ACTION ALERT: US Fish and Wildlife Service concludes motorized recreation is primary threat to species despite conclusions which contradict research.
Research Unable to Establish Relationship Between Wolverine and Motorized Recreation
The decades long saga around management of wolverines has reached another critical point with the proposed listing of the wolverine as a threatened species. Motorized recreation has again been identified as a primary threat to the species, despite previous listings recognizing the minimal risk to the species from recreation.
Wolverine Court Challenges
This listing is a result of litigation that was settled in 2011 requiring a final decision on the ESA status wolverine by 2016. The US Fish and Wildlife (USFWS) proposed to list the wolverine in 2013 with significant protections for motorized recreation.
The 2013 listing was then again challenged in Court and withdrawn by the USFWS. The most recent USFWS Proposal asserts to be applying new research in the listing, as well as moving forward with the original 2013 listing of the species without mentioning possible conflict between these two efforts.
Research Contradicts US Fish and Wildlife Opinion of Motorized Recreation
Several critical pieces of the analysis identify research without addressing other efforts where conclusions contradict that research.
As an example, the Fish and Wildlife Service asserts motorized recreation is a threat to the species but a coalition of globally 17 recognized leaders in research have concluded they are unable to establish a relationship between wolverine populations and all human activity.
This is a problem type of arbitrary decision making is a problem. If recreation, particularly winter motorized recreation is identified as a threat to the wolverine we will lose riding areas and any project will be more difficult. These complications and lost opportunities will probably not generate any benefit to the wolverine.
Please Send Comments
Concerns For Your Comments in Opposition
Please rewrite in your own style to ensure your comments are not consolidated.
1. The entire proposal is a highly theoretical “worst case scenario” for the wolverine, that is only the result of many layers of supposition, unrelated research and theory being stacked upon each other. Courts have recently determined worst case scenario listings are not acceptable for decision making on species. Without an accurate population count how can any decisions be made?
2. Wolverine in the lower 48 states are proposed to be listed as a threatened distinct population segment in isolation from Canadian based populations. This is problematic as the primary driver of population decline in Canada is alleged over trapping, while US populations appear steady and stable. Possible Canadian overharvesting simply cannot be remedied by US management decisions.
3. Canada is currently reviewing trapping limits for wolverine in response to possible population declines. This should be the first management response to these declines as management changes thousands of miles away will not impact anything.
4. The Proposal fails to even address population estimates for similar locations in similar time periods. The Proposal uses estimates for the US populations from 15 years ago and then applies current Canadian projections of population declines that are from an entirely unrelated geographic area. This type of failure of logic is simply not sufficient to support any listing of a species.
5. Populations of wolverine are simply not provided by States other than Idaho, who asserts they have between 250 to 318 wolverine. Most states simply assert their population is stable, without noting any decline. This is a concern as the original estimate used in the listing was 250 in the lower 48. If researchers cannot come to some type of consensus on a population range for the species how can any determination of declines in populations be supported?
6. Previous protections for motorized recreation provided in 2013 listing should be returned for motorized recreation as current research indicates the overwhelming threat to the species is reduced snowfall and trapping. Decades of targeted research has failed to establish any relationship between dispersed recreation and wolverine populations. This research has only expanded since the 2013 listing.
7. The Proposal makes divisions of uses and impacts to wolverine that simply make no sense. The listing says developed ski areas don’t impact wolverines and divided highways don’t stop wolverine movement but dispersed recreation is elevated to a primary threat. This makes no sense at all.
8. The listing identifies dispersed recreation as a threat to the wolverine based on a single study of a road that is open to snowmobile traffic along with timber harvest actions, other industrial uses and private lands access. We must ask how was motorized recreation identified as the threat? One study about wolverine and recreation is simply insufficient to support this decision after decades of research has been unable to establish a relationship.
9. Wolverine researchers have concluded that snow compaction is a natural process and is not impacted by recreational activity at any significant level. These conclusions were published in 2021 but are not mentioned in the listing despite the assertion the listing is addressing new science.
10. The motorized community supports the decision not to identify critical habitat for the wolverine.
More information on these efforts
Where to file written comments:
Public Comments Processing
Attn: FWS–R6–ES–2023–0216;
U.S. Fish and Wildlife Service; MS: PRB/3W;
5275 Leesburg Pike;
Falls Church, VA 22041–3803
Where to file electronic comments:
Federal Register: Endangered and Threatened Wildlife and Plants; Threatened Species Status With Section 4(d) Rule for North American Wolverine
Deadline: Comments must be received or postmarked by Jan 29, 2024