To: Maine Department of Inland Fisheries & Wildlife From: Northeast Wolf Coalition http://www.northeastwolf.org/ Date: August 11, 2014 Re: Proposed changes to the Maine List of Endangered and Threatened Species

The Northeast Wolf Coalition was organized in March 2014 as a new working group of partner organizations, scientific mentors and advisers who collaborate on critical issues that relate to the return of the wolf to the Northeast, including issues germane to the US Fish and Wildlife Service (USFWS) proposal to remove federal protections for gray wolves under the national Endangered Species Act (ESA). We have members and supporters across Maine, the Northeast, and the country. It is our understanding that the Maine Department of Inland Fisheries & Wildlife (MDIFW) is proposing recommended changes to Maine’s list of endangered and threatened species. We respectfully request consideration of the gray wolf as an addition to Maine’s Endangered Species list. In 2003, the U.S. Fish and Wildlife Service reclassified the gray wolf from endangered to threatened in the Northeast and eliminated the proposed Northeast Distinct Population Segment, virtually terminating any gray wolf recovery efforts in the region. The National Wildlife Federation, Vermont Natural Resources Council, Maine Audubon Society, and Maine Wolf Coalition (represented by Vermont Law School's Environmental and Natural Resources Law Clinic) alleged various violations of the Endangered Species Act and the Administrative Procedures Act, stemming from the federal government’s Final Rule to Reclassify the Gray Wolf. That same year, Defenders of Wildlife, RESTORE: The North Woods, Sierra Club and The Wildlands Project petitioned the USFWS to not abandon wolf recovery efforts in the Northeast. On August 19, 2005, the U.S. District Court for Vermont invalidated the rule and remanded it to the USFWS for reconsideration (National Wildlife Federation v. Norton, 386 F. Supp.2d 553 (D.Vt. 2005)). The National Wildlife Federation successfully argued that the administration improperly declared victory for gray wolf recovery based solely on the Northern Rockies and Great Lakes wolf populations, violating its Endangered Species Act obligation to recover endangered species across a “significant portion” of their historic range. The National Wildlife Federation also successfully argued that the administration violated its own Endangered Species Act policy on protecting “distinct population segments” and violated its legal obligation to obtain public comment on removing Endangered Species Act protection from the Northeast portion of the wolf’s historic range. This ground-breaking lawsuit against the U.S. Fish and Wildlife Service successfully challenged the attempt of the USFWS to walk away from a multiyear effort to restore the endangered gray wolf in the Northeast. It is important to note that a 2002 Survey coordinated by the Henry P. Kendall Foundation, “Nature Conservation in Northern New England,” found that wolves were linked to restoring a fully functional and wild ecosystem. From page 69 of the survey: “The survey examined basic attitudes toward the reintroduction of the wolf to the forests of northern New England. We find that a majority of residents in

both northern and southern New England correctly identifies the main cause of extinction of the wolf from the area as the hunting and killing of wolves (55% in both areas). About three in ten attribute the extinction to natural changes in the environment. When asked about bringing the wolf back to New England, six in ten northern New England residents (63%) believe it is important to reintroduce the wolf for the balance of nature in the area. Three in ten (30%) “strongly” take this position." At present, the gray wolf (Canis lupus) is on the federal Endangered Species list. However, the USFWS has proposed to remove federal protections for the species in the contiguous United States. In March, the Northeast Wolf Coalition submitted comments opposing this proposal. According to a peer review report by an independent panel of scientists produced by the National Center for Ecological Analysis and Synthes, the Service’s move to strip federal protection from nearly all gray wolves in the lower 48 states is flawed. The peer review committee reported that "there was unanimity among the panel that the [delisting] rule does not currently represent the ‘best available science.'” According to USFWS Specialist Mark McCollough, based in Orono, Maine, there are populations of wolves in Canada not far from the U.S. and wolves from other areas are occasionally found in the region. If they will no longer have federal protection, the states in the Northeast will be responsible for managing them. Presently in Maine, wolves are not given protection beyond a prohibition on hunting or trapping. Over the years, there have been numerous occasions when wolf-like animals have appeared in the region. In 2012, for instance, a wolf was shot in the Canadian province of New Brunswick, not far from Maine. Just this year, a trail camera captured photos of a large, wolf-like animal in Wilson's Mills, Maine, not far from the New Hampshire border. There are populations of wolves in Canada within 60 miles of the Maine border and according to Harrison and Chapin, "Substantial contiguous areas of forested habitat with road and human densities below the thresholds identified by Fuller et al (1992) occur within Maine…. These areas meet the criteria for defining potential core habitat..." (Harrison, Daniel J. and Theodore Chapin. 1998. Extent and Connectivity of Habitat for Wolves in Eastern North America. Wildlife Society Bulletin 26: 767-775.) Even the USFWS acknowledged in its Recovery Plan for the Eastern Timberwolf that sufficient habitat exists for wolves to repopulate in the Northeast (Wydeven et al. 1998). Yet, despite vast tracts of wilderness that are suitable for wolves in the Northeast, efforts to restore wolves to the region have never gotten off the ground. Individual wild wolves (either Canis lupus, C. lycaon, or their hybrids) have recently been recovered from the Northeast (Villemere and Jolicouer 2004; Kays and Feranec 2011). Such individuals — if they survive — could support a natural repopulation in the region similar to what occurred in the western Great Lakes region between the 1970’s and early 1990’s, where initial colonizers subsequently formed populations that allowed wolves to recolonize (Wydeven et al. 2009). Best science regarding wolf taxonomy and trophic cascades furnishes powerful evidence of our need to conserve wolves in the northeastern U.S. via ESA protection and other available policy and management tools. As Aldo Leopold, Adolph Murie, and others argued eloquently decades ago, apex predators, especially wolves, are essential in order to have resilient, healthy ecosystems. This is particularly true today, given climate change and habitat fragmentation.

We have unique opportunities and challenges in the Northeast. The Northeast Wolf Coalition is using the most current, peer-reviewed science to raise awareness and increase public understanding about wolves. A broad base of public support is necessary for wolves to recover and we remain committed to ensuring that stakeholders become active stewards in that regard. There are biological, economic, and ethical reasons to facilitate wolf recovery and our Coalition is eager to work with Maine’s Department of Inland Fisheries & Wildlife, area residents, and other appropriate agencies and organizations to promote the wolf's natural return to our region. The experts who form the Coalition are convinced that the preponderance of biological and societalcultural evidence indicates the wolf should unequivocally be listed as an Endangered Species and afforded any and all opportunity and effort for a full recovery based on the most current ecological principles and management techniques. Thank you for the opportunity to present these comments. We look forward to future discussions with your agency regarding these concerns. Respectfully submitted on behalf of the members and supporters of the Northeast Wolf Coalition,

Maggie Howell Maggie Howell, Coordinator Northeast Wolf Coalition http://northeastwolf.org Contact: [email protected] Members and Supporters

Adirondack Council, Adirondack Wild, Adirondack Wildlife Refuge, American Ecological Research Institute, Center for Biological Diversity, Cougar Rewilding Foundation, Earthjustice, Endangered Species Coalition, Maine Wolf Coalition, Predator Defense, Project Coyote, Protect the Adirondacks, Red Wolf Coalition, RESTORE: The North Woods, Vermont Law School, Wildlands Network, Wolf Conservation Center