On June 13, 2013, the U.S. Fish and Wildlife Service (FWS) proposed removing the gray wolf, Canis lupus, from the List of Endangered and Threatened Wildlife. At that time, I wrote an article and submitted an official comment, arguing that the 2013 Proposed Rule was capricious, arbitrary, and inconsistent.
Now, almost six years later, the FWS proposes to “delist” Canis lupus again. However, the logic underlying the 2019 Proposed Rule is no better than the logic underlying 2013 Proposed Rule. Comparing the two a bit, focusing on the wolves in the Pacific Northwest (western Washington and western Oregon) and California, will make that evident.












