many local ranchers have not been compensated for their losses, resulting in thousands of dollars in financial losses that can be directly attributed to the federal government.
Instead of responding to these impacts to local ranchers by ending the program, the U.S. Fish and Wildlife Service is now proposing to dramatically expand the program to include the entire state of Arizona between I-40 in the north to I-10 in the south. This expansion has the potential to affect, and put at risk, virtually all Arizonans who live within that area.
Along with an expansion of the geographic area in which wolves would be released, the U.S. Fish and Wildlife Service is proposing to increase (to an unnamed goal) the number of Mexican wolves to be recovered, raising the possibility that hundreds, if not several thousands of Mexican wolves could be roaming throughout central Arizona, again, putting at risk dramatically more people than are currently threatened by the program in its current form.
In light of these wolves’ predatory instincts, their documented ability to kill large cattle and wildlife, and their potential ability to kill human beings, one must ask: Why is our federal government spending tens of millions of dollars to promote this predatory species?
The only logical answer to this question is that the supporters of the Mexican Wolf Recovery Program place a greater priority on protecting animal life than they do on protecting the public. For this reason, the U.S. Fish and Wildlife Service and the supporters of the Mexican Wolf Recovery Program should be ashamed.
Gail Griffin Senator, District 14 Arizona State Senate