Mexican Wolf Blue Range reintroduction project 5-year review

              Mexican Wolf Reintroduction Project
Mexican Wolf Blue Range Reintroduction Project 5-Year Review
Prepared by the Mexican Wolf Blue Range Adaptive Management Oversight Committee and Interagency Field Team



December 31, 2005



Terry B. Johnson, AGFD 2221 W. Greenway Road Phoenix, AZ 85023-4399 602/789-3707 Chuck Hayes, NMDGF PO Box 25112 Santa Fe, NM 87504 505/476-8101 David Bergman, USDA-WS 8836 N. 23 Ave., Suite 2 Phoenix, AZ 85021 602/870-2081 Wally Murphy, USFS 333 Broadway Blvd., SE Albuquerque, NM 87103 505/842-3194 John R. Morgart, USFWS 2105 Osuna Rd, NE Albuquerque, NM 87113-1001 505/761-4748 John Caid, WMAT PO Box 220 Whiteriver, AZ 85941 928/338-4385



December 31, 2005



RECOMMENDED CITATION Mexican Wolf Blue Range Adaptive Management Oversight Committee and Interagency Field Team. 2005. Mexican wolf Blue Range reintroduction project 5-year review. Unpublished report to U.S. Fish and Wildlife Service Region 2, Albuquerque, New Mexico.



ACKNOWLEDGMENTS Completion of the 5-Year Review has been a result of effort and contributions from far too many people to mention by name. First and foremost, the Adaptive Management Oversight Committee and the Interagency Field Team thank all who contributed to the 3-Year Review that set the stage for this effort. Whether you were authors of components of that review or interested parties or stakeholders, you provided a rich foundation for us to work with. We also thank all Lead Agency employees, including the Directors, for persistent, enthusiastic support whenever it was needed; we will not identify any of you by name, lest we overlook anyone. Yet, two individuals must be mentioned by name � we thank Hector Ruedas and Kay Gale of Greenlee County AZ for going way above the call of duty to contribute in so many ways, not the least of which was those endless conference calls toward the end of the process. Truly, you set the bar for excellence as public servants, ably and assertively yet always constructively representing the interests of your Greenlee County constituents while still keeping a broad focus on "what's best for the public." Last but not least, we thank each and every member of the public, whether affiliated agency or NGO representative or private individual, who took the time to express their opinions about Mexican wolf reintroduction during this review, or in previous interactions that also contributed to it. Whether you submitted a form letter, post card, or email, or a personal verbal or written indication of your beliefs, opinions, or preferences, your thoughts were invaluable to the review and were considered very carefully before decisions were made. Knowing what people think overall about Mexican wolf reintroduction and recovery (an overwhelming majority of respondents favor it) was as important in its own way as knowing specifics about what individuals believe is working well in the reintroduction effort and what they think needs to be improved. For those who provided substantive specifics not just on what "to fix" but on how to fix it, we are especially thankful.



PREFACE Mexican wolf reintroduction has been prominent in the American public's eye since long before January 28, 1998, when the first captive-reared wolves were placed in acclimation pens in the Blue Range of east-central Arizona and west-central New Mexico for eventual release to the wild. Nor did controversy end with the first release. The mass media have been rich with Mexican wolf-related stories for more than 20 years, and references to ongoing controversy run rampant through them. Entire books, and parts of others, have been devoted to the subject; among the more prominent examples are: Brown (1983), Burbank (1990), Grooms (1993), Holaday (2003), Nie (2003), and Robinson (2005). In stark contrast, the definitive book on wolf ecology, L.D Mech's (1970) "The wolf: the ecology, and behavior of an endangered species," includes just a few lines about the Mexican wolf, reflecting a personal communication from B.R. Villa: In Mexico, the wolf is now restricted to three distinct areas....but the population is still declining and is in danger of extinction (Villa 1968)." Mech's book makes even less mention of the Mexican wolf's occurrence in the United States, from which it had long since been eradicated as a viable breeding species. But, the final tale is yet to be told, because the journey continues today. Reintroduction is underway, and perhaps recovery might yet be achieved. Whether reintroduction and recovery should be allowed, and if so where and how, were hotly debated through the 1990s, when reintroduction was formally proposed. They still are. Regardless, the proposal process ended with an affirmative decision pursuant to a Final Environmental Impact Statement (hereafter FEIS; USFWS 1996); a Record of Decision (hereafter ROD; USFWS 1997) pursuant to the National Environmental Policy Act (NEPA) of 1969; and finally a nonessential experimental population rule (hereafter Final Rule; USFWS 1998) approved on January 12, 1998, pursuant to the Endangered Species Act (ESA) of 1973, as amended. In keeping with the stated experimental nature of the reintroduction effort, and respectful of the doubts expressed by many, the Final Rule required full evaluations after 3 and 5 years to recommend continuation, modification, or termination of the Reintroduction Project. The 3-Year Review, conducted in 2001, concluded that reintroduction should continue, albeit with important modifications (Paquet et al. 2001; Kelly et al. 2001). However, as we discuss elsewhere in this report (e.g. AMOC Responses to Public Comment Component), for many reasons the 3-Year Review recommendations were not implemented, at least not to the extent that interested parties and stakeholders expected or desired. Regardless of cause, the apparent lack of closure was a significant agency and public concern when the time came for the next review. 5-Year Review By agreement among the primary cooperating agencies, responsibility for the Reintroduction Project's 5-Year Review fell to the Mexican Wolf Blue Range Adaptive Management Oversight



Committee (AMOC) that oversees the Project on behalf of six Lead Agencies and various formal and informal Cooperator agencies. AMOC Lead Agencies include the following: Arizona Game and Fish Department (AGFD), New Mexico Department of Game and Fish (NMDGF), USDAForest Service (USFS), USDA-APHIS Wildlife Services (WS), U.S. Fish and Wildlife Service (hereafter USFWS or Service), and White Mountain Apache Tribe (WMAT). Formal Cooperator agencies active in the review include the following: Greenlee County (AZ) and the New Mexico Department of Agriculture (NMDA). The Project's Interagency Field Team (IFT) also contributed significantly to the review, especially the technical aspects. AMOC and the IFT conducted the 5-Year Review to comply with the Final Rule, but above and beyond that the intent was to identify and implement improvements in the Project. The Review consists of several primary components: Administrative, Technical, Socioeconomic, and Recommendations. Each is detailed in this report. Regardless of implementation issues, the 3-Year Review's technical component (i.e. Paquet et al. 2001) and stakeholder component (Kelly et al. 2001) were excellent departure points for the 5Year Review. Both were rich with information. Unfortunately, conflicts within and among their recommendations were never resolved, so this added complexity to the 5-Year Review. The Draft Administrative and Technical Components of the 5-Year Review primarily addressed the period of January 1998 through December 31, 2003 (available information for 2004-2005 was also incorporated as it became available, and if was useful to include it. The Administrative and Technical Components were released for public comment in December 2004. Contract glitches with the Socioeconomic Component caused its release to be delayed until April 26, 2005. The public comment period for the 5-Year Review extended from January 2005 through July 31, 2005. More than 10,000 written comments were received on the Draft Review and related documents, including Standard Operating Procedures and a Proposed Moratorium for the Reintroduction Project. Additional comments were heard at 14 public meetings from January through June 2004. All comments received, whether they were written or verbal, were carefully considered in completing the final report. AMOC conducted the 5-Year Review on behalf of all agencies cooperating in the Reintroduction Project, but responsibility for its rigor and contents resides solely with AMOC. None of the cooperating agencies constrained the review; in fact, all of them were highly supportive of an objective, comprehensive analysis. The 5-Year Review serves several primary purposes with regard to the Final Rule and previous reviews of the Reintroduction Project, including evaluating: 1. Questions identified in the 1998 Mexican Wolf Interagency Management Plan (Parsons 1998). 2. Recommendations and suggested modifications from the 3-Year Review technical component (Paquet et al. 2001) and stakeholder component (Kelly et al. 2001).



3. Recommendations from the Arizona-New Mexico independent review of the 3-Year Review that was directed by Congress (AGFD and NMDGF 2002). 4. "Commission Directives" to the State Wildlife Agencies of AZ and NM (Attachment 1). 5. All aspects of the Reintroduction Project from 1998 through 2003. 6. All public comment received during AMWG meetings and written comment periods from January through July 2005. Review and adaptive management of the Reintroduction Project will not stop with this review. Project cooperators will continue to seek internal and public input regarding Mexican wolf reintroduction to help achieve recovery goals and objectives. The public input sought through this 5-Year Review analysis is an important part of that process. Wrestling with implementation issues will perhaps be even more important. Thus, we look forward to high levels of engagement in public meetings throughout the Blue Range area in 2006 et seq., as we strive to move forward with this Reintroduction Project, and contribute toward recovery and eventual delisting of the Mexican wolf. Adaptive Management Oversight Committee December 31, 2005



Mexican Wolf Blue Range Reintroduction Project 5-Year Review: Administrative Component

by Adaptive Management Oversight Committee Arizona Game and Fish Department New Mexico Department of Game and Fish U.S.D.A. � APHIS, Wildlife Services U.S.D.A. Forest Service U.S. Fish and Wildlife Service White Mountain Apache Tribe



December 31, 2005



ABBREVIATIONS, ACRONYMS, AND TERMS The following abbreviations, acronyms, and terms have been used to help make this document readable. We regret any inconvenience this creates for readers who do not like this approach. AGFD AMOC AMWG APA AC ARC ARPCC AUM AZ BLM BRWRA CBD CBSG C/R CV CWD CY DEA Defenders DPS EIS ESA EQIP EPA FAIR FEIS Final Rule FMD FOIA FR FTE FY GMU IFT IMAG IMPLAN MOU MWEPA NEPA Arizona Game and Fish Department Adaptive Management Oversight Committee Adaptive Management Working Group Administrative Procedures Act of 1946 Administrative Component AMOC Recommendations Component AMOC Responses to Public Comment Component Animal Unit Month Arizona Bureau of Land Management Blue Range Wolf Recovery Area Center for Biological Diversity Conservation Breeding Specialist Group Comment/Response entries (611 total) Current Value Chronic Wasting Disease Calendar Year Draft Economic Analysis Defenders of Wildlife Distinct Population Segment Environmental Impact Statement Endangered Species Act of 1973, as amended Environmental Quality Incentive Program Environmental Protection Agency Fort Apache Indian Reservation Final Environmental Impact Statement of 1996 (for proposed reintroduction of Mexican wolves) Final "nonessential experimental population" or "10(j)" rule of 1998 (for Mexican wolf reintroduction in Arizona and New Mexico) Foot and Mouth Disease (hoof and mouth disease) Freedom of Information Act of 1966 Federal Register Full Time Employee (or Full Time Equivalent) Fiscal Year Game Management Unit Interagency Field Team (for the Reintroduction Project; see below) Interagency Management Advisory Group (for the Mexican wolf) USFS IMPLAN Model Memorandum of Understanding Mexican Wolf Experimental Population Area National Environmental Policy Act of 1969



NGO NM NMDA NMDGF NRCS PRIA PVA ROD SCAR SCAT SEC SOP SSP SWCD SWDPS TC TESF US or USA USDA USDA-APHIS USFWS USFS WMAT WS WSMR WTP YNP



Non-Governmental Organization New Mexico New Mexico Department of Agriculture New Mexico Department of Game and Fish Natural Resources Conservation Service Public Rangelands Improvement Act of 1978 Population Viability Analysis Record of Decision of 1997 for the 1996 FEIS (see above) San Carlos Apache Reservation San Carlos Apache Tribe Socioeconomic Component of 5-Year Review Standard Operating Procedure for the Reintroduction Project Species Survival Plan Soil and Water Conservation District Southwestern (Gray Wolf) Distinct Population Segment (emphasis on Canis lupus baileyi, the Mexican wolf) Technical Component of 5-Year Review Turner Endangered Species Fund United States of America United States Department of Agriculture USDA-Animal Plant Health Inspection Service U.S. Fish and Wildlife Service USDA Forest Service White Mountain Apache Tribe USDA-APHIS Wildlife Services White Sands Missile Range Willingness-to-Pay Yellowstone National Park (and environs)



Mexican Wolf Blue Range Reintroduction Project 5-Year Review: Administrative Component

by Adaptive Management Oversight Committee INTRODUCTION The 5-Year Review Administrative Component evaluates the following: (a) Administrative questions identified in the 1998 Mexican Wolf Interagency Management Plan (Parsons 1998); (b) Organizational recommendations from the 3-Year Review technical component (Paquet et al. 2001) and stakeholder component (Kelly et al. 2001); (c) Recommendations from the AZ-NM independent review of the 3-Year Review that was directed by Congress (AGFD and NMDGF 2002); and (d) "Commission Directives" to the State Wildlife Agencies of AZ and NM following discussion of the States' independent review (see Attachment 1). Each question, comment, or recommendation below is accompanied by a Status statement indicating that the task it represents is: (a) Completed; (b) Not completed but being implemented and necessary to complete (followed by an assessment of the task and an estimated completion date), or Not completed because it is a continuing need that is being addressed, or Not completed; no action but necessary to complete; or (c) Not considered necessary to complete or to implement (followed by an assessment of why completion/implementation is not necessary). Each entry or item concludes with a 5-Year Review "Finding." 5-YEAR REVIEW ISSUES, ASSESSMENTS, AND FINDINGS A. A-1. Administrative questions identified in the Mexican Wolf Interagency Management Plan (Parsons 1998). Is effective cooperation occurring with other agencies and the public?



Status: Not completed but being implemented and necessary to complete. Assessment: Kelly et al. (2001) and AGFD and NMDGF (2002) noted that neither agencies nor the public were satisfied with the level of internal or external cooperation in the Reintroduction Project. In September 2002, the Arizona Game and Fish Commission and the New Mexico Game Commission directed their respective wildlife agencies to include improved interagency and public cooperation as a focal point of efforts to restructure and improve the Reintroduction Project. After a year of agency and public discussion, AMOC was created in October 2003 to help achieve that objective. As noted elsewhere in this document (see the AMOC Responses to Public Comment Component), AMOC believes interagency cooperation has vastly improved since 2001 (although AC-1



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NM and some AZ counties still do not participate) and cooperation with permittees has also improved (but again there is much room for further improvement). A draft 2005 statewide public survey in AZ and NM (Responsive Management in prep.; 1514 respondents, sampling error �2.5%) indicated a majority of respondents (67%) had heard about Mexican wolf reintroduction. Of the respondents who had heard about it, 73% were somewhat familiar with it. Among all respondents, 62% favored reintroduction and 13% opposed it. Most respondents (up to 83%) were not sufficiently informed about reintroduction to have an opinion on levels of cooperation. Although most did not know how effective or ineffective cooperation is within the Project or between the Project and the public, respondents were more likely to respond they were effective than ineffective, except cooperation with the public. In the latter area, 19% said it is very or somewhat ineffective and 20% said it is very or somewhat effective. We also note that 25% of respondents in the above-referenced survey said the responsibilities of the cooperating agencies, programs, and counties are now well, or at least adequately, defined, and 68% of those 25% respondents believe those responsibilities are serving the Project's needs. An area of special concern to the public, as evidenced in comment at AMWG meetings as well as in written comment on the 5-Year Review, is the relatively large number of apparently unlawful wolf mortalities since 1998. From 1998 through 2005, 25 wild Mexican wolves succumbed to gunshots; two of the incidents were resolved (one through a finding of self defense and the other through successful criminal prosecution, but the other 23 investigations remain open. Discussion of specific aspects of active investigations is precluded, but AMOC has itself expressed concern about the need to ensure that all available enforcement resources within the cooperating agencies are used effectively and efficiently in preventing as well as addressing unlawful take of Mexican wolves. Finding: Clearly, much work remains to be done in regard to improving cooperation with the public (including defining what such "cooperation" entails). Also, existing levels of interagency cooperation need to be maintained and enhanced (e.g. general cooperation as well as law enforcement issues), and additional effort needs to be put into increasing cooperation with counties other than Greenlee County AZ, which is a full and constructive participant in every aspect of the Project. Toward that end: 1. AMOC will maintain and improve administrative and adaptive management processes for the Reintroduction Project to enhance meaningful opportunities for, and participation by, the full spectrum of stakeholders and interested parties. AMOC efforts will include meeting with the IFT twice each year at the Alpine field office, and offering to meet once each year with the Commission or Board of Supervisors for each County within the Blue Range Wolf Recovery Area (BRWRA). 2. AMOC will direct Reintroduction Project-related outreach efforts in 2006 through the IFT Annual Work Plan to identify and reach specific target audiences, with emphasis on local communities and cooperating agencies within the BRWRA (>75% of outreach activity) and outside the BRWRA (<25% of outreach activity). AC-2



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3. AMOC will identify no later than June 30, 2006, in a confidential report to USFWS, any law enforcement actions that might help prevent unlawful take of Mexican wolves or help achieve closure on existing active investigations. A-2. Are combined agency funds and staff adequate to carry out needed management, monitoring, and research?



Status: Not completed but being implemented and necessary to complete. Assessment: The 3-Year Review identified a lack of resources essential to carrying out needed management, monitoring, and research. For example: management activities were constrained by insufficient staff to carry them out; annual reports, work plans, incident analyses, and operating procedures were not completed due to higher priorities for existing staff; local residents asserted they could not reach an IFT member when assistance was needed; public outreach languished as staff tried to manage the increasing number of released and free-ranging wolves; vehicles were in short supply, and most that existed were high-mileage disposal trucks close to or beyond their useful lifespan when assigned to the Project; some IFT members worked out of their homes due to lack of office space; the trailer housing the Alpine Field Office was questionable in terms of structural stability; monitoring was limited by availability of flights, which reflected limited air support and lack of funds to ensure that flight time could be increased to more fully meet Project needs; and basic questions about wolf movements and behavior, impacts on native and domestic prey, wolf relationships to total predator load, and all aspects of the human dimensions (sociocultural and economic issues), etc. remained unanswered due to lack of funding. This does not mean, however, that the Project's budget was inconsequential during this period. In fact, the cooperating agencies estimate (Table 1) that from FY1998 through FY 2004 they spent a combined $7,543,598 on wolf-related activities, including expenses associated with captive breeding and the over-arching rangewide recovery program, as well as the AZ-NM Reintroduction Project. When the two State Wildlife Agencies conducted an independent review of the 3-Year Review (see AGFD and NMDGF 2002), the lack of essential resources was still obvious. Thus, both State Wildlife Commissions endorsed a recommendation that USFWS "Restructure the Interagency Field Team response protocols, and enhance staff capacity to ensure immediate response capability to, and resolution of, urgent operational issues, such as depredation incidents." However, the situation did not improve much over the next two years, as the agencies began to restructure the Project. In fact, by late 2003 the pressures of cutbacks in Federal agency budgets began forcing States to either pick up the increasing funding shortfall or allow further decay in the IFT's ability to carry out its responsibilities. The partners had not begun trying to build an overall IFT budget to jointly expand the pool of available resources by December 31, 2003, the end of the period on which the 5-Year Review is primarily focused. Consequently, the available



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resources were not always shared effectively, and Project accomplishments and public and agency acceptance and satisfaction were appreciably hampered. Staff shortfalls in the Project have also been exacerbated by turnover throughout the Project. Given that the agency budgets for this Project are one-year commitments at best, and often are not fully resolved until well into the Fiscal Year, Project personnel have had an understandable degree of uncertainty as to their employment status. This has induced several IFT employees to leave the Project for more stable positions elsewhere, often with wolf management projects in other states or organizations. Disparities in State and Federal salaries for Field Team members have also contributed to dissatisfaction, and eventual vacancies. Government hiring processes tend to extend vacancy periods, imposing even greater workloads on remaining employees who are already stretched to or beyond their limits. The situation improved in 2004, as AMOC began to work more effectively as a collaborative effort under the October 2003 Project MOU. Initially that year, progress was again impeded by delayed Congressional approval of the Federal budget (i.e. USFWS did not receive its FY2004 allocation until June 2004; FY2004 began in October 2003), and further cutbacks (excluding salaries) in USFWS wolf budgets. However, in February 2004, under the new MOU, the Lead Agencies began building a joint Annual Work Plan and an overall budget for the year in progress. Unfortunately, available funds were not sufficient to cover full-time equivalent (FTE) needs (a total of 14.25 personnel) identified in the Project's (first joint) Annual Work Plan. Considerable progress was made in 2004 and 2005 as cooperating agencies brought more resources to bear, despite continued delays and cutbacks at the Congressional level. However, disparities in individual agency contributions continued to result in disparities in IFT resources available to address on-the-ground management issues in AZ vs. NM. The disparities in FTEs and the budget shortfalls had not been fully resolved as this 5-Year Review was completed. Thus, although the IFT and the cooperating agencies are increasingly working as a team, allocating IFT staff resources to a pressing issue of the day still means that other essential priorities, especially long-term issues and public expectations, are deferred beyond the prescribed response deadline or completion date. The same applies to the agency employees providing administrative oversight for the Project, and conducting the adaptive management program and contributing to this review. Other than most of the USFWS employees directly involved, and all the IFT employees except WS personnel, none of the agency staff are assigned only to the Project. Most have at best a small percentage of their work week available to address Project issues, which continues to cause delays in completing Project-related assignments and shortfalls in carrying out needed management, monitoring, and research. In addition to staffing funding issues, lack of a governmentally funded and administered program to address livestock depredation losses remains a huge impediment to local acceptance of wild Mexican wolves. Such a program would not eliminate opposition, but it would separate those who are adamantly opposed regardless from those who are opposed at least in part because they bear brunt of the real (i.e. documented) and perceived (i.e. undocumented or speculative) economic impacts of reintroduction. AC-4



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Insufficient resources have been significant problems to date in this Project, but the issue is even more problematic for the future. The reintroduced population is at a point at which exponential population growth might reasonably be expected. As the number of free-ranging wolves increases, and recovery and delisting are approached, management issues will increase proportionately. If those needs go unmet, public dissatisfaction, especially among local residents who are most affected by the Project, will inevitably sky rocket. Finding: Significant infusion of funding is essential to sustaining progress toward Project objectives, thus to contributing toward wolf recovery. Toward that end: 1. AMOC will develop, no later than June 30, 2006, a report describing a proposed Federally, State, and/or Tribally-funded incentives program to address known and potential economic impacts of wolf nuisance and livestock depredation behavior on private, public, and Tribal Trust lands. AMOC may convene, if necessary, a technical advisory group of individuals with appropriate expertise to assist with this task. The conservation incentives discussion will consider all relevant livestock depredation issues, including: livestock depredation prevention; livestock depredation response; carcass discovery, monitoring, removal, burial, and/or destruction; and possible adjustment of the Federal grazing (AUM) fee (and any Tribal grazing subsidies) within the Mexican Wolf Experimental Population Area (MWEPA) to provide de facto compensation for documented and likely undocumented losses of livestock. The AMOC report shall also include a thorough evaluation of the effectiveness and procedural efficiency of the Defenders of Wildlife wolf depredation compensation fund, and provide recommendations for appropriate improvements. 2. AMOC will advocate creating an IFT position in the Alpine field office to work with cooperators and stakeholders throughout Arizona and New Mexico on proactive measures by which to avoid or minimize wolf nuisance and livestock depredation problems. Note: AMOC as a body will not advocate regulatory changes to address carcass removal or disposal issues. 3. AMOC will collaborate with an appropriate entity to complete an IFT staffing needs assessment no later than June 30, 2007, based on (a) Reintroduction Project experience to date and (b) the Arizona-New Mexico Mexican Wolf Nonessential Experimental Population Rule recommended to USFWS. 4. AMOC will advocate creating sufficient IFT positions in each Lead Agency as appropriate to implement the staffing needs assessment conducted pursuant to Recommendation (30), above. AMOC will also recommend that at least one IFT member from each Lead Agency be stationed in the Alpine field office, to facilitate and enhance interagency communication and cooperation. 5. Concomitant with any recommended MWEPA Rule changes, AMOC recommends that State and Tribal Lead Agencies and non-Federal Cooperators make a contingentAC-5



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obligation request for annual Congressional line item allocations sufficient to cover all aspects of AMOC and AMWG participation in NEPA processes and ESA-related rulemaking processes required by such activities, through to the Record of Decision. 6. AMOC recommends that no later than April 30, 2006, AMOC State and Tribal Lead Agencies and non-Federal Cooperators complete and deliver to Congress a funding request that is sufficient to fully staff and equip the Reintroduction Project as of October 1, 2006, at levels commensurate with all on-the-ground responsibilities in all areas of responsibility, including wolf management (including control), enforcement, outreach (including establishing a Mexican wolf education center in Hon-Dah Arizona), citizen participation in adaptive management, Reintroduction Project-related research, and landowner incentives. B. Evaluation of the organizational recommendations from the 3-Year Review Paquet Report (Paquet et al. 2001) and Stakeholders Workshop (Kelly et al. 2001). As noted elsewhere in this report (e.g. AMOC Responses to Public Comment Component), recommendations from the 3-Year Review were not implemented to the extent that many stakeholders desired or expected. This was surprising to some people, because at least some of the recommendations seemed to be potentially valuable tools that, if implemented, might help further Mexican wolf recovery through successful reintroduction. What was not made clear to the public is that although USFWS regularly seeks peer and public review of its work and gives the results serious consideration, implementation is typically discretionary because recommendations must inevitably be balanced by logistical and other considerations, such as workload, staff availability, budget constraints, rulemaking requirements, direct input from key cooperators and local stakeholders, and the need to redefine or strengthen partnerships to support long-term conservation efforts. Moreover, in this case follow-up discussion with the reintroduction effort's primary cooperators was not carried out, thus conflicts among recommendations in the two review components were not resolved. Failure to resolve such conflicts made implementation all the more unlikely, especially for the much more plentiful and sometimes more complex recommendations in the Stakeholder Workshop (Kelly et al. 2001). Even in the 5-Year Review, we were unable to directly address those recommendations (hence they are omitted below) because of the process failures within the 3-Year Review that left Stakeholder consensus on substance, priorities, and completion timeframes unresolved. 3-Year Review Stakeholder Workshop Problem Statements Participants in the August 2001 Stakeholder Workshop (see Kelly et al. 2001) were divided into six Working Groups, to identify Problem Statements (issues), goals, and actions, and set within-group priorities. The intent was to conclude the Workshop with cross-group vetting and development of overall priorities. However, the Workshop ran so long that most Working Groups did not complete their own work, let alone review the work of other Working Groups. Thus, the Problem Statements provide insight into AC-6



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discussions within the Stakeholder Workshop, especially regarding the Paquet Report (Paquet et al. 2001) technical component of the 3-Year Review, but they do not represent stakeholder consensus. Even within the above-described limitations, the Workshop Problem Statements offer useful contrast to the Paquet Report, for two reasons in particular. First, technical shortcomings (e.g. Final Rule issues, science-based concerns about wolf management) in the Reintroduction Project are reaffirmed again and again. The Technical Component of the 5-Year Review will address these issues, so they are not addressed further in the Administrative Component. Second, they resurrect social issues that were lost when the Paquet Report failed to address two of the 3-Year Review issues put forth in the Mexican Wolf Interagency Management Plan (Parsons 1998): (1) Is effective cooperation occurring with other agencies and the public?; and (2) Are combined agency funds and staff adequate to carry out needed management, monitoring, and research? If these two questions had been addressed in the Paquet Report, they might have served well as reminders that feasibility issues must also be addressed when considering management solutions to biologically-based problems, and ultimately on a public lands landscape, feasibility has strong social and economic components. The Workshop Problem Statements are included below, as excerpts from Kelly et al. (2001), for information purposes. As noted above, technical aspects of the statements are addressed within the Technical Component of this review. Organizational and social aspects of the statements were addressed above, in Section A, covering the two questions from the Mexican Wolf Interagency Management Plan (Parsons 1998), thus they will not be discussed further. The Problem Statements follow, organized by Working Group: The Wolf Management Working Group identified, in priority order, the following six Problem Statements: (1) Areas for release and establishment of wolves have not always been selected on the basis of biological suitability, cost efficiency, logistical feasibility, wolf management feasibility, and minimized potential for impacts on existing land uses; (2) current post-release wolf management guidelines do not adequately address all relevant issues; (3) effective wolf management is hampered by a lack of information and by questions and concerns about the accuracy of the information on which it is based; (4) no mechanism has been clearly defined by which to monitor, evaluate and modify the Mexican wolf reintroduction program; (5) program staff may lack adequate training to meet the needs of implementing Mexican wolf recovery; and (6) current pre-release management guidelines do not adequately address all relevant issues. The Data Gathering Working Group crafted seven Problem Statements that were not prioritized. They are listed here in the same order they were listed in the group's report: (1) The Mexican Wolf Recovery Plan lacks current information and needs to be revised; (2) a Population Viability Analysis (PVA) has not been conducted for the wild Mexican Wolf population; (3) the effects of wolf populations on other wild predator and prey species and ecological process are not AC-7



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understood in the southwestern United States; (4) causes of wolf-human and wolflivestock conflicts are not sufficiently understood; (5) management actions such as capture and supplemental feeding may negatively effect wolves; (6) current boundaries hinder wolf recovery but may result in more human or wildlife wolf conflicts (7) there is a lack of historical data on wolves. The Communication and Trust Working Group crafted ten Problem Statements, listed here in priority order: (1) Mechanisms used to communicate are inadequate for stakeholder's satisfaction; (2) information handling and acquisition are not sufficient for good decision making; (3) important decisions are, or appear to be, preordained resulting in stakeholder disenfranchisement; (4) there is a lack of consultation and respect for local expertise which results in missing information, bad decisions, and erosion of local trust and support; (5) there is a lack of specific goals and objectives on how to reach recovery; (6) there is lack of recognition and inclusion of other forms of knowledge in addition to science; (7) changing the rules in the middle of the game, such as direct releases of wolves into the Gila, is premature; (8) anti-government sentiment which has developed from other issues and agencies has contributed to distrust of Wolf Recovery Program; (9) at times, rulemaking does not follow legislation and when it does there is no accountability or consequences; and (10) there is little consistency, permanency, and continuity of agency actors resulting in disrupted t rusting relationships and loss of local information. In addition, a plenary presentation by a member of this Working Group focused on the impact of the Mexican wolf recovery and reintroduction on the health of the local communities (see Appendix I of Kelly et al. 2001). The Human Dimension Working Group crafted five Problem Statements, listed here in priority order: (1) The administrators of the Mexican Gray Wolf Recovery Plan need to be accountable for their actions and the actions of the introduced wolves in order to obtain credibility with the public and other agencies; (2) lack of lines of communication, used in a timely manner, between program staff, agency partners and public needs to be improved; (3) there is a conflict between rural and urban values, perceptions and points of view that stresses the Mexican gray wolf program and local resident s in many ways; (4) the Mexican Wolf Program will inherently be a political issue; (5) there is lack of access to the program administrators from the local public that results in decisions that do not fully consider local views. The Economic Issues Working Group crafted three Problem Statements, but did not assign priorities to them. Thus, the three Problem Statements are listed here in the same order they were listed in the Working Group's report: (1) There are actual losses to the individual and local communities due to the introduction of the Mexican Wolf that are not being adequately addressed and will not be addressed until more permanent solutions are found; (2) the Mexican Wolf Recovery Program needs a better consideration of full costs, including an incentive program, control, accountability, and better use of budget , defining and AC-8



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accepting the financial and legal liabilities of the USFWS and the State entities involved in the project; and (3) the Mexican Wolf Recovery Program may create potential and actual benefit s and losses that have not been evaluated, quantified and considered for the proper balance of the program. The Livestock/Animal Conflict Working Group crafted six Problem Statements, listed here in priority order: (1) Current management techniques have not been optimally effective in reducing livestock/animal conflicts; (2) Economic impacts of wolf recovery on livestock and animal conflicts are unknown; (3) there is insufficient communication between agencies, livestock producers, and the public; (4) effective husbandry practices to decrease livestock-wolf conflicts have not been fully implemented; (5) existing rules and regulations regarding livestock and animal conflicts do not adequately address concerns of private and public land users and government agencies; and (6) impacts of wolves on the ecosystem are not fully understood. B-1. Modify the Recovery Team by inviting an appropriate individual other than the Recovery Coordinator to serve as the team leader



Status: Completed. Assessment: In August 2003, USFWS convened the Southwestern Gray Wolf Distinct Population Segment (SWDPS) Recovery Team (see below) and appointed Peter Siminski to serve as Team Leader. Mr. Siminski has a long-standing history with the Mexican wolf recovery program, dating back to 1983, shortly after five Mexican wolves had been captured in Mexico and transported to the Arizona-Sonora Desert Museum (ASDM) to establish a captive breeding program. Mr. Siminski, then an ASDM employee, was appointed as the official Mexican wolf studbook keeper and participated in recovery planning coordination of the captive management program. In 1985, a consortium of holders of captive Mexican wolves (i.e. the Mexican Wolf Captive Management Committee) was established. Through that body, Mr. Siminski has been instrumental in expanding the captive breeding program from the first few initial facilities that held Mexican wolves to currently more than 45 facilities in the United States and Mexico. Mr. Siminski is also credited with establishing management of captive Mexican wolves under the Mexican Wolf Species Survival Plan (SSP), a program of the American Zoo and Aquarium Association. He has served as Mexican Wolf SSP Coordinator since 1993. He also served as a member of the original Mexican Wolf Recovery Team since 1985, and of the second iteration of that Team in the 1990s. In 2003, Mr. Siminski was chosen as Team Leader for the newly convened SWDPS Recovery Team because of his vast knowledge of the program, his fair and unbiased approach toward recovery, and strong leadership abilities that would be needed to lead a diverse team with myriad viewpoints. Finding: AMOC finds that no further action is required on this topic.



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B-2.



Instruct the modified Recovery Team to revise by June 2002 the 1982 Recovery Plan.



Status: Not completed but being implemented and necessary to complete. Assessment: USFWS recognizes the importance of revising the 1982 Recovery Plan (USFWS 1982), given the plan (albeit intentionally) lacks recovery (downlisting or delisting) goals or strategies. When the plan was written, only a handful of Mexican wolves existed in captivity and recovery was virtually inconceivable unless the captive program was successful enough to produce enough wolves for reintroduction purposes. Therefore, the plan contained an overall primary objective to conserve and ensure the survival of Canis lupus baileyi by maintaining a captive breeding program and re-establish a viable, self-sustaining population of at least 100 Mexican wolves within their historic range. This was not intended to be a recovery objective for delisting purposes, but rather an interim goal given the uncertain progress of the captive propagation program at the time and recognition that a population of 100 wolves does not constitute recovery of the species. A second Mexican Wolf Recovery Team was convened in the 1990s, in part to assist in preparing NEPA documents associated with possible Mexican wolf reintroduction in the American Southwest. The Team, assisted by a private contractor, prepared a draft revised Recovery Plan but the document was never completed, nor was it subjected to peer review or shared with the public. Clearly, the 3-Year Review recommendation to revise the 1982 Recovery Plan was appropriate and valid. Revision was long overdue in 2001. However, the recommended completion date of June 2002 was unrealistic. Recovery planning is a lengthy process, especially with respect to recovering a species as complex and controversial as the wolf. A recovery plan requires a thorough evaluation of all relevant information, often necessitating much more time than the one year afforded by the 3-Year Review recommendation. Moreover, as occurred in this case, litigation sometimes has drastic effects on recovery planning. The following is an overview of circumstances that led to commencement of recovery planning in 2003 and a hiatus in 2005 that precluded completion of a revised Mexican Wolf Recovery Plan in conjunction with the 5-Year Review. Pursuant to the Final Rule, in 2001 USFWS conducted a 3-Year Review of Mexican wolf reintroduction. One of the Review's primary recommendations, in what is commonly referred to as the "Paquet Report" (Paquet et al. 2001) was to revise the 1982 Mexican Wolf Recovery Plan so it includes downlisting and delisting goals. However, in June 2001 Congress directed USFWS to obtain an independent review of the 3-Year Review. As a result, USFWS chose to delay implementing the 3-Year Review recommendations, including proceeding with recovery planning, until the independent review had been completed. In late August 2002, at USFWS request, AGFD and NMDGF agreed to conduct the independent review. USFWS chose the two State Wildlife Agencies because of their expertise and their participation and long history with the Mexican wolf program.



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The States' independent review was completed in September 2002 (AGFD and NMDGF 2002). The results were presented separately to each State's Commission, which resulted in the following direction to the two agencies: 1. The roles and functions of the Primary Cooperators (AGFD, NMDGF, and the Service) must be restructured to ensure State participation, authorities, and responsibilities as reflected in today's [Commission meeting] discussion. 2. The administrative and adaptive management processes must be restructured to ensure opportunities for, and participation by, the full spectrum of stakeholders. 3. The Interagency Field Team response protocols must be restructured, and staff capacity must be enhanced, to ensure immediate response capability to, and resolution of, urgent operational issues, such as depredation incidents. 4. Project outreach must be restructured as necessary to address the Commission, Department, and public concerns expressed today. 5. All actions in the Project must be in strict compliance with any applicable, approved special rules, policies, protocols, management plans, and interagency agreements. 6. The Project's review protocols and procedures must be restructured and improved to ensure that the 5-year review is effective and efficient, and an improvement over the 3Year Review. Following the States' review, AGFD initiated discussion with USFWS and NMDGF to address the Commissions' guidance. Despite clear direction and USFWS Region 2 Director concurrence with it, considerable effort was required to overcome staff resistance. However, by February 2003, progress was at last being made and additional potential cooperators were brought into the discussion, including USDA-APHIS WS, USFS, WMAT, NMDA, and various counties in AZ and NM. The lengthy process of restructuring the Blue Range reintroduction effort under State and Tribal leadership was culminated in an October 2003 MOU among AGFD, NMDGF, WS, USFS, USFWS, and WMAT as Lead Agencies and NMDA and Greenlee, Navajo, and Sierra counties as Cooperators. The MOU guides the Reintroduction Project through an adaptive management approach to managing the reintroduced wolf population. Concurrent with the activities outlined above, at a national level USFWS was in the process of reclassifying the gray wolf to remove it from the list of endangered and threatened wildlife throughout portions of the conterminous United States. This rule, which became effective on April 1, 2003, established three Distinct Population Segments (DPS) for the gray wolf, one of which was the Southwestern Gray Wolf DPS. This action did not change the status of Mexican wolves; wolves in the Southwestern DPS retained their previous experimental population or endangered status. However, establishment of the SWDPS required USFWS to achieve recovery at the DPS level (i.e. the DPS would be delisted when recovery is achieved within the DPS), which had important implications for how recovery is achieved in the Southwest. In recognition of this forthcoming rule, USFWS continued to hold off on recovery planning for the Mexican wolf until gray wolf policy at the national level was determined. Following the final reclassification rule in April 2003 (which established the SWDPS), and at the direction of the Regional Director, USFWS began to convene a new Recovery Team. The Team, AC-11



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composed of technical and stakeholder sub-groups to address science and social and economic considerations of wolf recovery, was assembled by August 2003. The Recovery Team consists of a Technical Sub-Group and a Stakeholder Sub-Group. The Technical Sub-Group is a body of scientists who represented expertise in wolf reintroduction and management, population demographics, general wolf biology and behavior, genetics, captive propagation, and research. The Stakeholder Sub-Group includes a variety of interests from local and private sectors representing the livestock and ranching industry, hunters, hunting guides and outfitters, and environmental and conservation organizations, as well as Federal, State, Tribal, and County governments. The Stakeholder Sub-Group provides the opportunity for those directly or indirectly affected by wolf recovery to voice their concerns, and concerns of the constituents they represent, regarding impacts of wolves on resource management, land use, and socioeconomic factors. Five Recovery Team meetings were held from October 2003 through October 2004. Progress was at last being made toward a revised Recovery Plan. In January 2005, the 2003 reclassification was vacated (see: Defenders of Wildlife v. Norton, 03-1348-JO; National Wildlife Federation v. Norton, 1:03-CV-340, D. VT. 2005). This caused USFWS to revert to the 1978 gray wolf listing, which listed the species (Canis lupus) as a whole but continued to recognize valid biological subspecies (e.g. Canis lupus baileyi) for purposes of research and conservation. In response to these rulings, in 2005 USFWS put the SWDPS Recovery Team "on hold" indefinitely; its charge to develop a recovery plan for the SWDPS was no longer valid, because there no longer was a SWDPS. In December 2005, the Department of Interior announced that it would not be filing appeals for either case (see below). This announcement provides impetus for the Southwest Region to reinitiate recovery planning, which USFWS will now proceed with in coordination with other wolf management activities. Note: On December 19, 2005, AMOC was informed that Craig Manson, Assistant Secretary of the Interior for Fish, Wildlife and Parks, had that day issued a statement on the USFWS decision regarding the U.S. District Court decisions earlier this year striking down the USFWS 2003 reclassification of gray wolf populations. Mr. Manson's statement was as follows: The U.S. Fish and Wildlife Service will not appeal U.S. District Court decisions earlier this year striking down the Service's reclassification of gray wolf populations from endangered to threatened for much of the species' current range in the United States, although we continue to believe the reclassification was both biologically and legally sound. We are exploring options for managing wolf populations that comply with the Courts' rulings, while recognizing, as the courts did, that the Yellowstone and Great Lakes wolf populations have reached the recovery goals necessary for delisting. The Department of the Interior plans to issue separate, proposed rules to delist new distinct population segments of gray wolves in the northern Rocky Mountains and the



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Great Lakes as early as possible in 2006. Both proposed rules will have public comment periods lasting 90 days. In the meantime, gray wolves will continue to be managed as they were prior to the 2003 reclassification. Gray wolves in Minnesota are classified as threatened, as a result of a 1978 reclassification. Gray wolves in the remaining 47 conterminous states and Mexico are endangered, except where they are listed as part of an Experimental Population for reintroduction purposes in the northern Rockies and parts of the Southwest. Citizens with concerns about wolf management should contact the Fish and Wildlife Service or their State wildlife agency for clarification of what actions are currently allowed under the management designation in effect where they live. In light of Assistant Secretary Manson's statement (above), USFWS Region 2 also affirmed on December 19, 2005 that it would move forward with wolf recovery planning in the Southwest. Meanwhile, after considering all public and cooperator comment during the 5-Year Review, and its own evaluations, AMOC has made various recommendations to USFWS and for AMOC action on issues that it considers necessary to address within the context of the 5-Year Review of the Reintroduction Project and the Final Rule under which the Project operates (see the AMOC Recommendations Component). Finding: AMOC recommends that USFWS complete a Mexican Wolf Recovery Plan no later than June 30, 2007. Note: AMOC appreciates that this recommended deadline is impractical, but offers it, nonetheless, to strongly underscore that (a) revision is long overdue, and (b) lack of a current Recovery Plan (and overall recovery goal) is negatively affecting the Reintroduction Project in several ways, perhaps most importantly that for a reintroduction project population (management) objective to have meaning and credibility, it must be placed in appropriate context by well-defined rangewide downlisting and delisting (recovery) goals. B-3. Immediately engage the services of the modified Recovery Team.



Status: Not completed but being implemented and necessary to complete. Assessment: As noted in B-2 (above), the Recovery Team has been on hold due to litigation that vacated the 2003 reclassification rule. Prior to that ruling, however, USFWS was using the full team in this recommended capacity, due to the body of expertise within both sub-groups of the Team. One such example included inviting the Team's Technical and Stakeholder Sub-Group members to review this 5-Year Review, and to provide feedback regarding reintroduction and overall management of wolves in the BRWRA. Finding: Given the December 19, 2005 Department of Interior announcement (see above) that it will not appeal the court cases that vacated the 2003 rule, USFWS, in coordination with AMOC, will now determine appropriate and necessary activities for the Recovery Team pertinent to the BRWRA. The Team may be able to provide assistance with at least two AMOC 5-Year Review Recommendations, which are as follows (see the AMOC Recommendations Component for these recommendations in full and for related recommendations): AC-13



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1. AMOC will determine, on biological/ecological grounds, and conclude in a written report to the USFWS Region 2 Director no later than June 30, 2006, whether (and, if so, the extent to which) the current MWEPA outer boundaries should be expanded within Arizona-New Mexico to enable the Arizona-New Mexico Mexican wolf population to exist within a metapopulation context consistent with Leonard et al. 2005 and Carroll et al. in press. AMOC may convene, if necessary, a technical advisory group of individuals with appropriate expertise to assist with this assessment. 2. AMOC will develop, no later than June 30, 2006, a report describing a proposed Federally, State, and/or Tribally-funded incentives program to address known and potential economic impacts of wolf nuisance and livestock depredation behavior on private, public, and Tribal Trust lands. AMOC may convene, if necessary, a technical advisory group of individuals with appropriate expertise to assist with this task. The conservation incentives discussion will consider all relevant livestock depredation issues, including: livestock depredation prevention; livestock depredation response; carcass discovery, monitoring, removal, burial, and/or destruction; and possible adjustment of the Federal grazing (AUM) fee (and any Tribal grazing subsidies) within the MWEPA to provide de facto compensation for documented and likely undocumented losses of livestock. The AMOC report shall also include a thorough evaluation of the effectiveness and procedural efficiency of the Defenders of Wildlife wolf depredation compensation fund, and provide recommendations for appropriate improvements. B-4. Immediately modify the final rule and develop authority to conduct releases into the Gila National Forest.



Status: Not completed; no action but necessary to complete. Assessment: The existing Final Rule restricts direct releases of Mexican wolves from captivity to the Primary Recovery Zone (PRZ), in the southern portion of the Apache National Forest, entirely within AZ (Greenlee County). Wolves released into the PRZ are allowed to disperse throughout the entire BRWRA, including the Apache National Forest (AZ) and the Gila National Forest (NM). Additionally, wolves that have previously been free-ranging (wild) may be translocated for management purposes anywhere within the Secondary Recovery Zone (SRZ), which includes the remainder of the BRWRA. AMOC recognizes there are limitations with the existing rule. The Gila National Forest is approximately 75% of the BRWRA and contains much of the best wolf habitat, due to existence of areas with low or no road densities, good populations of large native ungulates (primarily elk), and few to no permitted livestock. Currently, AMOC is limited to releasing (translocating) wolves that have had previous wild experience into New Mexico. This restricts the pool of available release candidates and limits AMOC's ability to release wolves for management purposes, such as replacement of lost mates or genetic augmentation. The ability to augment the wild population with wolves that are genetically underrepresented is important to increasing the overall fitness of the population, thereby aiding recovery of the species. AC-14



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Additionally, there is public perception that AMOC is concentrating "problem" wolves in New Mexico, because wolves translocated into the Gila are "problem" wolves that have been removed from the wild for livestock depredations or other such nuisance/problem behavior. However, data indicate that translocated "problem" wolves are more likely to succeed, not less likely. In other words, this means wolves are less likely to have to be removed because of problem behavior again after being translocated. The data indicate that relocating the offending problem animal(s) to another area can alter their behavior, thereby rendering them no longer "problem" wolves. Nonetheless, AMOC recognizes the value of being able to directly release wolves without any previous history of problem behavior into New Mexico. Aside from the obvious biological considerations, it could help improve relations and build trust with those most affected by wolf reintroduction. Clearly, a consistent policy needs to be in place that allows wolves with successful experience in surviving on wild prey (even if that includes limited involvement in depredation situations), and wolves that are more na�ve but have no experience with livestock to be candidates for release or translocation throughout the BRWRA. In fact, pairings of wolves that are na�ve with those having previous wild experience could lead to establishment of pairs or packs with more of the desired attributes for successful establishment in the wild. As stated above, however, the current rules and policies limit the ability to translocate or release wolves with successful experience with wild prey throughout the recovery area, and limit the availability of wolves with no history of depredation for translocations to the SRZ (e.g. New Mexico). As early as 1999, USFWS began internally discussing the possibility of modifying the Final Rule.1 In the short time since they had been released, Mexican wolves had colonized the majority of the PRZ, leaving fewer release sites in which to conduct further releases. Additionally, the Project had experienced several conflicts between wolves and human activities in rural areas, wolf/dog conflicts, and several confirmed depredations. Many illegal wolf shootings had also occurred. Thus, USFWS convened a Mexican wolf program review in January 1999, in which experts strongly recommended modifying the rule to gain authority to release wolves in remote areas (i.e. the Gila National Forest) in the NM portion of the BRWRA, to minimize the conflicts. Based on its experience at that time with managing and monitoring the free-ranging population, the IFT also supported this action. In September 1999, approval was received from the USFWS Southwest Regional Director at the time to proceed with steps that would allow for releases in the Gila National Forest, including focused outreach, relocation/release site clearances, and revision of the Final Rule, the latter of which would require extensive public comment opportunities (e.g. public scoping, review and comment periods, public meetings and/or hearings) under section 10(j) of the Endangered Species Act (ESA), the Administrative Procedures Act (APA), and the National Environmental Policy Act (NEPA).



It should also be noted that a potential rule amendment regarding direct releases into New Mexico was foreseen by USFWS and mentioned as a possibility in the FEIS (public comment and response on pages 5-87 � 5-88).



1



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In October 1999, the Mexican Wolf Recovery Coordinator retired from USFWS, but momentum for proceeding forward with modifying the Final Rule continued. Internal draft Proposed Rule language to allow for direct releases into New Mexico was completed by USFWS in February 2000, and was then to be released to the public through the appropriate NEPA process to solicit public comment. However, it was never released. In April 2000, a new Mexican Wolf Recovery Coordinator was hired and Project priorities were redirected toward improving the IFT's effectiveness and responses to field issues and conflict situations. This shift put rule change momentum on hold, in order to focus on establishing a system of Recovery Protocols to ensure consistency and quality of data collection, consistency in how IFT personnel respond to field situations, safety of Project personnel and wolves, and to provide mechanisms for project peer review and Project and individual accountability. In 2001, following drafting of various Recovery Protocols, USFWS began the Project's 3-Year Review pursuant to the Final Rule. With USFWS concurrence and support, an independent team of scientists was contracted by the Conservation Breeding Specialist Group (CBSG) to perform the technical portion of the review, which is commonly referred to as the Paquet Report (Paquet et al. 2001). The Paquet Report concluded that the simplest and most important change USFWS could make to enhance recovery would be to modify the Final Rule to allow for initial releases of captive-born (and wild-born if appropriate) Mexican wolves into the Gila National Forest. Similarly, the "Wolf Management Working Group" of the 3-Year Review's August 2001 Stakeholder Workshop in Show Low, AZ identified (see Kelly et al. 2001) the highest two ranking goals as: (1) to reassess and refine the boundaries for wolf recovery in Arizona and New Mexico; and (2) select better wolf release/management areas within the recovery zones in Arizona and New Mexico. The stakeholders group further indicated that the flexibility to select wolves that have a greater probability of success, and thereby impact landowners and economic interests the least, is in the best interest of the program, both biologically and for those that may be impacted by wolves. Importantly, both the Paquet Report and the Stakeholders Workshop provided recommendations on strengths and weaknesses of the Reintroduction Project as it was then being implemented. However, some recommendations in the Stakeholders report conflicted with some in the Paquet report or with others in the Stakeholders report. Due to review process design and execution problems, the 3-Review failed to result in an overall set of recommendations from the various components that the primary cooperators (at that time: USFWS, AGFD, NMDGF, and WMAT) agreed to implement. This problem was duly noted in the Stakeholders Workshop Report (Kelly et al. 2001, see minority reports therein) and again in AGFD and NMDGF (2002). To date, USFWS has not taken action on the Paquet Report recommendation to modify the Final Rule to allow for releases into the Gila National Forest. Shortly after completion of the 3-Year Review, a new Regional Director, H. Dale Hall, was assigned to Region 2. His main priorities for the Mexican wolf recovery program were (1) to restore intended levels of cooperation with State, Tribal, and other interests in reintroduction and recovery planning, and (2) to revise the 1982 Recovery Plan, since the plan does not identify criteria (i.e. how many wolves in how many areas constitutes recovery?) for removing the Mexican wolf from the endangered species list. AC-16



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Once the 2003 reclassification rule solidified the direction that USFWS would take with respect to wolf recovery (i.e. DPS listings instead of species/subspecies listings), Mr. Hall directed his wolf recovery program staff to revise the Recovery Plan to include downlisting/delisting criteria and describe the larger picture of recovery for the entire SWDPS before considering a rule change for the BRWRA reintroduction effort. Concurrently, he also indicated that in order to revise the rule, USFWS must first have a recommendation from the SWDPS Recovery Team, including both the technical and stakeholder sub-groups, and from AMOC. However, due to the 2005 court decisions vacating the 2003 reclassification rule, thus putting the SWDPS Recovery Team on hold, Mr. Hall stated in Spring 2005 that in the absence of a functioning Recovery Team, he would look to AMOC and the 5-Year Review for recommendations on changes to the Final Rule. Accordingly, AMOC has made recommendations in the final 5-Year Review for Final Rule changes to address boundary modification concerns (see AMOC Recommendations Component). USFWS will then determine whether and how to proceed with AMOC's recommendations. If and when proposed rule change language regarding authorizing releases into the Gila National Forest is drafted, it will be released to the public pursuant to the APA, ESA, and NEPA to ensure appropriate opportunities for participation and input by the public. Finding: AMOC proposes combining the current BRWRA Primary and Secondary Recovery Zones, the Fort Apache Indian Reservation (FAIR), and/or any other appropriate contiguous areas of suitable wolf habitat into a single expanded Blue Range Wolf Reintroduction Zone (BRWRZ) and allowing initial releases and translocations throughout the BRWRZ in accordance with appropriately amended AMOC Standard Operating Procedures (SOPs) 5.0: Initial Wolf Releases and 6.0: Wolf Translocations. B-5. Immediately modify the final rule to allow wolves that are not management problems to establish territories outside the BRWRA.



Status: Not completed; no action but necessary to complete. Assessment: (Note: Please see B-4 above for additional information regarding rule change modification that is also relevant to this entry). Under the current Final Rule, AMOC is required to capture wolves that establish territories on public land wholly outside the designated wolf recovery areas and return them to the BRWRA or captivity. Additionally, if wolves establish themselves on private or Tribal land outside the BRWRA, AMOC must remove them unless the landowner agrees they may remain. The 3-Year Review Paquet Report criticizes USFWS for promulgating a rule in which the boundary is so constrained. The report states, "Such regulations are inappropriate for at least 2 reasons: 1) they are nearly impossible to effectively carry out as the wolf population grows because of the difficulties of managing an ever-increasing number of wide-ranging dispersing animals, and 2) they establish a precedent that could be effectively used to argue for the removal of other endangered species inhabiting certain tracts of public or private land (Paquet et al. AC-17



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2001). They further point out that nowhere else in the United States does USFWS remove wolves simply for being outside a boundary in the absence of a problem. Although it was the prerogative of the Paquet panel, as an independent reviewer, to make such comments, these opinions are hindsight that was not shaped by the lengthy evaluation and discussions that led to the Final Rule. The criticized constraints were not offered lightly, or without consideration of the problems they might present in the future. USFWS promulgated the Final Rule based on circumstances at the time, including the full range of agency and public comment on the Draft EIS; in the absence of such provisions, USFWS and its primary cooperators believed that reintroduction would likely not have been possible. The proposed rule change language drafted by USFWS in February 2000 (discussed in B-4, above) did not address allowing wolves that are not a management problem to establish territories outside the BRWRA. At the time the proposed rule change language was drafted, the most important issue viewed as hindering wolf recovery in the Southwest was the inability to release wolves into the Gila National Forest, which makes up of the majority of the BRWRA and contains some of the best wolf habitat. Therefore, the draft primarily addressed modifying the final rule to allow for direct releases of captive-raised wolves into the SRZ (i.e. Gila NF) of the BRWRA. Along with this amendment, USFWS intended to seek suggestions from program cooperators and the public for any other needed rule changes. Because the presence of wolves throughout the entire BRWRA, with all anticipated associated impacts, were analyzed in detail in the FEIS, a rule change considering direct releases into New Mexico would not have required a Supplemental EIS (SEIS). This was because the proposed action of allowing direct releases into the SRZ would not have altered the scope or scale of the impacts, and the actual impacts observed in the BRWRA after two years of wolf releases generally were consistent with what was predicted in the EIS. Therefore, no significant change or new information had been presented that would require a SEIS, and a revision to the rule presumably could have proceeded, in the absence of any new information received during the public comment period. As the free-ranging wolf population expanded however, a more important issue surfaced that revolved around the BRWRA boundary. As the population grew, dispersing wolves began to travel beyond the BRWRA boundary, sometimes requiring retrieval, as mandated by the Final Rule, even in the absence of problem behavior or conflict situations. As stated in the Paquet Report, this is problematic for several reasons, the most obvious being that it hinders natural dispersal and recolonization of wolves into new areas, thereby slowing recovery. As the number of un-collared wolves increases, it also sets an unrealistic expectation that the IFT will be able to remove wolves that establish outside the BRWRA boundary, when in fact there is no guarantee that even collared wolves can always be captured due to their wide-ranging capabilities. This creates credibility issues with the public, and significant frustration. It also presents serious logistical and staffing concerns, since the IFT must spend considerable time and resources removing otherwise non-problematic wolves, when their time could be spent more productively dealing with more pressing field issues, such as daily monitoring, trapping for un-collared wolves or responding to wolf-livestock conflicts.



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To date, as noted in B-4, above, USFWS still has not taken action on the Paquet et al. (2001) recommendation to modify the Final Rule to allow wolves that are not a management problem to establish territories outside the BRWRA. Any proposed rule change language is now separate from the recovery planning process and will come through AMOC as part of this 5-Year Review. Accordingly, AMOC has made recommendations in the final 5-Year Review for Final Rule changes to address boundary modification concerns (see the AMOC Recommendations Component). USFWS will then determine whether and how to proceed with AMOC's recommendations. If and when proposed rule change language regarding authorizing wolves that are not management problems to establish territories outside the BRWRA is drafted, it will be released to the public pursuant to the APA, ESA, FACA, and NEPA to ensure appropriate opportunities for participation and input by the public. Finding: AMOC will determine, on biological/ecological grounds, and conclude in a written report to the USFWS Region 2 Director no later than June 30, 2006, whether (and, if so, the extent to which) the current MWEPA outer boundaries should be expanded within Arizona-New Mexico to enable the Arizona-New Mexico Mexican wolf population to exist within a metapopulation context consistent with Leonard et al. 2005 and Carroll et al. in press. AMOC may convene, if necessary, a technical advisory group of individuals with appropriate expertise to assist with this assessment. The AMOC assessment will also consider other relevant issues, such as: likelihood of expansion area occupancy by wolves dispersing from northerly states or from Mexico; the merits of extending nonessential experimental population status beyond the current boundaries; and estimated costs associated with managing wolves in an expanded area. The technical advisory group, if convened, shall be chaired by an AMOC representative and shall include no more than 15 other members, each with appropriate scientific expertise. AMOC will advocate that the MWEPA recommendation constructed as a result of its Recommendations allow wolves to disperse from the BRWRZ throughout the MWEPA, subject to management consistent with current Blue Range Reintroduction Project SOPs. Any recommendation to amend the existing Final Rule or to create a new Final Rule would ultimately, if acted on by USFWS, be in full compliance with all applicable APA, ESA, FACA, and NEPA requirements. B-6. Resist any opportunity to reintroduce Mexican wolves in the White Sands Wolf Recovery Area.



Status: Not completed; being implemented but necessary to complete. Assessment: As authorized by the Final Rule (USFWS 1998) and Record of Decision (USFWS 1997), USFWS is implementing the "Preferred Alternative" of the FEIS on reintroduction of the Mexican wolf (USFWS 1996). The Preferred Alternative allows wolves to be reintroduced into a portion of the BRWRA, and if feasible and necessary to achieve recovery, White Sands Missile Range (WSMR) would be used as a secondary reintroduction site. Limiting use of WSMR solely as a secondary site was based on two independent assessments (Bednarz 1989, Green-Hammond 1994) that concluded WSMR by itself could not support a viable population of wolves due to its relatively small size and its isolation from other suitable habitat. This finding was reiterated in the 3-Year Review, noting wolf dispersal would be AC-19



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hindered by Interstate-25 and poor wolf habitat surrounding WSMR (Paquet et al. 2001). Another more recent habitat modeling analysis (Carroll et. al. in press) came to the same conclusion, stating, "Conversely, an area such as the WSMR, even in the doubtful event that it could support a viable population, would make little contribution to regional recovery goals due to its isolation and small size." Carroll et al. evaluated WSMR in a regional context, but also summarized habitat quality for WSMR as a stand-alone area for reintroduction. Their results suggest that habitat within WSMR would play little or no role in facilitating reintroduction success. Finding: AMOC sees no benefit to continuing to hold WSMR up as a possible reintroduction site or primary recovery area. Although wolves might eventually disperse to WSMR, neither the habitat (prey base) nor the management constraints of that site (i.e. national defense and Homeland Security issues) would be conducive to establishing a significant population segment or to contributing toward wolf recovery on a rangewide basis. Thus, AMOC recommends that any amended or new Mexican Wolf Nonessential Experimental Population Rule drafted in conjunction with Recommendations (1) and (2), above, not include WSMR as a Mexican Wolf Recovery Area (i.e. its designation in the current Final Rule) or as a Reintroduction Zone. This would not preclude natural dispersal to WSMR, nor would it require removal of wolves dispersing to WSMR. B-7. Provide biologists with opportunities to visit other wolf projects to gain training with capturing and handling free-ranging and captive wolves.



Status: Not completed because it is a continuing need that is being addressed. Assessment: AMOC and the IFT recognize that the highest levels of professionalism, expertise, and ethical standards are required of a workforce in a field as dynamic, broad-based, and closely scrutinized as the Mexican wolf reintroduction effort. AMOC and the IFT include a multitude of agencies that bring to the Project a tremendous diversity in workforce. Each agency represented on the IFT ensures that its own personnel will meet the annual training requirements placed upon them by their own agency, including as a result of consideration of Project needs. The IFT goes even further in ensuring that its members are trained. The IFT currently holds annual training (e.g. immobilization training) that is open to employees of cooperating agencies and held at captive facilities in New Mexico, the Alpine Field Office, and other sites within AZ and NM. Where appropriate, each agency invites other agency personnel to training sessions or to be a trainer at agency meetings. Project staff members have also been detailed to other wolf programs to gain field experience. In addition, and dependent upon funding, AMOC and the IFT will strive to provide additional training opportunities, such as net-gunning wolves in the Rocky Mountains, to increase proficiency and knowledge of IFT members. Finding: No later than December 15, 2007, AMOC and the IFT will identify training recommendations to build and enhance administrative, project management, supervisory, communication, and technical skills and knowledge as appropriate to each staff member's job functions within the Reintroduction Project.



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B-8.



Station the Field Coordinator in the BRWRA (e.g. in Glenwood or Silver City, New Mexico or Alpine, Arizona) and insist that this person be intimately involved with all aspects of fieldwork (wolf management, public relations, data collection, management, analysis, report preparation, etc.).



Status: Completed. Assessment: Mexican wolves were first released to the wild in March 1998. At that time, the USFWS Mexican Wolf Field Coordinator position was stationed in the Regional Office in Albuquerque NM. In 1999, USFWS began making plans to station the Field Coordinator in the BRWRA, specifically Glenwood NM. This shift in operations was initiated in order for USFWS to have more presence in local communities affected by wolves. It also gave USFWS the ability to be more responsive to wolf situations in a timely manner as they arose in the field. From 2000 through May 2001, the Field Coordinator was stationed part-time in Glenwood until her departure from the Mexican wolf recovery program. The Field Coordinator position remained vacant until September 2002, when the current Field Projects Coordinator was hired. The Field Projects Coordinator has been stationed in Alpine AZ, headquarters for the IFT, since being appointed. At this time, USFWS intends to keep the Field Projects Coordinator position stationed in the BRWRA. As a fully functioning member of the IFT, the Field Projects Coordinator is intimately involved in all aspects of fieldwork, as suggested in the 3-Year Review recommendation. The functions and duties of the Field Coordinator are spelled out in the MOU among the Lead Agencies and other Cooperators as follows: The Field Coordinator shall: 1. Serve as a member of the IFT and assist the Field Team Leaders in carrying out any field activities necessary to accomplish project goals and objectives. 2. Serve as the communication liaison between the Adaptive Management Oversight Committee and the IFT. 3. Collaborate with the IFT to draft recovery protocols. 4. Assist the Field Team Leaders in drafting Annual Work Plans, Annual Performance Reports, and new or revised project operating procedures. 5. Plan and coordinate, with assistance from the Field Team Leaders, the identification of review of additional release sites for release or translocation of Mexican wolves. Additional insight on the Field Projects Coordinator can be gleaned from the referenced MOU (see Administrative Component Attachment 2). Finding: Under current structure, for coordination and communication purposes AMOC believes it is essential for the Field Projects Coordinator to remain stationed in the IFT field office (currently in Alpine AZ). The same logic applies to other agency cooperators, if, as projected, AC-21



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the IFT expands to meet needs resulting from a growing wolf population. Thus, AMOC recommends that at least one IFT member from each Lead Agency be stationed in the Alpine field office, to facilitate and enhance interagency communication and cooperation. B-9. Put forth a concerted effort to develop realistic expectations for the Project.



Status: Not completed because it is a continuing need that is being addressed. Assessment: This recommendation from the Paquet Report identified a need to "constantly remind the public and the media" that "restoration is an imprecise process that is by definition `heavy handed.'" It further reflected Paquet et al.'s admonition that USFWS would face (and need to overcome) many "great challenges," meaning that "intervention will be required, wolves will disappear, and that some animals will die. But just as certainly, meeting the challenges will ensure the restoration of a self-sustaining population of Mexican wolves in the Blue River [sic] Wolf recovery area." Clearly, establishing more realistic expectations for the Reintroduction Project was a pressing priority in August 2001, as the 3-Year Review came to a close. The Stakeholders Workshop underscored the Paquet Report admonition about realistic expectations. It seemed evident that to some, the death of any wolf, perhaps even from natural causes, was unacceptable, and especially so for any wolf that died as a direct consequence of human action. Yet, as Paquet et al. (2001) pointed out, mortality was inevitable. Unrealistic expectations were also evident in regard to human ability to control, or at least modify, wolf behavior. The difficulties of tracking wolves in extremely rugged terrain, from searing summers through snow-bound winters, were too often casually dismissed, as some people questioned why the IFT did not know where every wolf was at every second. And even as these questions were asked, other people or even some of the same people criticized the Project for too much intervention, opining that the wolves should be allowed to adjust to the wild and people would simply need to adjust to them. Also, IFT response time to "nuisance" and "problem" wolves was often perceived by local residents as inadequate, even as criticisms were constantly lodged about the cost of the Project, which would only be increased if additional resources were allocated to increase responsiveness. The need for more realistic expectations was reaffirmed a year later, in the State Wildlife Agencies' September 2002 independent review of the 3-Year Review (AGFD and NMDGF 2002). To better address public expectations for a well-managed reintroduction project that appropriately considered and responded to the public's expectations, the AZ and NM State Wildlife Commissions requested in September 2002 that USFWS: 1. Restructure the roles and functions of the Primary Cooperators (AGFD, NMDGF, and the Service) to ensure State participation, authorities, and responsibilities. 2. Restructure the administrative and adaptive management processes to ensure opportunities for, and participation by, the full spectrum of stakeholders. AC-22



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3. Restructure the Interagency Field Team response protocols, and enhance staff capacity, to ensure immediate response capability to, and resolution of, urgent operational issues, such as depredation incidents. 4. Restructure Project outreach as necessary to address Commission, Department, and public concerns. 5. Ensure that all actions in the Project be in strict compliance with any applicable, approved special rules, policies, protocols, management plans, and interagency agreements. 6. Restructure and improve the Project's review protocols and procedures to ensure that the 5-year review is effective and efficient, and an improvement over the 3-Year Review. The State Wildlife Commissions and their respective agencies were willing to help USFWS restructure the Project from top to bottom, and work toward successful reintroduction and recovery, but first they needed to know that USFWS was receptive to a more collaborative partnership than the States and the public perceived had existed since the initial wolf releases in 1998. Fortunately, the new leadership in USFWS Region 2 was more than receptive to this concept, as Regional Director H. Dale Hall both embraced and helped structure the necessary changes in organizational philosophy, structure, and function. By November 2002, Directors of the two State Wildlife Agencies and USFWS Region 2 had agreed upon a course of action to address these concerns in such a way that more realistic expectations would be developed on both sides of the equation: the agencies that manage the Project and the public that is interested in and/or affected by it. Identifying themselves as Primary Cooperators, the three agencies agreed (see Attachment 1, dated November 8, 2002): The Service is responsible for providing guidance and coordinated information to all interested parties relative to recovery of the Mexican wolf. The States and Tribes are responsible for conducting reintroduction efforts in such a manner that they contribute directly to recovery. Other federal, state, local, and private stakeholders have to some extent shared responsibilities, or at least significant stakes, in these areas. The intent of the current Primary Cooperators is to realign the Recovery and Reintroduction components so they are fully integrated, smoothly coordinated, and effective. This document begins, but does not complete progress toward achieving the direction that was given to the two State Wildlife Agencies by their respective Commissions in September 2002. The Primary Cooperators will, however, complete this effort before March 31, 2003, through appropriate collaboration with Tribal and other interested parties. From November 2002 through October 2003, the original Primary Cooperators met frequently, and over time with an increasing number of other State agencies, tribes, and local governments, to discuss a new framework for collaboration to ensure that expectations about the Project were more realistic, and more importantly that they were met. Agencies-only meetings were blended with what evolved into quarterly AMWG public meetings for open discussion of virtually all



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aspects of the Project. One of the more frequently voiced criticisms reflected a lack of trust in the agencies managing the Project. The transition from Federal to State and Tribal implementation lead for the Mexican Wolf Blue Range Reintroduction Project was problematic at times for some Project cooperators, as new roles and responsibilities of agencies were defined and implemented. Uncertainty in how the new structure might affect day-to-day operations and decision-making at the field level prevailed. Many of these issues remained unresolved as staff-level discussions continued; consequently, interagency meetings from February 2003 through October 2003 covered many of the same issues repeatedly, thus delaying addressing fundamental problems such as insufficient funding and staff required to carry out the needed management, monitoring, and research. It was difficult to reach consensus decisions about such issues, as agency representatives at the negotiating table struggled under the new organizational structure they had been directed to implement. Roles, functions, and authorities were debated repeatedly. Overcoming the trust issues among Project cooperators required time, persistence, and a spirit of cooperation. Nevertheless, by October 2003, the agencies had crafted an MOU (Attachment 2) as a foundation for adaptive management of the Reintroduction Project. Quarterly meetings of AMOC, which guides the Project, and AMWG, which affords a forum for public participation, thus became the primary mechanism for ongoing discussion and re-discussion of what to expect from the Project, and what the Project might expect from the public. Many of the same questions and concerns came up at virtually every meeting in 2003 and 2004, and they were addressed each time. Over-commitment of limited resources in a partnership effort was finally beginning to give way to a more realistic accounting of what could and would be done, and doing it. That seemed to be a significant step forward in a Project as complex and controversial as wolf reintroduction, and it is a credit to all the agencies and public involved. As of the time at which this 5-Year Review is being completed, the cooperating agencies are continuing to diligently work to develop more realistic expectations for and by the Project in all sectors. It is, however, a never-ending, difficult task. Few individuals inside and especially outside the agencies are sufficiently attuned to the Project to stay fully abreast of its problems, and its progress. Many other issues and activities draw on their time. Thus, the focus is on constant re-education as well as on education. Information is now flowing better about the Project than ever before. The Project has established a toll-free number (1-888-459-WOLF) whereby the public can call during business hours to report sightings or incidents, or to receive information about the project. A 24-hour radio dispatch (1-800-352-0700; the AGFD Operation Game Thief Hot Line) is also operational to report incidents, depredations, or emergencies after hours. SOPs have been completed for all essential areas of IFT activity, and they are continually revised as new experience and knowledge is brought to bear. Lead Agency Directors meet twice each year with AMOC, the IFT, and Cooperators for Project updates on key issues and activities, and to discuss significant issues of concern. The backlog of uncompleted Annual Reports has been eliminated. AMOC and the IFT now engage in joint annual work planning and budgeting, to ensure that staff resource allocations appropriately match product and service expectations and the available resources. Electronic self-subscription update services at http://azgfd.gov/signup AC-24



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complement information posted on the AGFD wolf website, http://azgfd.gov/wolf, and the USFWS Mexican wolf website, http://mexicanwolf.fws.gov. Enhanced signage in wolf-occupied areas, brochures, public adaptive management discussions, outreach presentations by the IFT, and countless "one-on-one" field staff conversations with local residents are occurring to ensure that people have opportunities to gain more knowledge about the Project, express their opinions, and form more realistic expectations about it. The same mechanisms of interaction serve to inform the agencies about the public's expectations, and how they can best be met. Finding: As stated before, the "concerted effort" necessary to "develop realistic expectations" (within and outside the Reintroduction project) is indeed never-ending, thus this Paquet Report recommendation can only be described as "Being Implemented;" it will never be "Completed." B-10. Initiate programs to educate people about wolf behavior. Status: Not completed because it is a continuing need that is being addressed. Assessment: Education and public outreach is essential and should be a continual, dynamic, and effective part of the Mexican Wolf Recovery Program. Providing sufficient and accurate information on wolves and their behavior is important to all entities involved in this program. Many strategies have been introduced to provide this information to the public. An interim "Education and Public Outreach Position" was created by USFWS to initially coordinate program goals. It has been superseded by AMOC SOP 3.0: Outreach (available at http://azgfd.gov/wolf). AGFD now employs a full-time person on the IFT to meet overall outreach responsibilities for the Project, with emphasis on local education and information (i.e. outreach) efforts. Wolf education boxes have been provided to agencies for public forums; mounts of wolves are on display in various places in the BRWRA, with additional mounts expected in the future. Public outreach presentations have been initiated for schools, communities, and requesting groups. Permanent educational displays are being promoted for various locations. Traveling displays exist but are limited in number at the present; funding is being pursued to develop additional displays. Other educational materials such as brochures and posters have been created and are available from participating agencies. Signs have been developed and posted in wolf areas; additional sign postings are pending. Information has been included in Hunting and Recreation Regulations and made available with permits or hunt tags; presentations have been made at Hunter Safety Courses. Flyers have been made available and passed out to hunters prior to and during hunt seasons. A 24-hour report, information, and emergency phone line and a web-site to sign up for monthly updates are currently in place (see B-9, above). Monthly Project Updates are provided to the public at large via an electronic selfsubscription newsletter (Endangered Species Updates), at http://azgfd.gov/signup, and to certain interested or affected parties who have a specific need for more specific, current information are provided weekly updates after routine monitoring flights, via e-mail, fax, and by local postings. Personal contacts are also made via the phone or by one-on-one discussion with parties reporting wolf sightings or incidents. IFT field activities have been, and will continue to be, conducted to demonstrate wolf monitoring techniques. Wolf issues are discussed and coordinated on a regular basis during AMOC and AMWG meetings, which are held at least quarterly and more often as AC-25



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necessary. Wolf identification, behavior, and pertinent report information is coordinated for release to local media, including radio stations, television stations, and newspapers, especially prior to hunting seasons. Many Project-related articles have appeared in magazines, as well as professional journals. Partnerships have been established with local businesses and private organizations. Planning and development for educational outreach opportunities are a continuing and expanding part of the recovery program. The need for public education about measures by which to prevent or at least minimize risks associated with free-ranging animals, whether feral dogs or predatory wildlife, was underscored just as AMOC was completing this 5-Year Review. The event occurred in Canada, and might be highly relevant to the subject of human-wolf interactions in North America. On November 8, the body of 22-year-old Kenton Joel Carnegie, a 3rd-year survey crew intern with an energy exploration company, was found in northern Saskatchewan. Dr. Paul Paquet (personal communication, December 13, 2005) advises AMOC that a final Provincial Coroner's report is expected in January 2006, at which time it also will be made public. However, Dr. Paquet, a wolf expert well known to the Southwest as author of the 3-Year Review "Paquet Report" (Paquet et al. 2001), advises AMOC that preliminary investigation by law enforcement officials, and his own ongoing investigation for the Provincial Coroner, indicate a pack of four wild wolves might have attacked and killed the young man. However, death by wild dogs, with subsequent scavenging by wolves, had not yet been ruled out as this account was being written. If wolves are proven to have killed Mr. Carnegie, it would be the first documented human death attributed to healthy wild (free ranging) wolves in North America in at least 100 years (see McNay 2002a and 2002b). Canadian experts and officials speculate that several factors might have contributed to the attack. In particular, huge expansion of exploration and mining for oil, gas, precious metals, etc. has resulted in an explosion of "wildcat" dumps (i.e. unregulated dumps), which are well known to attract predators (and wild dogs) and to result in increased risk of negative human-wildlife interactions. The excerpted article below from the International Wolf Center is the most recent and thorough account available as to what might have occurred. It is included here in the 5-Year Review to ensure that it becomes part of the context for considering the issue of human-wolf interactions. Regardless of the final outcome of the investigations, the fatal incident and increasing prevalence of habituated wolves and wild dogs in Saskatchewan underscore the need to take precautions in minimizing risks, including: ensuring that garbage dumps (regulated and not) are maintained in such a way that bears, wolves, wild dogs, and mountain lions do not become habituated to them; never feeding free-ranging predators, especially not at arm's-length distances; never providing food to domestic dogs or other domestic animals in such a way that predators might be attracted, and maintaining ready access to deterrent sprays and other protective devices in case of approach closely; etc. AMOC SOP 13.0: Control of Mexican Wolves provides additional information on this subject, as do other public education materials disseminated by the Reintroduction Project.



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Finding: Educating people about wolf behavior (and the Reintroduction Project as a whole) is a never-ending process, thus this Paquet Report recommendation can only be described as "Being Implemented;" it will never be "Completed." B-11. Require livestock operators on public land to take some responsibility for carcass management/disposal to reduce the likelihood that wolves become habituated to feeding on livestock. Status: Not completed because it is a continuing need that is being addressed. Assessment: The 3-Year Review identified an issue concerning livestock carcasses. Simply stated, the concern was that free-ranging Mexican wolves that scavenge on domestic livestock carcasses become habituated, and subsequently depredate domestic livestock. This suspected behavior in turn results in management actions ranging from capture and translocation to permanent removal from the wild, sometimes by lethal control of the offending wolf. Scavenging in this context means that free-ranging wolves encounter a livestock carcass and feed on it. The animal might have died from any of a variety of causes other than attack by wolves. To put this issue into context, we reviewed the issue as outlined in the 5-Year Review and the findings in both the 3-Year Review Stakeholders Workshop final report and Paquet report. We conducted a thorough review to evaluate whether a carcass feeding issue does exist, and if so what its magnitude might be. First, we accessed the IFT's Mexican wolf "Incident Database" for all records of Mexican wolf carcass feeding, depredations, and subsequent management actions. Next, we reviewed information that the Center for Biological Diversity (CBD) had previously received under FOIA, to determine whether the IFT Incident Database contained all relevant information on depredations and carcass feeding. In reviewing the CBD data, we found that all carcass feeding and depredation events noted therein were in fact included in the Incident Database. We also examined land management agency (i.e. USDA Forest Service and USDI Bureau of Land Management) regulations and policies to determine if the agencies have policies or other authorities regarding this issue. Changes between Draft and Final 5 Year Review: The Draft 5-Year Review noted that 91 percent of the wolves involved with carcasses had also been involved with depredations. This "association" has been widely cited by interested parties during the 5-Year Review public comment period. However, further analysis indicates the 91 percent figure (see old Table 2 in the Draft Technical Component) is misleading, in that it was not based on analysis of the chronology of depredations and carcass feeding incidents. After preliminary internal review and discussion among AMOC and the IFT, we conducted a further review of depredation and carcass involvement data from the Draft 5-Year Review. Our primary focus was the chronology of the depredations and carcass involvement incidents. Three groupings emerged from this analysis: Group One involves 12 wolves that were clearly involved in a depredation incident prior to being seen feeding on a livestock carcass. Group Two involves six wolves that were seen feeding on a carcass that was the direct result of a depredation. Group AC-27



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Three involves five wolves that fed on a carcass and later depredated livestock. (Please refer to the following Analysis Section). Summary of Public Comments to the Draft 5 Year Review: AMOC solicited public comment on the Draft 5-Year Review through a variety of venues. Comments concerning the carcass issue can be summarized as follows: those who felt that the section should be removed from the document because it leads to increased conflict and animosity with the livestock industry; those who felt that carcass removal was not at all practical due to problems finding carcasses and the time and expense involved in disposal; those that felt removing carcasses would lead to further depredations; those that felt using the CBD data biased the results; those that felt the agencies should develop and/or enforce policies for carcass removal; and those that felt incentives for livestock owners should be developed to promote voluntary carcass removal. (Please refer to Response to Comments Section). 3-Year Review: Participants in the Stakeholders Workshop were organized into six working groups. One, the "Wolf-Livestock-Animal Conflict Working Group," identified finding and disposal of livestock carcasses as an "issue," and further identified lack of implementation of effective husbandry practices to decrease livestock-wolf conflicts as a "problem." This Working Group called for livestock producers and land management agencies to work together to develop guidelines for detection and disposal of livestock carcasses to reduce wolf-livestock conflicts. The 3-Year Review's Paquet Report addressed the livestock carcass issue in a section titled "Has the Livestock Depredation Control Program been Effective" (pages 52-85). The concluding remarks assert that "Similarly, livestock producers using public lands can make a substantive contribution to reducing conflicts with wolves through improved husbandry and better management of carcasses." The "Overall Conclusions and Recommendations" (pages 67 to 68) include a recommendation that "livestock operators on public land be required to take some responsibility for carcass management/disposal to reduce the likelihood that wolves become habituated to feeding on livestock." 5-Year Review: Building on the Paquet Report, with additional information from Project experience since 2001 and from public comment on the 5-Year Review, AMOC now offers an analysis of documented Mexican wolf livestock depredations and incidents of livestock carcass feeding. The information is this section was derived from the IFT's Incident Database and, for purposes of completeness and accuracy, was checked against information the CBD provided to AMOC that it had obtained via Federal FOIA. Table 2 displays information on wolves involved in known depredation incidents from 1998 through 2004: a total of 46 depredation incidents have been recorded; of those, 23 (50%) involved documented cases of wolves feeding on domestic livestock carcasses. Because this issue involves a suspected link between wolves scavenging on domestic livestock carcasses and subsequent depredation on domestic livestock, Table 2 presents data on wolf activities such as depredations and scavenging on livestock carcasses as well as management actions associated with each type of incident from capture to translocation. The current fate of each wolf (as of 2005) is also included in Table 2. AC-28



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Of the 46 wolves involved in known depredation incidents through 2004, 16 (35%) were involved in more than one depredation incident. Of these 46 wolves, 20 (43%) were removed from the wild for depredations; 24 (52%) were translocated into New Mexico; 11 (24%) were permanently removed from the wild population; and 19 (41%) died (Table 2; Note: because some wolves were assigned to multiple activity categories, percentages total more than 100). Of the 46 wolves involved in livestock depredations, 9 (20%) are currently in captivity and 8 (17%) remain in the wild (Table 3). In the Draft 5-Year Review, we reported that 91 percent of the 22 wolves involved in known livestock depredations had fed on livestock carcasses. Between Draft and Final, we took a further look at the data and separated it by the chronology of depredations versus the chronology of confirmed carcass feeding events. As a result of this analysis, our results have changed and the way we are reporting them has changed. In addition, the sample size increased by 1 from 22 to 23 wolves involved with both carcasses and depredations. By looking at the chronology of the depredation and carcass feeding incidents, three groupings emerged: Group One involves 12 wolves that were clearly involved in a depredation incident prior to being seen feeding on a livestock carcass. Group Two involves six wolves that were seen feeding on a carcass that was the direct result of a depredation. Group Three involves five wolves that fed on a carcass and later depredated livestock. Table 3 reveals that 5 of the 46 wolves (11%) with records of suspected or confirmed depredations had fed on carcasses prior to their documented depredation incident(s). The 12 wolves in Group One were involved in depredations prior to any documented carcass feeding event. Six wolves in Group Two were seen feeding on a livestock carcass clearly associated with a depredation incident. Only the five wolves in Group Three were known to have fed on a livestock carcass prior to being involved in a depredation incident; this amounts to 11% of all wolves known to have depredated or suspected of depredations in the BRWRA. Table 4 displays the "locations" of the five wolves identified in Group Three. Federal Land Management Agency Regulations and Policies Concerning Domestic Livestock Carcass Removal: USDA Forest Service and USDI Bureau of Land Management are the two principal federal land management agencies involved in or affected by Mexican wolf reintroduction and recovery. Neither agency has authority by law, regulation, or policy to require a permittee to remove dead livestock, render dead livestock unpalatable, or bury dead livestock on public lands where domestic livestock grazing is authorized. However, if a permittee voluntarily wanted to commit to such actions, both agencies could write such a commitment into the permittee's grazing permit. Authority for such mutually agreed-upon actions (essentially, self-imposed commitments) stems from (BLM) 43 CFR Chapter II �4130.3-2 (other terms and conditions) and (Forest Service) 36 CFR 222 and Forest Service Handbook 2209.13 �16.11 (Modification After Issuance). These allow each agency to address the issue of requiring the removal of livestock carcasses, rendering dead livestock unpalatable or burying dead livestock through individual grazing lease/permit authorizations or modifications.



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State Statutes Pertaining to Carcass Disposal: The carcass disposal issue is also constrained by AZ and NM State Law. The following Statutes have bearing on whether livestock carcasses can be removed from public lands, to reduce risk of wolves or other predators feeding on them. Arizona (Note: this information was taken from Arizona's on-line Statutes, which are available at http://www.azleg.state.az.us/ArizonaRevisedStatutes.asp) Chapter 11, Article 4, Section 3-1293. Procedure for owner to authorize another person to deal with animals; violation A. A person who desires to authorize another person to gather, drive or otherwise handle animals bearing the recorded brand or mark owned by the person granting the authority, or animals of which he is the lawful owner but which bear other brands or marks, shall furnish the other person an authority in writing which lists the brands or marks authorized to be handled, and authorizes the other person to gather, drive or otherwise handle the animals described. If a person who gives written authority for the purposes provided in subsection A inserts therein any brand or mark of which he is not the lawful owner and an animal bearing such brand or mark is unlawfully taken, gathered, driven or otherwise unlawfully handled by virtue of the written authority by the person to whom the written authority was given the person giving the written authority shall be deemed a principal to the unlawful taking, gathering, driving or handling of such animals.



B.



Chapter 11, Article 4, Section 3-1302. Taking animal without consent of owner; classification A person who knowingly takes from a range, ranch, farm, corral, yard or stable any livestock and uses it without the consent of the owner or the person having the animal lawfully in charge is guilty of a class 2 misdemeanor. Chapter 11, Article 4, 3-1308. Evidence of illegal possession of livestock Upon trial of a person charged with unlawful possession, handling, driving or killing of livestock, the possession under claim of ownership without a written and acknowledged bill of sale, as provided by section 3-1291, is prima facie evidence against the accused that the possession is illegal. Chapter 11, Article 4, 3-1303. Driving livestock from range without consent of owner; classification When livestock of a resident of the state is intentionally driven off its range by any person, without consent of the owner, the person is guilty of a class 5 felony.



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Chapter 11, Article 4, 3-1307. Unlawfully killing, selling or purchasing livestock of another; classification; civil penalty; exception A. A person who knowingly kills or sells livestock of another, the ownership of which is known or unknown, or who knowingly purchases livestock of another, the ownership of which is known or unknown, from a person not having the lawful right to sell or dispose of such animals, is guilty of a class 5 felony. A person who knowingly attempts to take or does take all or any part of a carcass of any such animal, pursuant to subsection A, for such person's own use, the use of others or for sale is guilty of a class 5 felony. In addition to any other penalty imposed by this section, a person depriving the owner of the use of his animal or animals under subsection A or B of this section shall be liable to the owner for damages equal to three times the value of such animal or animals. This section shall not apply to taking up animals under the estray laws.



B. C.



D.



New Mexico (Note: this information was taken from New Mexico's on-line Statutes, which are available at http://www.lawsource.com/also/usa.cgi?nm) Article 9. Section 77-9-45. Ownership; possession; transportation; seizure; disposition of livestock; refusal of certificate. If any duly authorized inspector should find any livestock or carcasses in the possession of any person, firm or corporation for use, sale or transporting by any means, and said person, firm or corporation in charge of said livestock or carcasses is not in possession of a bill of sale, duly acknowledged, or cannot furnish other satisfactory proof of lawful ownership or said inspector has good reason to believe that said livestock or carcasses, are stolen, said inspector shall refuse to issue a certificate authorizing the transportation of said livestock or carcasses, and shall seize and take possession of same. Livestock Industry Perspective in the Southwest: Both the Arizona and New Mexico Cattle Growers Associations are on public record in Mexican Wolf Adaptive Management Work Group meetings as opposing any mandatory removal of dead livestock from public lands. Finding: Five (11%) of the 46 wolves known to have been involved in a depredation incident had fed on a livestock carcass prior to committing a depredation. Of these five wolves, two remain in the wild, one is "fate unknown," and two have been permanently removed from the wild. This sample size is too small to support even preliminary, let alone definitive, conclusions as to correlations, trends, or "depredation predisposition" resulting from carcass feeding. Federal land management agencies do not have the authority to require lease/permit holders to remove livestock carcasses from public land. Permittees can voluntarily commit to such actions, and these commitments could be written into their BLM or USFS grazing permit if the permittee



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so desired (i.e. perhaps in exchange for incentive payments of some sort?). The livestock industry in the Southwest opposes mandatory removal of livestock carcasses from Federal lands. In light of the above: 1. AMOC will develop, no later than June 30, 2006, a report describing a proposed Federally, State, and/or Tribally-funded incentives program to address known and potential economic impacts of wolf nuisance and livestock depredation behavior on private, public, and Tribal Trust lands. AMOC may convene, if necessary, a technical advisory group of individuals with appropriate expertise to assist with this task. The conservation incentives discussion will consider all relevant livestock depredation issues, including: livestock depredation prevention; livestock depredation response; carcass discovery, monitoring, removal, burial, and/or destruction; and possible adjustment of the Federal grazing (AUM) fee (and any Tribal grazing subsidies) within the MWEPA to provide de facto compensation for documented and likely undocumented losses of livestock. The AMOC report shall also include a thorough evaluation of the effectiveness and procedural efficiency of the Defenders of Wildlife wolf depredation compensation fund, and provide recommendations for appropriate improvements. Note: (a) The technical advisory group, if convened, shall be chaired by an AMOC representative and include a maximum of 15 other members, each with appropriate expertise. (b) AMOC as a body will not advocate regulatory changes to address carcass removal or disposal issues. 2. AMOC will convene a stakeholders group to assist AMOC in evaluating, and reporting in writing no later than December 31, 2006, social (human and socioeconomic) implications (including estimated annual livestock depredation losses) for any boundary expansions recommended. Note: The stakeholders advisory group will be Co-Chaired by an AMOC representative and an AMWG Cooperator (County) representative, and include a maximum of 50 other members, representing, insofar as is possible, the full spectrum of stakeholders. This group will comply with FACA, if necessary. 3. No later than March 1, 2006, AMOC will convene a science and research advisory group. The group will review, on a continuing basis, current and proposed management practices and recommend research priorities for AMOC to advocate to external entities and the cooperating agencies on all aspects of the Reintroduction Project. Review tasks will include, but not be limited to: overall Reintroduction Project effectiveness, statistically reliable wolf survey and population monitoring techniques, wolf population dynamics (demographics), prey base dynamics, total predator loads, seasonal wolf livestock depredation rates, annual wolf impacts on native ungulate populations, prey base monitoring techniques appropriate to determining when prescribed unacceptable levels of impact on native wild ungulates have been met or exceeded, wolf-related disease occurrence and prevention, seasonal livestock depredation rates, prevention and/or remediation of wolf nuisance and livestock depredation problems, livestock husbandry, wolf-related tourism, socioeconomics, and human dimensions.



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4. AMOC will advocate creating an IFT position in the Alpine field office to work with cooperators and stakeholders throughout Arizona and New Mexico on proactive measures by which to avoid or minimize wolf nuisance and livestock depredation problems. Note: AMOC as a body will not advocate regulatory changes to address carcass removal or disposal issues (but see Recommendation [12], above, regarding a process by which AMOC will explore possible mechanisms to address this issue). B-12. When writing or lecturing about the project, the Service should emphasize a community approach to understanding the wolf reintroduction project and its effect on other species and ecological processes Status: Not completed because it is a continuing need that is being addressed. Assessment: Apparently, Paquet et al. (2001) presumed that only USFWS had a role or stake in guiding and implementing the Reintroduction Project. What caused that presumption is moot. In any event, this recommendation from the Paquet Report and indeed all others apply to all Lead Agencies, not just to USFWS, thus AMOC responds along those broader lines. This recommendation appears to be based on the Paquet Report's rationale that "Conservation policy is shifting away from the preservation of single species toward preservation and management of interactive networks and large scale ecosystems...." Although the authors did not provide specific references for this statement, their review does discuss changes in entire food webs that can result from disruption of top predator populations (e.g. McLaren and Peterson 1994, Terborgh et al. 1999). The authors also discuss the effects of wolves on prey survival and behavior (e.g. Nelson and Mech 1981, Ballard et al. 1987, Messier 1994), and influences of prey densities on wolf demographics (e.g. Messier 1985, Fuller 1989). The driving authorities and policy leading to re-establishment of Mexican wolves within the BRWRA were the ESA, the 1982 Mexican Wolf Recovery Plan, and State and Tribal laws and regulations pertaining to wildlife management and conservation. Although the ESA calls for conservation of ecosystems that support listed species, the majority of its protections and regulations are directed at the single-species (as opposed to ecosystem) level. State and Tribal wildlife agency authorities for management and conservation also focus on individual species, rather than habitats. Even public land management agencies, which have mandates to provide for a multitude of land uses, and extensive authority over wildlife habitat, have specific direction regarding individual wildlife species that may be given special status for management or planning purposes. Therefore, while the statement that "conservation policy is shifting...toward preservation and management of interactive networks" may be reflective of the current academic and even public understanding of the importance of landscape-level factors in conservation of wildlife (particularly large carnivores), it has yet to be manifested in significant changes to the State, Federal, and Tribal legal and policy frameworks that guide Mexican wolf reintroduction. Despite the lack of a clear ecosystem-level mandate related to Mexican wolf reintroduction, community-level changes remain an interest of many of the involved or affected agencies and stakeholders. Possible impacts to game populations are of strong interest to State Wildlife AC-33



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Agencies, sportsmen, and those involved in or supported by hunting-related industries. Similarly, questions are frequently raised regarding possible impacts of wolves on industries such as ranching, either through direct or indirect impacts that could result from effects to secondary carnivores (e.g. coyotes), ungulate populations, alternate prey populations, or even primary producers (plants). At this time, little information is available to answer these community-level questions regarding Mexican wolf reintroduction. AMOC has not attempted to quantify a broad array of ecosystem parameters for the explicit purpose of pre- and post-reintroduction comparisons. Also, because the objective for number of wolves to be established within the BRWRA has yet to be reached, community-level influences of wolves may not yet be detectable. Density of wolves within the 17,752 km2 BRWRA is estimated at approximately 3 wolves/1,000 km2. This density is at the far lower end of wolf densities where authors such as Ballard et al. (1987) (range of ~3 wolves/1,000 km2 after wolf control to ~10 wolves/1,000 km2 before control), Parker (1973) (range of 2 wolves/1,000 km2 to 28-50 wolves/1,000 km2 concentrated on prey winter range), and Hayes et al. (2003) (1.7 wolves/1,000 km2 after wolf control and 6.0 wolves/1,000 km2 before) evaluated interspecific interactions at multiple wolf densities. In comparison, wolves on Isle Royale have represented the high end of wolf densities found in North America, up to 91/1,000 km2, (Peterson and Page 1988), and currently exist at about 50 wolves/1,000 km2 in Yellowstone's northern range (Smith et al. 2003). Although it is expected that populations of ungulate prey, alternate prey, competing predators, and the amount of primary production would be decreased in more arid wolf habitats, such as the Southwest, these parameters have not all been quantified within the BRWRA or within other wolf study areas. Therefore, it is difficult for AMOC to provide unequivocal information at this time regarding any landscape-level changes that might occur through Mexican wolf reintroduction. More time is needed for the wolf population to grow, and for effects to be determined through focused research. Paquet et al. (2001) acknowledged this, stating that wolf reintroduction has influenced the carnivore guild (wolves, bears, coyotes, mountain lions) within the northern Rocky Mountains (where wolves had already approached or surpassed recovery levels), but recommending research within the BRWRA regarding interaction of wolves with other carnivores to inform future Mexican wolf reintroduction project evaluations and adjustments. Finding: Based on the information above, the recommendation from the 3-Year Review that "When writing or lecturing about the project, the Service should emphasize a community approach to understanding the wolf reintroduction project and its effect on other species and ecological processes" (Paquet et al. 2001) is not considered appropriate at this time. Rather, this recommendation is replaced with a related one that: When writing or speaking about the Mexican wolf reintroduction project, entities cooperating in Mexican wolf reintroduction should accurately reflect the available current information regarding projected and realized community and ecosystem-level functions involving Mexican wolves in all appropriate outreach materials and Project reports or presentations. Wherever



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possible, they should also support studies, monitoring, and analyses to evaluate any communitylevel changes that might result from Mexican wolf reintroduction. Specifically: 1. No later than March 1, 2006, AMOC will convene a