HFW Official Comment on the USFWS delisting proposal

July 13, 2019


Public Comments Processing

Attn: Docket No. FWS-HQ-ES-2018-0097

U.S. Fish & Wildlife Service Headquarters, MS: BPHC

5275 Leesburg Pike

Falls Church, VA 22041-3803


To Whom it May Concern,

The following are the official comments offered by Howling For Wolves regarding the proposed delisting of the gray wolf, Docket No. FWS-HQ-ES-2018-0097.

Howling For Wolves is a Minnesota-based wolf advocacy group that formed in 2012 to oppose wolf hunting and trapping. Our mission is to educate the public about the wild wolf and to foster tolerance and understanding while we advocate for policies that ensure the wolf's survival for future generations. We advocate for nonlethal prevention methods to reduce wolf-livestock conflicts, and we believe more work is needed for the wolf to survive and thrive before removing federal protections. Minnesota is the only state in the Lower 48 with its original gray wolf population that never went extinct and its wolf population is vital for the recovery of the gray wolf species.  

Currently, the U.S. Department of Interior is proposing to remove federal Endangered Species Act protections for wolves throughout the entire U.S. If successful, states will conduct wolf hunting and trapping seasons. In addition to rifle seasons, wolves have previously been hunted with wire snares. In Wisconsin, wolf hunting has occurred year-round, at night, and using packs of dogs. The last time gray wolves in the Great Lakes region lost federal protections, in 2012, the Minnesota State Legislature hastily authorized a wolf hunting and trapping season to occur that same year, without even conducting a population estimate to determine whether the wolf population could tolerate losing those federal protections. Howling For Wolves supports protecting the gray wolf for future generations and vigorously OPPOSES any effort to remove federal protections for the reasons outlined below.

Howling For Wolves opposes delisting the gray wolf because the consequences of doing so will result in widespread killing of wolves. This is in direct conflict with the wishes of the majority of Minnesotans and American citizens. The alleged economic benefit of delisting claimed by a few special interests should not over-rule the will of the people. The Endangered Species Act’s very existence indicates that the wolves of America are a resource for all, not a trophy hunting target for a few. Clearly, the vast majority of Minnesotans oppose trophy hunting and reckless killing which invariably will occur when protections are lost. Instead, our citizens value wolves and want them protected for future generations. This was demonstrated in a 2013 Lake Research poll, where 79 percent of Minnesotans agreed that the wolf is an asset to protect for future generations. Even a Minnesota Department of Natural Resources (MN DNR) online survey showed 79 percent of Minnesota residents who participate in the survey responded “no” to wolf hunting. And yet the pressure by special interests on states to hold hunts overwhelm these agencies so they hold wolf hunts despite the public opposition. Thus, the federal protections are still needed.

Howling For Wolves opposes delisting the gray wolf because doing so will betray the relationship with Native American tribes that the federal government is obliged to honor. Most Minnesotans think wolf hunting and wolf persecution is cruel and inhumane. This is particularly true for many of Minnesota’s Native American tribes who regard the wolf as a sacred animal as it fulfills a significant cultural role.  This is also true for the Ojibwe people of northern Minnesota. All Ojibwe tribes in Minnesota have forbidden wolf hunting and have designated their lands as wolf sanctuaries. For the Ojibwe people, killing wolves is egregiously disrespectful.

Wolves in Minnesota should not be hunted for trophies out of respect for Native American beliefs. Hunting has occurred in every state where wolves were delisted, and will happen again if this delisting proposal becomes the rule. As part of its responsibility to Native American populations (as the Bureau of Indian Affairs is a division of the USFWS), the federal government should not delist the gray wolf.

Howling For Wolves opposes delisting the gray wolf because the reckless killing that has invariably occurred - and will occur again - will threaten the survival of the species in direct contradiction of the intent of the Endangered Species Act. Human killing of wolves disrupts wolf packs, creating unstable and unpredictable effects such as increased wolf-livestock conflicts. Wolf killing causes more pack member deaths beyond the actual wolf killed because the affected pack becomes fractured and cannot survive. The massive loss of social and genetic diversity by a recreational wolf hunting season cannot be overstated. The wolf depends on her pack to survive. They hunt animals that are much larger, and they require an entire pack to succeed. A wolf pack has one litter of pups per year and the entire pack raises the pups. Still, nearly half of all wolf pups die. In fact, the population estimates in Minnesota decreased by 25% after the first wolf hunt in 2012, and have not yet returned to 1998 levels.

Howling For Wolves opposes delisting of the gray wolf because of the reckless killing that would inevitably occur, leading to harm – and possibly irreparable harm - of the Minnesota forest ecosystem. Wolves are vital for a healthy forest as their presence ensures vegetation growth. Wolves are crucial to healthy habitat for all species from insects and pollinators to birds and even the moose. Without the wolf, forest habitat degrades for all species. This is why the wolf is currently being restored to Isle Royale. The forest is alive when the wolf is ecologically present. Scientists are among the first to push for restoration of the wolf to the Isle Royale National Park: there are still many benefits from the presence of wolves to be studied.

Howling For Wolves opposes delisting of the gray wolf because MN DNR population estimates indicating the wolf population has “recovered” are wildly uncertain at best, and possibly completely useless. Delisting of wolves is often justified by those in favor of it by repeating the mistaken belief that “we already have too many wolves.” These misinformed individuals cite the figure of 1600 wolves as the maximum that should be allowed to exist. This is not a maximum: it is the minimum number of wolves needed in Minnesota to provide some chance for survival of the species.

To make matters worse, the very system used by the Minnesota Department of Natural Resources (MN DNR) to estimate the wolf population is fraught with over-simplified assumptions, outdated methodology, and a consistent bias in the analysis that results in an over-estimate of the population.

The population numbers published by MN DNR each year are not based upon an actual count of wolves. Instead, the agency relies on a simple three-term equation to theoretically calculate their numbers.  The population of actual wolves upon which the “pack size” term of the simple equation model is based only number about 140. Yet the calculated population is on the order of 2500, with a wide range of uncertainty of plus or minus 700 wolves. Stated another way, over 90% of the wolves reported in the population estimate are the result of calculations, not observations. This method is susceptible to error and dramatic changes in the outcome with different assumptions or small changes in some variables, particularly the “pack territory” term. These findings are based upon a detailed statistical analysis undertaken by Howling For Wolves and performed by Elite Research, LLC, a statistical analysis firm based in Texas. The analysis also shows that better estimation techniques are available according to current scientific literature. Applying these better methods would result in a smaller population estimate in every case examined and suggests that the confidence implied by MN DNR’s use of these estimates for management purposes is vastly overstated. The MN DNR’s population estimates are 10% calculation, 20% extrapolation, and 70% speculation.

In the last two years, Howling For Wolves has also discovered that the input information for MN DNR population estimates is even less reliable than thought at the time of the aforementioned statistical analysis. For the last two years, large percentages of the wolves that were used as the basis for the “pack territory” term of the extrapolation have either gone missing or died. In 2017-2018, 4 collared wolves were marked "???," 7 marked “mortality,” 10 marked “missing,” 4 marked “failed/dropped.” That’s 48% out of 52 collared individuals that are the basis for the calculation, leaving 27 actual wolves upon which an inflated population of 2655 wolves was based, a mere 1% real wolves and 99% theoretical wolves.  In 2016-2017, 13 collared wolves were marked “mortality,” and 13 “missing” or “dropped.” That’s 49% out of 53 collared individuals, leading to a similar situation where the population estimate is based upon an actual wolf count amounting to, at best, a few percent of the total estimated wolf population.

Howling For Wolves opposes delisting of the gray wolf because the killing that will occur after delisting will destroy wildlife that provide an economic benefit to the State. Delisting will produce a net detriment to the economy, making the alleged economic basis for the proposed rule invalid. Having a state habitat with the wolf also creates significant economic value in Minnesota. A 1996 study showed the economic boost from wolves was $33 million per year just for Ely, Minnesota. Further, a 2011 United State Fish and Wildlife Service (USFWS) report highlights that Minnesotans spent $621 million on wildlife viewing. The wolf offers Minnesota an opportunity to distinguish our state as a home to a true wilderness. In fact, Howling For Wolves garnered international attention with people from as far away as New Zealand signing letters asking to stop the first wolf hunts.

Minnesota can be known as a wolf tolerant state and attract international tourists. The wolf is unique to our state and having the original population that never went extinct is a testament to our wild lands.  A trophy hunter can kill a wolf just once. Multiple visitors to Minnesota’s wild areas can hear a wolf howl or see one running over the ice many times, each time bringing the state an economic benefit.

Howling For Wolves opposes delisting of the gray wolf because the reckless killing that has invariably occurred will NOT benefit farming and ranching operations. Instead, it will make matters worse. Recreational wolf hunting and trapping is touted as a tool to decrease wolf-livestock conflicts. Yet, killing wolves, either in a recreational hunt or for livestock conflict, causes unstable packs of younger wolves. A December 2014 scientific study by Weilgus of Washington State University, found killing up to 25% of a wolf population resulted in increased predations on livestock the following year. When this happens, more wolves are killed, and the cycle does not stop until so many wolves die that they are no longer reproducing - a certain death spiral for the species. This effect has been proven in the data provided by the USDA Animal and Plant Health Information Services office located in northern Minnesota. Reported wolf-livestock conflict complaints increased after the first wolf hunting season. This impact on farming operations due to wolf killing has been well documented in multiple studies.

Howling For Wolves opposes delisting of the gray wolf because killing wolves will not improve matters and wolf predation is NOT economically significant in spite of claims to the contrary. Any economic loss can be reimbursed through State and Federal programs. These programs WILL END IMMEDIATELY if the wolf is delisted. In Minnesota, wolf-livestock conflicts are low. In 2017, there were 89 verified complaints of wolves at 76 sites in the state. Out of this, 76 calves/cattle were verified to be killed by wolves. Reimbursement is available for losses that can be verified as resulting from wolf predation. For the past two years and hopefully continuing, funding has been available through a pilot program from the Minnesota Department of Agriculture for farmers to purchase prevention methods including livestock guard animals, fladry, fencing, and other deterrents. This pilot project has earned the support of the agricultural community and now makes Minnesota eligible for federal matching dollars.

Howling For Wolves opposes delisting of the gray wolf because the killing that will occur after protections are removed will threaten the species’ survival, in very much the same scenario that threatened the bald eagle - our NATIONAL SYMBOL.  Rather than delist the wolf and then scramble to repair the damage as was the case with the eagle, wolves should not be delisted. The proponents of eliminating federal protections for the gray wolf justify their position by claiming significant economic harm and depicting the wolf as an evil predator that must be killed when and wherever possible. Most Americans believe quite the opposite. The abundance of artwork, promotional materials, T-shirt, hats, mugs, books, and even commercial use of the wolf (such as the Minnesota Timberwolves basketball team) all show that the wolf is regarded as a valuable national resource. The wolf is as much a part of the American spirit as the bald eagle, another critically endangered species saved by the Endangered Species Act. Even following the eagle’s removal from the Endangered Species List, an additional federal law was needed to prevent hunting the eagle after delisting. Fortunately for the eagle, the public’s attitude toward hunting eagles has shifted, but that additional protection is still needed to ensure the eagle will survive as a species. Today, the wolf faces a more hostile environment, even while under federal protection. The wolf must be protected by the Endangered Species Act until anti-wolf sentiments can evolve and “catch up” to the majority of American attitudes.


The people of Minnesota have made it clear, repeatedly, that they value the wolf as an asset that must be protected for future generations. As a representative of the vast majority of Minnesotans on this issue, we respectfully demand that the U.S. Fish and Wildlife Service immediately abandon any plans to delist the gray wolf.



Dr. Maureen Hackett, MD

Founder and President of Howling For Wolves

July 13, 2019