Gila Livestock Growers Assn.’s suggested wolf rule talking points

Gila Livestock Growers Assn. Call for assistance if needed 575-772-5753  Laura

Talking points for listing and expansion of Mexican wolf 10J Rule. Please not there are TWO current proposals we need you to comment on.

Where to comment

(1) Electronically: Go to the Federal eRulemaking Portal: Search for either of the two titles for the proposed rule below the direct links are here as well. You may submit a comment by clicking on ‘‘Comment Now!’’


(2) By hard copy: Submit by U.S. mail or hand-delivery to: Public Comments Processing, Attn: FWS–R2–ES–2013–0056; Division of Policy and Directives Management; U.S. Fish and Wildlife

Service; 4401 N. Fairfax Drive, MS 2042–PDM; Arlington, VA 22203.


1. The first will be fairly easy, the second a little more difficult. They are both tied to each other. So you can be blunt and quick with the first one, but the second you need to be a little more detailed.

Effects of the Rule

This proposal, if made final, would remove the protections of the Act for the current C. lupus listing, by removing this entity from the List of Endangered and Threatened Wildlife. This proposal, if made final, would list C. l. baileyi as an endangered

subspecies. This proposed rule has no effect on the existing nonessential experimental population designation for gray wolves in portions of Arizona, New Mexico, and Texas.


However, as a matter of procedure, in a separate but concurrent rulemaking, we are also reproposing the nonessential experimental population to ensure appropriate association of the experimental population with the newC. l. baileyi listing. In addition, that proposed rule includes revisions to the regulations governing the management of the nonessential experimental population


Once on the site (link just below) Click on the links and on the right side click on comments to either comment directly or upload your comments.

Removing the Gray Wolf (Canis lupus) from the List of Endangered and Threatened Wildlife and Maintaining Protections for the Mexican Wolf (Canis lupus baileyi) by Listing It as Endangered.!documentDetail;D=FWS-HQ-ES-2013-0073-30560





Delist the Mexican wolf with the gray wolf.    Genetics and taxonomy show that the Mexican wolf is located between the Canadian gray and the north American gray and both those species are slated for delisting.


The Mexican wolf should be delisted on this proposal it is not a subspecies of wolf,  it is a gray wolf and able to breed with the original species.   A grizzly and black bear are separate and distinct subspecies, but a gray wolf and Mexican wolf can breed and therefore are not.  The Mexican wolf is simply a line bred, wolf with the distinction of sharing mitochondrial DNA in its captive gene pool.  That does not make it a separate distinct sub species.  It is simply a geographically separate population of gray wolves that should be subject to De-listing.



Delist all Gray wolves they are recovered and no longer in danger of extinction.



2.  Proposed Revision to the Nonessential Experimental Population of the Mexican Wolf.


  1. 1. Proposed Revision to the Nonessential Experimental Population of the Mexican Wolf.!documentDetail;D=FWS-R2-ES-2013-0056-2892


De-listing / Re-listing  .  ( please use your own words and ideas and experience as much as possible and choose several topics)


*Delist the Mexican wolf with the gray wolf.    Genetics show that the Mexican wolf is located between the Canadian gray and the north American gray and both those species are slated for delisting.   The Mexican wolf distinction of being line bred from one female wolf does not constitute a separate and distinct subspecies.  The only criteria that is not subjective scientifically geographically  separate gray wolf.


Do not change listing to Essential  whether or not such population is essential to the continued existence of an endangered species or a threatened species is the only criteria that matters.  With the captive population and breeding animals in place and with the northern populations, none of these wolves are essential to the continued existence of this species.   For 16 years non-essential was the legal definition of this animal, with far fewer of the animals than exist today. Regardless of the emotional plea of wolf activists changing the species to essential should never be a consideration.


With the substantial captive breeding gene pool, and the wild population being made up of solely redundant animals, this population of wolves is not in danger of extinction and cannot be designated essential.


Keep the 10J status, critical habitat shall not be designated under this Act for any experimental population determined under subparagraph (B) to be not essential to the continued existence of a species.


The Mexican wolf is not a subspecies of wolf,  it is a gray wolf and able to breed with the original species.   A grizzly and black bear are separate and distinct subspecies, but a gray wolf and Mexican wolf can breed and therefore are not.



In the above proposal, the US Fish and Wildlife Service also want to (See the maps below of what they want to do now and what they envision in the future) – “modify existing regulations governing the nonessential experimental population to allow captive raised wolves to be released throughout the Blue Range Wolf Recovery Area in the Apache and Gila National Forests east central Arizona and west central New Mexico, and to disperse into the Mexican Wolf Experimental Population Area in the areas of Arizona and New Mexico located between I 40 and I 10.”   There are 4 alternatives available all of which involve direct release into the current BRWRA with natural expansion into the entire recovery area. All of which have parternerships for releases with cooperating private landowners out of the current BRWRA and all of which allow direct release potential into state lands.  The breeding up of over 300 ready to go wolves in captivity is certainly an indicator that the plan is already bigger than simply continuing releases into the BRWRA and allowing natural dispersal.

Consider also the last rulemaking an entirely new final rule was implemented after scoping and draft rulemaking so don’t let the idea that it will continue as is and complacency is acceptable sway your thinking.  Direct releases occurred in NM a year after that rule was implemented after a short month long comment period EA discussing sites.

Management and rule changes.  Talking points.  ( please use your own words as much as possible and choose several topics)

No increase in released wolf population into the BRWRA the area is saturated and overflow dispersal is already occurring.  300 more wolves into the BRWRA is simply not scientifically feasible for the habitat that exists. It is a foot in the door to spread the program without the outside impacted people being made aware.

NO private landowner agreements for releases due to surrounding livestock producer and private property impacts.

Private property (pets, livestock and other privately owned animals)deserve protection from wolves and the owners should never have their right to protect their property restricted or denied over this animal.

Mexican wolves are not in danger of extinction in the wild as some may claim.  No permit should ever be required for a property owner to protect livestock regardless of the location of that livestock whether on private or federal land.

Discriminating against federal allotment owners by not allowing them to defend their livestock from attack, is not ethical and is arbitrary and capricious whether that depredation occurs on deeded land or a federally administered grazing allotment where the owner has vested prior existing rights, surface property rights and rights of way.   Location does not change the designation of private property.

State lands should not gain the same management status as federally owned land. Voters in those states must decide that issue not the federal government.

Replacing the term depredation incident was done by default of a policy change several years ago, the definition should be one animal depredated is one depredation incident. Not multiple animals in a 24 hour period.  The change was arbitrary and capricious then and it is arbitrary and capricious as a rule change as well.

The agency should stop using the term Extinction in the wild, the term was coined by wolf advocates and isn’t relevant to this program.  Extinction only means the state or situation that results when something (such as a plant or animal species) has died out completely.  It isn’t subject to location or whether or not an animal is or isn’t in all corners of the historic habitat.

The term extinction in the wild is spin until or if the captive breeding  animals all die, and the wild population is also dead the term is arbitrary and capricious and unethical

Extinction is something that is less likely to occur than it was in the years before this program began and the term extinction in the wild should never be thrown around  loosely.

Incorporate the New Mexico Cattle Growers association Petition for rule change document into scoping and alternatives.  Simply ignoring it isn’t an option.  This petition was written and submitted during the 5 year review.

Removal of trapping in the BRWRA and expanded areas is not conducive to the survival of the species as a whole, all released wolves are redundant and not essential to the survival of the species, if one is accidentally trapped on occasion it does not threaten the species.

The captive breeding population increase of the past 6 years is indicative of a predetermined decision to expand the program.  Pre determined decisions are illegal under the ESA and NEPA.


How they (meaning wolves) will DIRECTLY affect your operation if they showed up.

How they will affect your livestock operation?

How will they affect your farming operation?

How will they affect your registered herd?

How they will affect your genetics your breeding program?

How will they affect your children (Family)? They are finding that kids who live in the current area are suffering from all kinds of fears.

How will it affect your community?

How will it affect the economics of your business?

How will it affect wildlife on your place? If you also have a hunting operation, how will it affect that? Depredation?

How will they affect your pets? This needs to be addressed in detail, currently the 10J rule does not allow you to kill a wolf if it is attacking a pet dog or cat. You need to tell them this needs to be changed. Many of you have working dogs that you not only use as a tool to help on your operations, but are like kids to many people!

And while you are doing this. Ask them point blank, how they will MITIGATE these affects? They MUST answer how they will do this, according to the law. But don’t count on it! It at least sets precedence and allows you to pursue lawsuits if needed!

Remember, they don’t want emotions or opinions. They want direct solutions, unforeseen problems etc. So be concise and to the point. And again, Directly ask how they will fix it when and if it happens!

Also, be aware that the Department of Game and Fish will tell you that there is no good food source as far as game outside the Gila to support wolves! This leaves very little for them to prey on, other than your livestock and pets! Remember wolves are opportunistic predators. When they are hungry they will eat, they don’t care what it is. They will try to tell you they will only prey on the weak and sick. That is not true, they will prey on whatever they can catch and eat. Most don’t kill the animal immediately; they mostly take down an animal by hamstringing them. Then they will start to eat them before they are even dead. Most animals die from shock while being consumed.

**One thing I want to point out to everyone who thinks the 3S’s will work for you! When the wolves were first released, and the wolves started dying (if you look back you’ll realize that most of them were killed in and around the opening of hunting season and through it) all those who lived in the area of that killed wolf were harassed and investigated fully by Federal Law Enforcement! Guns were confiscated for ballistic tests and they were harassed relentlessly by the government and the EnviroNazis. Many threats along with death threats to them and their families. So don’t for a minute think the 3S’s are a solution to your problem!

Once you have written all this up, go to the links above and either copy and paste your comments or upload the document. Remember, they will publish it for all to see! So don’t put anything on there you don’t want to make public!