I cannot say I was surprised by the recent peer review report on wolf delisting from a panel of independent scientists. They unanimously concluded that the U.S Fish and Wildlife Service's (the Service) proposal to strip federal protections for gray wolves across nearly all of the lower 48 states was not supported by the best available science. Ever since the Service announced its delisting proposal, scientists, conservation groups and concerned citizens have been telling the Service that the delisting proposal is premature and shortsighted, and above all, based on bad and incomplete science.
But my lack of surprise does not make the panel's findings any less egregious; the Endangered Species Act (ESA) expressly requires that listing and delisting decisions be made only on the basis of the "best available science." Now, the wolf peer review report proves that the Service has failed to properly implement the ESA because it did not use the best available science to guide its decisions on wolf recovery.
I was director of the U.S. Fish and Wildlife Service from 1997 -2001 and have over 30 years of experience with the ESA. Needless to say, I know what it's like to make tough calls on species listing and delisting decisions. But no matter how difficult these decisions were in the past, we always based them on the best available science and an optimistic vision of what species recovery should mean. The gray wolf delisting proposal represents a disappointing and flawed departure from the scientific standards that we embraced when I used to work for the Service.
It's not uncommon for peer review panelists to disagree among themselves during the peer review process. In fact, it's the job of any peer review committee to raise questions and concerns about the science underpinning the issue or proposal under review. But what was most remarkable about the unanimous panel conclusion repudiating the Service's science is that the panel had members who professionally disagreed over the underlying policy question of whether wolves should be delisted at all. Thus, despite their differing views on delisting itself, they found themselves in agreement that the science relied upon by the Service was seriously flawed.
In this case, the peer reviewers criticized the Service for relying on just a single scientific report, the Chambers et al. analysis, as the basis for their delisting proposal. They pointed out that that study was highly selective in the data it used. Evidence that did not support the proposal to delist was criticized and dismissed by Chambers et al., whereas evidence that supported the proposal to delist was accepted uncritically. Peer reviewers also said the Service got the taxonomy and range of wolves all wrong in their delisting proposal. For example: gray wolves may have lived in the Northeast, wolves of the Pacific Northwest are likely distinct from other populations, and Mexican gray wolves historically had a much larger range than the Service claimed.
The process used to generate and publish the Chambers study was also problematic. The study was written by scientists from the Service itself and was only published in a Service publication and not by a respected independent journal as one would expect. Mysteriously, the Service's publication had been defunct for more than 20 years and seemed to have been brought back to life to publish this paper.
If this peer review process tells us anything, it tells us - yet again - that the Service is not treating wolves in the same way it treated the recovery of the bald eagle, peregrine falcon or the American alligator. Each of these species reached recovery throughout their range before being taken off the endangered species list. There is still much unoccupied suitable habitat available for wolves. Delisting should not be considered until wolves reach true recovery.
So now, the Service needs a dramatic mid-course correction on wolves. At each step of this delisting proposal - written comments, public hearings and testimony and now the peer-review process - the Service's delisting proposal has been called into question for being premature and based upon bad science. Secretary of the Interior Sally Jewell and U.S. Fish and Wildlife Service Director Dan Ashe have repeatedly asserted that the Service will base decisions on the status of wolves only on the best available science. In light of this damning peer review report on wolves, the Service should withdraw its current delisting proposal, and instead chart a sustainable recovery path for wolves that is truly based upon the best science on the subject.
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