Dr. Nathan Roberts’ Expert Testimony to Congress on Delisting the Gray Wolf
The Subcommittee on Water, Wildlife and Fisheries
Legislative Hearing on H.R. 276, H.R. 845, H.R. 1897 & H.R. 1917
Submitted by Nathan M. Roberts, PhD.
March 22, 2025
Good morning, Chair Hageman, Ranking Member Hoyle, and committee members.
I appreciate the opportunity to be here today to discuss wolf management and The Pet and Livestock Protection Act. With 25 years of experience in wildlife management, I have worked with federal and state agencies, academic institutions, and the conservation organization Hunter Nation. Wildlife management aims to maintain the long-term viability and sustainability of wildlife populations and seeks to enhance the positive contributions of these species while also reducing their negative impacts on people and ecosystems. Managing carnivores is complex and challenging due to various factors, including their intricate ecological impacts (both positive and negative), the potential for conflicts, differing public interests, and a complex legal and regulatory framework.
Wildlife managers successfully address these challenges using a range of well-established tools and strategies. Regulations and policies are carefully designed to meet specific conservation goals. In some cases, this means temporarily prohibiting the take of a species, while in other cases, regulated take may be allowed. In some cases, conflicts can be managed through non-lethal methods, but in other cases, lethal methods may be necessary. Similarly, in some situations, the best approach may be reactive and to respond to conflicts after they occur while in other cases, it may be most effective to be proactive and reduce the probability of conflicts by managing population size or habitats. There is a time and place for each of these approaches, but there is not a single approach that is appropriate for all cases. State wildlife agencies are best equipped to make these decisions as they have the local knowledge and experience needed. It is critical for wildlife managers to have a diverse toolbox, equipped with a variety of approaches and techniques, to employ to achieve conservation objectives.
The management of wildlife is the primary responsibility of state fish and wildlife agencies. When a species is listed under the Endangered Species Act, the federal government temporarily assumes management authority until the species recovers and is no longer at immediate risk of extinction. During this temporary period, certain conservation tools that are typically used to achieve management goals may be restricted while the species is at the greatest risk of extinction. The problem comes when the ESA is abused, the intent of the Act is distorted, and species remain listed for decades after recovery goals are met, denying professional state wildlife managers the use of all the conservation tools in their toolbox. The gray wolf is a prime example of these problems.
The gray wolf in the United States is clearly recovered and stable, yet it remains listed as an endangered species. The recovery plan established for the Great Lakes region set specific numeric goals as criteria for determining successful recovery that have been surpassed every year since at least 1994, with an estimated 4,000 to 5,000 wolves in this region alone. The Department of Interior has issued numerous rules to delist wolves, only to have these rules vacated through litigation. Despite exceeding the population criteria for restoration by more than ten-fold, wolves remain listed, and state agencies still do not have management authority, or their toolbox, restored.
While wolves they may not occupy their entire historic range, the overall population in the United States remains secure and in no danger of extinction. State wildlife agencies have demonstrated their ability to effectively manage wolves, as well as other wildlife. In the Rocky Mountains, wolves have been delisted for many years, there may be debate over specific management strategies, but there is no question that wolves continue to inhabit and thrive in this region.
Keeping wolves listed is inappropriate and harmful to overall conservation efforts, weakens the integrity of the ESA, and misallocates limited conservation resources. The ongoing cycle of litigation, ignoring established scientific recovery benchmarks, creates a disincentive for landowners and jurisdictions to engage in species recovery and states are needlessly restricted from effectively managing wolf populations and implementing proactive strategies, such as maintaining populations within a designated range, to achieve wildlife management goals that maximize positive benefits, minimize negative impacts, while also ensuring the species' long-term viability.
The Pet and Livestock Protection Act would formalize what the Department of the Interior has repeatedly stated under multiple presidential administrations—that gray wolves are recovered, have exceeded the established delisting criteria, and that states should regain management authority as originally intended under the ESA. Gray wolves are recovered in the United States and state fish and wildlife agencies possess both the capacity, and a proven track record in species management and recovery, to manage gray wolves effectively and sustainably for the benefit of the public they serve. The Endangered Species Act is well-intentioned but has been exploited and misused in ways that undermine both conservation efforts and public trust. The bills discussed today will promote responsible wildlife management and stewardship, helping to restore balance and ensure effective conservation practices.
Thank you again for the opportunity to address this important issue.