November 20, 2003
The Honorable Gale Norton
Secretary of the Interior
Department of the Interior
1849 C Street, NW
Washington, DC 20240
Dear Secretary Norton:
We write to register our concern regarding recent litigation on the decision to upgrade the status of gray wolves from threatened to endangered. With regard to the wolf population in the northern Rocky Mountains, the decision being challenged was sound and timely, if not overdue, and we support it. We urge a full and vigorous defense and also recommend your attention to an important related policy issue.
Species conservation policy has fallen behind the needs for wolf management in the northern Rockies. Wolf reintroduction began with the premise that recovery is a hands-on project, requiring that wolves be captured, relocated, physically deterred from conflict with livestock, and sometimes killed (59 Fed. Reg. 60266). The Endangered Species Act, however, is a hands-off statute. Special rules were required to authorize the necessary handling of wolves, and the rules required every precaution so that management would not accidentally harm the small, newly-reintroduced wolf population (50 CFR 17.84(i)). Under these special rules the wolves have flourished. The latest official numbers - which are one year out of date - estimate conservatively that nearly 700 wolves in more than 40 packs inhabit the northern Rocky Mountain area. Even these minimum numbers from the Service represent more than twice the overall growth that the Service expected in each reintroduction area. Now that the wolf population is large and established, the painstaking procedures for wolf management must be updated so managers can work faster and more effectively. As Governor Kempthorne of Idaho has said, "the wolves have done their part biologically; now we must do our part bureaucratically."
We understand and appreciate your position that - based on the findings of the U.S. Fish and Wildlife Service - wolves have surpassed their recovery goals in the northern Rockies and should be considered for de-listing under the Endangered Species Act. We also believe that interim steps may be necessary. The recent new litigation affirms that the de-listing process can be easily disrupted, and likely will be disrupted at every step. The price of delay is borne in part by the wolf population, which is now so large that it cannot be managed effectively under current rules. We understand that Idaho, Montana, and Wyoming have all either finalized or soon will finalize state wolf conservation policies. We urge you to find ways to include these state management programs in the authority for wolf management during the potentially long period of time between now and the de-listing of wolves under the Act.
Sincerely,
Senator Mike Crapo
Senator Larry Craig
Senator Conrad Burns
Senator Gordon Smith
Senator Max Baucus
Senator Craig Thomas