Sally Stockwell
Maine Audubon
20 Gilsland Farm Road
Falmouth, Maine 04021

 26 September 2011

US Fish and Wildlife Service
4401 N. Fairfax Drive
MS 2042-PDM
Arlington, VA 22203

To Whom It May Concern:

Thank you for providing another opportunity to comment on the proposed rule regarding the gray wolf listing following the publication of vonHoldt et al’s 2011 article on wolf genetics.

Maine Audubon urges you to reject the proposed rule to revise the list of endangered and threatened wildlife for the gray wolf (Canis lupus) in the eastern United States and to initiate status reviews for the gray wolf and for the eastern wolf (Canis lycaon).  [Docket No. FWS-R3-ES-2011-0029; 92220-1113-111; ABC Code: C6]

Canis lycaon is not a separate species from Canis lupus so Canis lupus should not be removed from endangered species listing.

Delisting the gray wolf (Canis lupus) now while you study the status of the eastern wolf (Canis lycaon) presumes that Canis lycaon was the “historic” wolf in the east and is a different species than Canis lupus, therefore cannot be protected under endangered species listing for Canis lupus.

Recent genotyping of present and past wolves and coyotes from across the United States revealed that Canis lycaon is not a separate species but rather a wolf-coyote hybrid with more coyote genomes present than its western counterpart, most likely because eastern wolves were hunted to near extinction, and the few remaining wolves interbred with coyotes as they dispersed eastward (vonHoldt et al. 2011).

In addition, it seems likely that the wolf present in the early 1800s that was feeding primarily on moose and caribou must have been larger than the present day Canis lycaon, suggesting that the larger gray wolf (Canis lupus) inhabited the eastern U.S. before it was exterminated.

Because the gray wolf of the midwest, the eastern wolf of the northeast, and the red wolf of the southeast are all just genetic variants of Canis lupus, with more or less coyote genes mixed in (vonHoldt et al. 2011), they should all be treated as one species and protected as such under the Endangered Species Act.  This means that just because the population of wolves is healthy in Minnesota and Michigan, since that represents just a tiny fraction of its historic range in the eastern U.S., the gray wolf in this region cannot be considered recovered and should not be removed from endangered species listing.  The Minnesota and Michigan populations remain an important source for any further dispersal and colonization in the upper Midwest and even possible recovery in other eastern states.

Removing ESA protection for Canis lupus while studying the status of Canis lycaon leaves dispersing wolves with no protection.

If gray wolves are removed from listing under the Endangered Species Act for all or parts of 29 eastern states, then any wolf that disperses into the region from either Canada or the Midwest would be without any protection.  For Maine, this presents a real problem. At least seven wolves have dispersed from Canada into northeastern states during the past decade and several of these have been shot.  Dispersing wolves must be protected under the ESA to facilitate natural recovery.

Any status review of the eastern wolf and red wolf must only happen while maintaining current protections for all gray wolves under the ESA and should include a study not only of changes in genetics but changes in behaviors over time.

Eastern wolves and red wolves must not be removed from the endangered species list while a status review is conducted to better determine if they are separate species from the gray wolf.  Historical accounts of “eastern” and “red” wolves should be examined for a better understanding of how behaviors of wolves have changed over time – particularly in relation to available prey species – as a result of interbreeding with coyotes.  This may help shed additional light on whether or not to treat gray, eastern, and red wolves as different species, different subspecies, or all one species, and has implications for any future recovery efforts in the eastern U.S.  For example, it is highly likely that the Canadian eastern wolf of today is not the same as the eastern U.S. wolf of yesterday, either genetically or behaviorally, and that the Canadian eastern wolf would have a harder time competing with the eastern coyote than would the Great Lakes gray wolf, based purely on size.

Thank you for the opportunity to comment this proposed rule.

Sincerely,
Sally Stockwell
Director of Conservation

Citation:

Bridgett M. vonHoldt, John P. Pollinger, Dent A. Earl et al. A genome-wide perspective on the evolutionary history of enigmatic wolf-like canids.  Genome Research published online May 12, 2011.

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