April __, 2007

Earthjustice argues that the FWS proposal to delist gray wolves in the Northern Rockies is illegal and biologically unsound. The organization contends that the proposed DPS boundaries are arbitrary, demographic recovery goals are set too low to ensure long-term viability, and state regulatory frameworks in Idaho, Wyoming, and Montana are inadequate to protect wolves from aggressive killing. Furthermore, Earthjustice asserts that the FWS failed to account for habitat fragmentation from roading, the loss of historic range, and the lack of guaranteed funding for management activities.

• The FWS's proposed Northern Rockies DPS boundaries are described as "boundaries of convenience" based on state lines rather than sound biological principles, encompassing areas that the agency itself admits are unsuitable for wolves.
• The demographic recovery goal of 300 wolves and 30 breeding pairs is argued to be too low for population viability; conservation biology suggests a minimum viable population (MVP) for gray wolves could be as high as 6,332 individuals.
• The FWS's claim that a functioning metapopulation exists is contested, with evidence suggesting limited interchange between the three recovery areas and a lack of suitable habitat in dispersal corridors.
• Road density is identified as a primary source of habitat fragmentation that increases human-caused wolf mortality and negatively affects the distribution of prey species like elk.
• The FWS's use of a thirty-year window for the "foreseeable future" is criticized as too short, with the document arguing that extinction risks should be evaluated over at least one hundred years, consistent with IUCN standards.
• Idaho's regulatory framework is deemed inadequate because it lacks specific population targets, allows for virtually unlimited killing under the term "unacceptable conflict," and provides no judicial review of state management plans.
• Wyoming's laws are characterized as an "affirmative threat" to wolves, as they classify wolves as "predatory animals" in most of the state, allowing for aggressive extermination methods including baiting and aerial gunning.
• Montana's regulatory framework is criticized for being a "plan to make a plan," lacking adopted regulations, and relying on a lower recovery standard (groups of four wolves) rather than breeding pairs.
• The proposal is argued to be illegal because it lacks a reliable source of funding for post-delisting management, with Idaho and Montana both indicating a reliance on federal funds.
• The FWS's contingency plan to delist only a portion of the Northern Rockies DPS if Wyoming fails to adopt adequate laws is asserted to violate the ESA, which does not permit piecemeal delisting below the DPS level.

APA

Earthjustice (n.d.). April __, 2007. https://earthjustice.org/wp-content/uploads/final-5-07-earthjustice-comment-letter-on-wolf-delisting.pdf

Chicago

Earthjustice. April __, 2007. n.d. https://earthjustice.org/wp-content/uploads/final-5-07-earthjustice-comment-letter-on-wolf-delisting.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=April __, 2007 |url=https://earthjustice.org/wp-content/uploads/final-5-07-earthjustice-comment-letter-on-wolf-delisting.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjusticendapril, author = {{Earthjustice}}, title = {{April \_\_, 2007}}, publisher = {Earthjustice}, url = {https://earthjustice.org/wp-content/uploads/final-5-07-earthjustice-comment-letter-on-wolf-delisting.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }