If you and your family were the last remaining members of humanity, would you consider your existence essential to the future of humans? The answer seems obvious: your life (and ability to reproduce) in this doomsday scenario would of course be essential to the survival of humanity.

I present this scenario not because I have been reading too many articles about the climate crisis and Covid-19, but because, despite the fact that there is only one small population of 186 highly-related Mexican gray wolves roaming in American wildlands, the US Fish and Wildlife Service (USFWS) still does not consider them essential to the survival of the species in the wild.

After being exterminated from the American Southwest, Mexican gray wolves, saved by the capture and captive breeding of a few wild wolves in Mexico, were reintroduced to the region beginning in the late 1990s. They are listed as endangered under the federal Endangered Species Act (ESA), and are managed under section 10(j) of the ESA, which authorizes experimental population designations for imperiled animals reintroduced in isolated areas. In their new proposed 10(j) management rule, released in October, the USFWS explains, “we determined that the experimental population was not essential to the survival of the species in the wild based on the current and expected future availability of Mexican wolves in captivity that would be available for release to the wild.”

In other words, the only wolves of their kind alive in the wild are not essential to the survival of wild wolves because captive wolves exist. According to this illogic, it seems the goal is really not to have a self-sustaining population of lobos in the wild, nor to establish an ecologically effective, self-sustaining population.

The designation of the population as “essential” by the federal government is crucial because it triggers additional, much-needed ESA protections, including designating critical habitat, for a species on the brink. The USFWS seems doomed to repeat the mistakes of its red wolf recovery program — where, after the population peaked at over 130 wolves in 2006, it plummeted to the current eight wolves in the wild.

This tragic failure of the USFWS to protect wild wolves could happen again to Mexican gray wolves unless major policy reforms are adopted.

The 10(j) rule-making process is a clear opportunity for needed reforms to Mexican gray wolf conservation. Although there are a few bright spots in the proposed rule (for example, lifting the population cap of 320 wolves, which is an improvement but still too low and after which states will clamor for lethal removal), it fails to include evidence-based best practices to prevent conflict and promote true species conservation.

First, the rule fails to change the lobos’ status to an essential experimental population that would enhance protections and allow critical habitat designation. Second, it fails to enact practices, such as releasing bonded mates with pups in addition to current cross-fostering practices (where genetically important pups born in captivity are surreptitiously added to wild litters), that would enhance the genetic diversity of a species rebounding from a severe bottleneck of only seven unrelated individuals by 1980. Third, it fails to take proactive actions like reforming husbandry practices to prevent conflict between livestock and wildlife before it ever occurs.

Additionally, it prohibits lobos from freely dispersing to habitats they determine to be suitable. The current proposed rule fails to remove or revise the arbitrary, politically-motivated northern boundary of the lobo recovery area, which is currently defined by Interstate-40 (I-40), not by suitable habitat. Excellent lobo habitat and available prey abound above I-40 and will be especially important as climate change shifts species distributions northward, but the USFWS and other cooperating agencies will continue to trap and relocate wolves who cross the interstate.

The best available science identifies expansion of lobo range northward as critical for recovery, as well as addressing the other failures outlined above. But if science does not sway, consider the true adventure story of Anubis, the intrepid young wolf who insists on reminding us of what we should already know: wolves wander.

Born in 2020 in the Dark Canyon Pack of the Gila National Forest in New Mexico, in April and May of 2021 Anubis traveled more than 400 miles to the Flagstaff area of the Coconino Plateau where he minded his own business for four months until the Arizona Game & Fish Department captured and relocated him to the Apache-Sitgreaves National Forest this past August.

He immediately traveled 200 miles to return to his preferred home in the Coconino. Anubis is like any wolf; he is resilient, he is a generalist, he can make a living wherever there is wild prey. He can thrive above Interstate-40. If the USFWS would lift their arbitrary (or more accurately, politically-motivated) limits to lobo range, he might find a mate with similar tenacity and wanderlust and found a much-needed additional population of lobos in the wild.

We are living in an age of crisis for all life. For lobos, both past and future keys to dealing with crises lie in their genetic diversity. Thus, we need to do everything we can to preserve their genetic heritage and give them the keys to success in an uncertain future.

You can speak up now to urge the USFWS to propose a 10(j) rule that includes the practices essential to recovery of this essential lobo population. The USFWS proposal has been published to the Federal Register (docket # FWS–R2–ES–2021–0103) and comments are due January 27, 2022.

There are two scheduled virtual information sessions, followed by public hearings with comment opportunities, on December 8 and January 11. You can read the proposed rule and register for the sessions and hearings on the USFWS website. Use these talking points to draft and submit your comment to USFWS today.