Endangered and Threatened Wildlife and Plants; Request for Information on Implementation of the Gray Wolf (Canis Lupus) Nonessential Experimental Population Rule in Colorado

The Colorado Conservation Alliance opposes the implementation of the Gray Wolf reintroduction program, arguing that the 2020 Proposition 114 mandate was based on fraudulent election results. They request that the U.S. Fish and Wildlife Service reconsider its memorandum of understanding with the Colorado Parks and Wildlife based on their provided analysis of the election.

The Associated Governments of Northwest Colorado (AGNC), a statutory council of governments, opposes the current implementation of the gray wolf nonessential experimental population rule in Colorado. They argue that the state has failed to provide adequate management tools, transparency, and compensation for livestock producers, and they request that the federal government impose stronger sideboards and reevaluate the necessity of the current framework.

The Western Landowners Alliance, a nonprofit representing livestock producers and land managers, supports the continued management flexibility provided under the 10(j) rule for gray wolves in Colorado. They argue for a balanced approach that combines early nonlethal conflict prevention with timely, targeted lethal removal for chronically depredating packs to protect the economic viability of working lands.

The Colorado Nature League, a nonprofit conservation organization, supports the continued implementation of the 10(j) Rule for gray wolves in Colorado. They argue that the program is currently successful, that more wolves are needed to create a self-sustaining population, and that the state's nonlethal deterrence and compensation programs are effective.

Forest Service Employees for Environmental Ethics (FSEEE), a nonprofit organization, supports the continued implementation of the Colorado gray wolf reintroduction program under the 10(j) Rule. They argue that the program is successfully meeting the Endangered Species Act's recovery mandate and advocate for improved funding, better communication with producers, and the creation of an independent advisory board to manage the program effectively.

Several members of Congress are expressing concern over Colorado's wolf reintroduction program, arguing that it is poorly funded, lacks scientific backing, and negatively impacts the agricultural industry. They advocate for a pause or suspension of the program, citing high costs, low survival rates of translocated wolves, and the lack of support from the state's wildlife management agency.

The State of Utah is submitting comments expressing opposition to the current implementation of the gray wolf nonessential experimental population rule in Colorado. They argue that the rule imposes unmitigated financial and ecological burdens on Utah's agricultural sector and rural communities due to "border spillover," and they call for stricter federal oversight, clearer "take" definitions, and proactive federal funding for adjacent states.

The Colorado Public Lands Council (CPLC), representing livestock producers on federal grazing permits, supports the implementation of the Gray Wolf Nonessential Experimental Population Rule provided it maintains management flexibility for livestock operations. They argue that the rule must ensure timely conflict response, equal treatment for public and private land grazing, and that wolf restoration should not result in the reduction of authorized livestock grazing.

The Colorado Cattlemen’s Association (CCA) opposes the current implementation of the Gray Wolf Nonessential Experimental Population Rule, arguing that it fails to adequately address livestock depredation, conflict mitigation, and producer compensation. They are requesting a pause on additional wolf releases until existing management deficiencies, such as inconsistent chronic depredation standards and insufficient agency staffing, are resolved.

The Public Lands Council (PLC), National Cattlemen’s Beef Association (NCBA), Colorado Public Lands Council (CPLC), and Colorado Cattlemen’s Association (CCA) are advocating for the proper implementation of the 10(j) rule to manage gray wolves in Colorado. They argue that the federal government must ensure management flexibility, including timely lethal take for chronic depredation, robust and inclusive compensation for livestock losses, and improved communication and coordination with producers. They specifically urge the U.S. Fish and Wildlife Service to resolve existing management deficiencies and address the economic impacts on livestock operations before proceeding with additional wolf releases.