Arizona Cattle Growers’ Association November 26, 2013
Proposed Rule Removing the Gray Wolf (Canis lupis) from the List of Endangered Species and Maintaining Protections for the Mexican Wolf (Canis lupis baileyi) by Listing It as Endangered Docket No. FWS-HQ-ES-2013-0073 Link to ACGA Comments Comments on the Proposed Mexican Wolf Nonessential Experimental Population Rule Docket No. FWS-R2-ES-2013-0056 Link to ACGA Comments
All Comments Due on December 17, 2013
We encourage all members to attend and express their opinion. The environmental community is operating in full force and will no doubt try to pack the room. We need to do the same. All comments will be put into the record. WE MUST TELL OUR STORY!!! Public Hearing December 3, 2013, from 6 p.m. to 8:30 p.m., in Pinetop, AZ-Hon Dah Conference Center
ACGA is working with Norm James, ESA Attorney at Fennemore Craig, and Terry Johnson, former ESA Director for the Arizona Game and Fish Department. Both individuals have over 20 years of experience in their respective fields. In addition, ACGA organized a coalition of sportsmen, counties, USDA-APHIS and AZ Game and Fish to work on the wolf issue. These coalition comments can be viewed here. These comments are focused on more general points to create a unified front amongst the organizations that are interested in the wolf.
Executive Summary for the Delist and Relist Rule:
- ACGA fully supports the Delisting of the gray wolf.
- ACGA would like the USFWS to keep the listing as is for the Mexican Wolf (Non-essential)
- The Service will not fully delist the Mexican Wolf because we do not have the science to prove the taxon of the Mexican Wolf is the same as the Gray Wolf, in addition, we have not met the goals of the 1982 Recovery Program
- We must focus our argument where we can make a credible and legal argument. Keep the Mexican wolf the same Non-Essential Experimental so that we can manage under the 10j rule.
- ACGA also believe the USFWS should have never listed the Gray Wolf in the beginning and should have never included the Mexican Wolf in the delist rule. The Mexican could have been dealt with administratively making the rule less convoluted.
Executive Summary for the 10j Rule
- We urge the service to withdraw the proposal of this rule and follow all rules and regulations. 10j regulations require the Service to work with State and Tribal officials when developing these rules and they have failed to do so.
- ACGA has supplied a modified 10j rule from the gray wolf as a suggested starting point. The wolf program is finished in the Northern US why are we not using the same or similar rules for the Mexican Wolf.
- ACGA opposes the expansion of the Blue Range Wolf Recovery Area.
- The Service as failed to express the need for expansion of the area. They do not have the biological science to support expansion.
- The USFWS fails to provide clear and precise goals and direction in the 10 j leaving to much room for litigation.
- The USFWS must provide clear management direction that everyone can understand.
- ACGA strongly opposes the occupancy of any wolf in the Mexican Wolf Experimental Population Area. (Light gray area on maps between I-40 and I-10)
- ACGA does suggest an expansion of the Mexican Wolf Experimental Population Area to the Mexican Border ONLY if wolves are not permitted to occupy the area. This expansion would allow for management of wolves that wander from Mexico.
- ACGA believes the Arizona Game and Fish should take over the program at this time.
- ACGA believes the approach of the USFWS on these rule making packages are wrong and should have been performed in a more systematic approach allowing adequate time for review and comment.
- The USFWS has shown a lack of leadership and direction on this program coupled with wasting millions of tax payers dollars they should not continue to operate the program.
- The process is completely flawed and USFWS is driving this because of sue and settle tactics by the environmentalists to meet a deadline in January 2015 on a full EIS that is not possible.
- Once again the American public is left to foot the bill of a mismanaged program and the local communities are left to suffer.
- USFWS have designed a program and rule package that is again destined for failure.
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