Petition to Maintain Protections for Gray Wolves (Canis lupus) in the Lower 48 States as Endangered or Threatened “Distinct Population Segments” Under the Endangered Species Act December 17, 2018 Authored By: Center for Biological Diversity The Humane Society of the United States December 17, 2018 David Bernhardt, Deputy Secretary of the Interior U.S. Department of the Interior 1849 C Street NW Washington, DC 20240
[email protected] Margaret Everson, Principal Deputy Director U.S. Fish and Wildlife Service 1849 C Street NW Washington, DC 20240
[email protected] Dear Deputy Secretary Bernhardt and Principal Deputy Director Everson: Pursuant to 16 U.S.C. § 1533(b)(3) of the Endangered Species Act (“ESA”) and its implementing regulations, 50 C.F.R. § 424.14, as well as section 5 U.S.C. § 553 of the Administrative Procedure Act (“APA”), the Center for Biological Diversity and The Humane Society of the United States hereby petition the U.S. Department of the Interior (“DOI”), and the U.S. Fish and Wildlife Service (“Service” or “FWS”), to change the existing listing for the gray wolf (Canis lupus), excluding the Mexican wolf subspecies (Canis lupus baileyi),1 into one or several “distinct population segments” (“DPSs”) that encompass the entire range of the gray wolf in the conterminous U.S. This petition requests one of three alternative DPS designations: 1) a DPS for the entire lower 48 States; 2) “Western” and “Eastern” DPSs; or 3) regional DPSs for the West Coast, Southern Rocky Mountains, Northern Rocky Mountains, Northeast, and Midwest. Such biologically-sound DPSs should be assigned ESA listing statuses according to the best available science, as described in this petition.