Hello,
The U.S. Fish and Wildlife Service announced this week (see below) that it no longer intends to issue a nationwide recovery plan for gray wolves. This is a disappointing and dangerous policy reversal by the Trump administration. My thoughts are below.
“I’m appalled that Trump wants to strip gray wolves of federal protections and turn their management over to states that are dead set on killing them,” said Collette Adkins, senior attorney and Carnivore Conservation director at the Center for Biological Diversity. “Courts have repeatedly made it clear that our country’s gray wolves have not recovered in places like the southern Rocky Mountains and West Coast. We’ll challenge the Trump administration’s unlawful decision to once again abandon wolf recovery, and we’ll win.”
This decision is unlawful because wolves remain protected under the Endangered Species Act in places like the southern Rockies, West Coast and Northeast. These wolves still need recovery plans under the law.
Please reach out with any questions.
Thank you,
Collette Adkins
Carnivore Conservation Director
Center for Biological Diversity
[email protected]
(651) 955-3821
Recovery Planning Exception Findings for the 44-State and Minnesota Listed Entities of Gray Wolves (Canis lupus)
U.S. Fish and Wildlife Service
Headquarters Ecological Services Office Falls Church, Virginia
With major contributions from:
Pacific Region Southwest Region Midwest Region Northeast Region Mountain-Prairie Region Pacific Southwest Region
November 2025
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PURPOSE AND DISCLAIMER
The gray wolf recovery planning exception findings present the U.S. Fish and Wildlife Service’s (Service) review of information regarding whether a recovery plan would promote the conservation of the species. As detailed below, we found that recovery plans would not promote the conservation of the gray wolf 44-State or Minnesota listed entities because listing these entities is no longer appropriate under 4(a)(1) of the Endangered Species Act (Act) and measures provided pursuant to the Act are no longer necessary. A consequence of our findings that a recovery plan would not promote the conservation of the two gray wolf listed entities is that recovery plans are no longer statutorily required under the Act and the Service will not develop recovery plans for them. However, these findings do not affect any other provisions of the Act. All other provisions of the Act still apply while the two entities remain listed, including sections 7, 9, and 10 of the Act, consistent with any designated critical habitat, and any regulations issued under sections 4(d) and 10(j) of the Act.
If circumstances for gray wolves change in the United States and new information becomes available indicating a recovery planning exception is no longer appropriate, the Service at that time, could consider whether to engage in recovery planning.
1. BACKGROUND
The gray wolf (Canis lupus) is currently listed as: (1) an endangered species in all or portions of 44 of the contiguous United States and Mexico (44-State entity); and (2) a threatened species in Minnesota (MN entity). The findings address recovery planning for these two gray wolf entities as they appear on the List of Endangered and Threatened Wildlife at 50 CFR 17.11.
The geographic scope of current gray wolf entities listed under the Act at 50 CFR 17.11 are: • Endangered species in 44 States within the contiguous United States, and Mexico:
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ο All of AL, AR, CA, CT, DE, FL, GA, IA, IN, IL, KS, KY, LA, MA, MD, ME, MI, MO, MS, NC, ND, NE, NH, NJ, NV, NY, OH, OK, PA, RI, SC, SD, TN, TX, VA, VT, WI, and WV; and portions of AZ, NM, OR, UT, and WA as follows:
(1) Northern AZ (that portion north of the centerline of Interstate Highway 40); (2) Northern NM (that portion north of the centerline of Interstate Highway 40);
(3) Western OR (that portion of OR west of the centerline of Highway 395 and Highway 78 north of Burns Junction and that portion of OR west of the centerline of Highway 95 south of Burns Junction);
(4) Most of UT (that portion of UT south and west of the centerline of Interstate Highway 84 and that portion of UT south of Interstate Highway 80 from Echo to the UT/WY Stateline); and
(5) Western WA (that portion of WA west of the centerline of Highway 97 and Highway 17 north of Mesa and that portion of WA west of the centerline of Highway 395 south of Mesa); and
(6) Mexico.
A complete discussion of gray wolf biology and ecology, as well as a history of regulatory actions and recovery planning for the gray wolf can be found at 85 FR 69778; November 3, 2020.
ESA Recovery Planning Requirements
Section 4(f)(l) of the Act directs the Service to develop and implement recovery plans for the conservation and survival of endangered and threatened species, “unless [the Service] finds that such a plan will not promote the conservation of the species.” Conservation is defined in Section 3(3) of the Act as “... the use of all methods and procedures which are necessary to bring any endangered species or threatened species to the point at which the measures provided pursuant to this Act are no longer necessary.” The definition of conservation is further supported by the Service’s regulatory definition of recovery meaning “improvement in the status of listed species to the point at which listing is no longer appropriate under the criteria set out in section 4(a)(1) of the Act” (50 CFR 402.02). In the context of recovery planning this means that the Service includes in recovery plans all methods necessary to bring a listed species to the point at which protection under the Act is no longer necessary. Thus, per the statutory and regulatory language above, we can only decline to develop a recovery plan when it would not benefit the species through contributing to its recovery.
2. RECOVERY PLANNING EXCEPTION FINDINGS
The Service’s most recent status reviews for listed gray wolves determined that neither listed entity (44-State or MN entities) meet the definitions of a threatened species or endangered species under the Act according to the best scientific and commercial data available (85 FR
ο CO (nonessential experimental population)
• Threatened species in the state of Minnesota.
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69778, November 3, 2020).1 With these determinations, we conclude that listing is no longer appropriate under 4(a)(1) of the Act and measures provided pursuant to the Act are no longer necessary. Both listed gray wolf entities are no longer in need of conservation under the Act due to recovery. We therefore conclude that recovery plans for these two entities would not promote their conservation.
We base these conclusions on our 2020 status reviews for gray wolves in the 44-State and MN entities. We also reviewed subsequent analyses for information or conclusions that could cause us to reconsider these conclusions. We summarize our 2020 status review and subsequent analyses below.
Summary of 2020 Status Review and Determinations
In our 2020 status review (85 FR 69778, November 3, 2020), for each listed gray wolf entity, we evaluated human-caused mortality (Factor C); habitat and prey availability (Factor A); disease and parasites (Factor C); genetic diversity and inbreeding (Factor E); commercial, recreational, scientific, or educational uses (Factor B); climate change (Factor E); and other threats singly and in combination. We also evaluated state, Tribal, and federal agency wolf management and regulatory mechanisms that will be in place following delisting.
Based on our analysis, we concluded that Minnesota will maintain an abundant and well- distributed wolf population that will remain above recovery levels for the foreseeable future (85 FR 69881), and that the primary threat of human caused mortality has been sufficiently addressed. Minnesota’s wolf management laws, plans, and regulations adequately regulate human-caused mortality (85 FR 69881).
We also concluded that Wisconsin and Michigan will maintain an abundant and well distributed wolf population in their states above recovery levels for the foreseeable future (85 FR 69883), and that the threat of human-caused mortality has been sufficiently reduced (85 FR 69883). Both states have wolf-management laws, plans, and regulations that adequately regulate human- caused mortality (85 FR 69883). Further, while relatively few wolves occurred in the west coast portion of the 44-State entity at the time of the status review, the state wolf-management plans for California, Washington, and Oregon include recovery objectives intended to ensure the reestablishment of self-sustaining populations in these states (85 FR 69883). In addition, we expected wolves in the delisted Northern Rocky Mountain Distinct Population Segment (DPS) and western Canada to continue to expand into unoccupied suitable habitats in the Western United States, as envisioned in state wolf conservation and management plans (85 FR 69883).
1 Our 2020 delisting rule was vacated and remanded by a district court in Defs. of Wildlife v. FWS, 584 F. Supp. 3d 812 (N.D. Cal. Feb. 10, 2022). We are appealing the district court’s decision to the 9th Circuit Court of Appeals.
The Appellate court has not yet ruled on our appeal (and has not yet scheduled oral argument; briefing was completed in the spring of 2025). However, in Center for Biological Diversity v. Halaand, 2023 U.S. Dist. LEXIS 139815 (D.D.C. Aug. 11, 2023), the U.S. District Court for the District of Columbia acknowledged that although the 2020 delisting rule had been vacated by the Northern District of California, the vacatur did not change the fact that the Service had conducted 5-year status reviews for the two listed gray wolf entities (44-state and MN entities) as part of that rule.
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We determined that none of the factors we evaluated are of sufficient imminence, intensity, or magnitude to indicate that the 44-State or MN entities are in danger of extinction or likely to become so within the foreseeable future throughout all or a significant portion of their ranges. We also determined that recovery efforts resulted in a significant expansion of wolves in the listed entities over the past decades. We also determined that state, Tribal, and federal agency wolf management and regulatory mechanisms that will be in place following delisting will be adequate to ensure the conservation of wolves in the 44-State and MN entities (85 FR 69881; 85 FR 69884).
Thus, our November 3, 2020, status review included the following determinations:
44-State Entity: Final Determination
“After a thorough review of all available information and an evaluation of the five factors specified in section 4(a)(1) of the Act, as well as consideration of the definitions of ‘threatened species’ and ‘endangered species’ contained in the Act and the reasons for delisting as specified at 50 CFR 424.11(e), we conclude that removing the 44-State entity of the gray wolf (Canis lupus) from the List of Endangered and Threatened Wildlife (50 CFR 17.11) is appropriate. Although this entity is not a species as defined under the Act, we have collectively evaluated the current and potential threats to gray wolves in the 44- State entity, including those that result from past loss of historical range. Wolves in the 44-State entity do not meet the definition of a threatened species or an endangered species as a result of the reduction of threats as described in the analysis of threats and are neither currently in danger of extinction, nor likely to become so in the foreseeable future, throughout all or a significant portion of their range.
Although substantial contraction of gray wolf historical range occurred within the 44- State entity since European settlement, the range of the gray wolf has expanded significantly since its original listing in 1978, and the impacts of lost historical range are no longer manifesting in a way that threatens the viability of the species. The causes of the previous contraction (for example, targeted extermination efforts), and the effects of that contraction (for example, reduced numbers of individuals and populations, and restricted gene flow), in addition to the effects of all other threats, have been ameliorated or reduced such that the 44-State entity no longer meets the Act's definitions of ‘threatened species’ or ‘endangered species (85 FR 69885).’”
MN Entity: Final Determination
“After a thorough review of all available information and an evaluation of the five factors specified in section 4(a)(1) of the Act, as well as consideration of the definitions of ‘threatened species’ and ‘endangered species’ contained in the Act and the reasons for delisting as specified at 50 CFR 424.11(e), we conclude that removing the gray wolf (Canis lupus) in Minnesota from the List of Endangered and Threatened Wildlife (50 CFR 17.11) is appropriate. Although this entity is not a species as defined under the Act, we have collectively evaluated the current and potential threats to gray wolves in Minnesota, including those that result from past loss of historical range. Wolves in Minnesota do not meet the definition of a threatened species or an endangered species as
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a result of the reduction of threats as described in the analysis of threats and are neither currently in danger of extinction, nor likely to become so in the foreseeable future, throughout all or a significant portion of their range within the State (85 FR 69882).”
Analysis & Determinations Conducted Since Our 2020 Status Determinations
The Service has also considered additional analyses and determinations conducted since our 2020 status determinations that provide further information on aspects of the current gray wolf listed entities. Specifically, we considered two species status assessments (SSAs), one for gray wolves in the Western United States and one for gray wolves in the Eastern United States, and our 2024 12-month finding for wolves in the Northern Rocky Mountains and the Western United States. We summarize each of these below.
Species Status Assessment for the Gray Wolf (Canis lupus) in the Western United States (U.S. Fish and Wildlife Service, 2023): The geographic scope of the analysis in the SSA includes the states of: Arizona, California, Colorado, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, Washington and Wyoming. Within this 11-state geographic scope, gray wolves are delisted in the Northern Rocky Mountain Distinct Population Segment (NRM DPS), which includes all of Montana, Idaho, and Wyoming, and portions of eastern Washington, eastern Oregon, and north central Utah. Gray wolves in the remaining states in the analysis area (California, Colorado, and Nevada, northern Arizona, northern New Mexico, western Oregon, western Washington, and most of Utah) make up a portion of the 44-State entity that is listed as an endangered species.
The stressors that we evaluated for wolves in the Western United States included: human-caused mortality, disease and parasites, inbreeding depression, climate change, disease in prey species, and other sources of habitat modification. We also evaluated the state, Tribal, and federal management that provide for the conservation of wolves in the Western United States by reducing the influence of stressors, improving the condition of wolf habitat, or improving wolf demographic factors. In the Western United States, the primary stressor influencing wolf populations is human caused mortality. Within current wolf range, most states, Tribal Nations, and federal agencies have management protocols and regulations that govern conservation and take of wolves.
In the SSA, we concluded that habitat and prey for wolves are abundant and well distributed in the Western United States. This, in conjunction with the high reproductive potential of wolves and their innate behavior to disperse and locate social openings or vacant suitable habitats, has allowed wolf populations to withstand relatively high rates of human-caused mortality (Service 2020, pp. 8–9). Our analysis of the current condition of gray wolves in the Western United States demonstrates that, despite current levels of regulated harvest, lethal control, and episodic disease outbreaks, wolf abundance in the Western United States has generally continued to increase and occupied range has continued to expand since reintroduction in the 1990s. This large population size and broad distribution contributes to the resiliency and redundancy of wolves in the Western United States. Moreover, wolves in the Western United States currently have high levels of genetic diversity and connectivity, further supporting the resiliency of wolves throughout the
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West. Finally, based on several metrics for assessing adaptive capacity, wolves in the Western United States currently retain the ability to adapt to changes in their environment.
In the Western SSA, we also modeled projections of future wolf populations. Based on our stated assumptions and accounting for uncertainty, our model projections indicate that wolves will avoid extirpation in the Northern Rocky Mountains (NRM) and Western United States over the next 100 years. More generally, gray wolves in the NRM and the Western metapopulation will retain the ability to withstand stochastic and catastrophic events in the future (resiliency and redundancy). We also expect the population size to remain large enough, with sufficient connectivity and genetic diversity, to avoid consequential levels of inbreeding or inbreeding depression in the future. Given this maintained connectivity, combined with wolves’ adaptable life history characteristics, we expect wolf populations in the NRM and Western United States will be able to maintain their evolutionary potential and adapt to future change (representation). The likelihood of additional wolves in California and Colorado (and possibly in Arizona, New Mexico, and Utah in the long term), the continued recolonization of Western Oregon and Washington, and the availability of suitable wolf habitat and prey further support the continued viability of the gray wolf in the NRM and the Western metapopulation under the existing management commitments, albeit at potentially reduced population sizes compared to current numbers.
Species Status Assessment for the Gray Wolf (Canis lupus) in the Eastern United States (U.S. Fish and Wildlife Service, 2025): The geographic scope of the analysis in this SSA includes the states of: Connecticut, Illinois, Indiana, Iowa, Kansas, Maine, Massachusetts, Michigan, Minnesota, Missouri, Nebraska, New Hampshire, New Jersey, New York, North Dakota, Ohio, Oklahoma, Pennsylvania, Rhode Island, South Dakota, Texas, Vermont, and Wisconsin. These 23 states encompass the current range and the potential historical range for gray wolf in the Eastern United States. Within this analysis area, the gray wolf is listed as a threatened species in Minnesota. The remaining 22 states within the geographic scope of our analysis are part of the 44-State entity that is listed as an endangered species.
The stressors that we evaluated for gray wolves in the Eastern United States included: human- caused mortality, disease and parasites, inbreeding depression, hybridization, climate change, disease in prey species, and other sources of habitat modification. We also evaluated the state, Tribal, and federal management that provide for the conservation of gray wolves in the Eastern United States by reducing the influence of a stressor, improving the condition of gray wolf habitat, or improving gray wolf demographic factors. All states and some Tribal Nations within the current range of gray wolves have statutes, regulations, and management plans that govern conservation and take of gray wolves. Federal agencies also have rules and regulations in place to minimize disturbance to gray wolves, when necessary. In the Eastern United States, gray wolves occur in one large metapopulation in the Western Great Lakes, distributed across the states of Michigan, Minnesota, and Wisconsin. To date, the best available science indicates that current levels of human-caused mortality have not caused significant reductions in gray wolf abundance throughout the Western Great Lakes.
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Despite past harvest seasons, ongoing lethal depredation control, and periodic disease outbreaks, the population in the Western Great Lakes has maintained a large population size and broad distribution. The wolves in the Western Great Lakes States occupy areas of high-quality habitat with abundant prey. The Western Great Lakes’ metapopulation’s large size, the metapopulation’s broad pack distribution, the metapopulation’s high levels of genetic diversity and connectivity, gray wolves’ high reproductive potential, and gray wolves’ innate behavior to disperse into vacant suitable habitats contribute to the species’ current ability to withstand stochastic and catastrophic events within the Western Great Lakes. Finally, based on multiple contributing factors to adaptive capacity, wolves in the Western Great Lakes currently retain the ability to adapt to changes in their environment. In sum, while the gray wolf currently occupies only a portion of its historical range in the Eastern United States, within its current range (i.e., within the Western Great Lakes), the gray wolf currently retains the ability to withstand stochastic and catastrophic events and adapt to changes in its environment.
We also modeled projections of the future gray wolf population in the Western Great Lakes under scenarios with varying levels of mortality from lethal depredation control, harvest, and disease. While projected population sizes represent a decrease relative to the metapopulation’s current size due to these stressors, after this initial decline the population stabilizes around a large equilibrium population size and does not fall to a level that indicates risk of quasi- extinction or inbreeding, demonstrating the population’s ability to withstand the sustained human-caused mortality and disease rates we model (both stochastic events (resiliency) and catastrophic events (redundancy)). The continued availability of suitable habitat and prey further support the Western Great Lakes metapopulation’s resiliency into the future. Moreover, the metapopulation’s currently high levels of genetic diversity are unlikely to decrease in the future, given maintained connectivity within the metapopulation and with the larger gray wolf population in Canada. This sustained genetic diversity and connectivity also contribute to the species’ continued ability to withstand stochastic events (resiliency) into the future within the Western Great Lakes (the extant metapopulation in the Eastern United States).
Finally, given this maintained genetic diversity, and gray wolves’ innate characteristics that contribute to the species’ ability to live in and disperse to multiple different habitat types, the adaptive capacity of the species (representation) within the Western Great Lakes is unlikely to decrease in the future relative to current condition. Due to the risk of human-caused mortality, gray wolves are unlikely to recolonize areas outside of the Western Great Lakes within the Eastern United States in the future, which means redundancy and representation is unlikely to increase in the future. However, based on our analysis, the gray wolf in the Western Great Lakes will likely retain sufficient resiliency, redundancy, and representation to avoid extirpation for the next 100 years, meaning that, even without this recolonization, the gray wolf will successfully maintain populations in the wild in the Eastern United States into the future, despite the continued occurrence or introduction of various stressors.
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12-month finding for gray wolf in the Northern Rocky Mountains and Western United States (89 FR 8392, February 7, 2024): The geographic scope of the analysis in this finding is the same as for the SSA for gray wolf in the Western United States and includes the states of: Arizona, California, Colorado, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, Washington and Wyoming. The finding, which was informed by analyses in the SSA for gray wolf in the Western United States, addressed petitions to list the delisted NRM DPS of gray wolf or a gray wolf DPS in the Western United States. A gray wolf DPS in the Western United States would include a portion of the 44-State entity that is listed as an endangered species.
Based on the analyses in the SSA for gray wolf in the Western United States, which is summarized above, we found that gray wolves throughout the Northern Rocky Mountains and Western United States do not meet the definitions of an endangered species or threatened species and therefore do not warrant protections of the Act (89 FR 8392, February 7, 2024).2
Summary of review of analyses conducted since our 2020 status review: While these analyses and determinations were conducted for gray wolf metapopulations in the contiguous United States that do not align perfectly with the current gray wolf listed entities (44-State and MN entities), together their evaluations comprehensively encompass all the currently listed gray wolf entities. None of the new information or analyses provided in these documents cause us to reconsider our 2020 status determinations. These analyses, which take into account state management plans, generally conclude that the wolf metapopulations that make up the currently listed entities will retain the ability to withstand stochastic and catastrophic events in the future (resiliency and redundancy) under future scenarios. We also expect the population sizes to remain large enough, with sufficient connectivity and genetic diversity, to avoid consequential levels of inbreeding or inbreeding depression in the future. Given this maintained connectivity, combined with wolves’ adaptable life history characteristics, we expect wolf populations in the contiguous United States will be able to maintain their evolutionary potential and adapt to future change (representation). These analyses and conclusions are consistent with our 2020 status review determinations that neither gray wolves in the 44-State entity nor the MN entity meet the definitions of a threatened or endangered species.
2 The District Court of the District of Montana in Ctr. for Biological Diversity v. FWS, 2025 U.S. Dist. LEXIS 150500 (D. Mont., Aug 5, 2025) vacated in part and remanded our 2024 “not warranted” finding for the Gray Wolf in the Northern Rocky Mountains and the Western United States. This court opinion is not at issue in the appeal of the 2020 delisting rule. This court’s opinion did not disagree with our finding that the gray wolf population for the western United States has recovered under the Act.
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Summary of the Recovery Planning Exception Findings
Based on our 2020 status review for gray wolves in the 44-State and MN entities, and our review of subsequent analyses for other populations of gray wolves in the United States that include all or portions of the 44-State and MN entities, we find that a recovery plan for the listed gray wolf entities would not promote their conservation because listing is no longer appropriate under 4(a)(1) of the Act, and measures provided pursuant to the Act are no longer necessary.
APPROVED BY: __________________________ DATE: November 3rd, 2025 Acting Assistant Director, Headquarters Ecological Services Program
The U.S. Fish and Wildlife Service announced this week (see below) that it no longer intends to issue a nationwide recovery plan for gray wolves. This is a disappointing and dangerous policy reversal by the Trump administration. My thoughts are below.
“I’m appalled that Trump wants to strip gray wolves of federal protections and turn their management over to states that are dead set on killing them,” said Collette Adkins, senior attorney and Carnivore Conservation director at the Center for Biological Diversity. “Courts have repeatedly made it clear that our country’s gray wolves have not recovered in places like the southern Rocky Mountains and West Coast. We’ll challenge the Trump administration’s unlawful decision to once again abandon wolf recovery, and we’ll win.”
This decision is unlawful because wolves remain protected under the Endangered Species Act in places like the southern Rockies, West Coast and Northeast. These wolves still need recovery plans under the law.
Please reach out with any questions.
Thank you,
Collette Adkins
Carnivore Conservation Director
Center for Biological Diversity
[email protected]
(651) 955-3821
Recovery Planning Exception Findings for the 44-State and Minnesota Listed Entities of Gray Wolves (Canis lupus)
U.S. Fish and Wildlife Service
Headquarters Ecological Services Office Falls Church, Virginia
With major contributions from:
Pacific Region Southwest Region Midwest Region Northeast Region Mountain-Prairie Region Pacific Southwest Region
November 2025
1
PURPOSE AND DISCLAIMER
The gray wolf recovery planning exception findings present the U.S. Fish and Wildlife Service’s (Service) review of information regarding whether a recovery plan would promote the conservation of the species. As detailed below, we found that recovery plans would not promote the conservation of the gray wolf 44-State or Minnesota listed entities because listing these entities is no longer appropriate under 4(a)(1) of the Endangered Species Act (Act) and measures provided pursuant to the Act are no longer necessary. A consequence of our findings that a recovery plan would not promote the conservation of the two gray wolf listed entities is that recovery plans are no longer statutorily required under the Act and the Service will not develop recovery plans for them. However, these findings do not affect any other provisions of the Act. All other provisions of the Act still apply while the two entities remain listed, including sections 7, 9, and 10 of the Act, consistent with any designated critical habitat, and any regulations issued under sections 4(d) and 10(j) of the Act.
If circumstances for gray wolves change in the United States and new information becomes available indicating a recovery planning exception is no longer appropriate, the Service at that time, could consider whether to engage in recovery planning.
1. BACKGROUND
The gray wolf (Canis lupus) is currently listed as: (1) an endangered species in all or portions of 44 of the contiguous United States and Mexico (44-State entity); and (2) a threatened species in Minnesota (MN entity). The findings address recovery planning for these two gray wolf entities as they appear on the List of Endangered and Threatened Wildlife at 50 CFR 17.11.
The geographic scope of current gray wolf entities listed under the Act at 50 CFR 17.11 are: • Endangered species in 44 States within the contiguous United States, and Mexico:
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ο All of AL, AR, CA, CT, DE, FL, GA, IA, IN, IL, KS, KY, LA, MA, MD, ME, MI, MO, MS, NC, ND, NE, NH, NJ, NV, NY, OH, OK, PA, RI, SC, SD, TN, TX, VA, VT, WI, and WV; and portions of AZ, NM, OR, UT, and WA as follows:
(1) Northern AZ (that portion north of the centerline of Interstate Highway 40); (2) Northern NM (that portion north of the centerline of Interstate Highway 40);
(3) Western OR (that portion of OR west of the centerline of Highway 395 and Highway 78 north of Burns Junction and that portion of OR west of the centerline of Highway 95 south of Burns Junction);
(4) Most of UT (that portion of UT south and west of the centerline of Interstate Highway 84 and that portion of UT south of Interstate Highway 80 from Echo to the UT/WY Stateline); and
(5) Western WA (that portion of WA west of the centerline of Highway 97 and Highway 17 north of Mesa and that portion of WA west of the centerline of Highway 395 south of Mesa); and
(6) Mexico.
A complete discussion of gray wolf biology and ecology, as well as a history of regulatory actions and recovery planning for the gray wolf can be found at 85 FR 69778; November 3, 2020.
ESA Recovery Planning Requirements
Section 4(f)(l) of the Act directs the Service to develop and implement recovery plans for the conservation and survival of endangered and threatened species, “unless [the Service] finds that such a plan will not promote the conservation of the species.” Conservation is defined in Section 3(3) of the Act as “... the use of all methods and procedures which are necessary to bring any endangered species or threatened species to the point at which the measures provided pursuant to this Act are no longer necessary.” The definition of conservation is further supported by the Service’s regulatory definition of recovery meaning “improvement in the status of listed species to the point at which listing is no longer appropriate under the criteria set out in section 4(a)(1) of the Act” (50 CFR 402.02). In the context of recovery planning this means that the Service includes in recovery plans all methods necessary to bring a listed species to the point at which protection under the Act is no longer necessary. Thus, per the statutory and regulatory language above, we can only decline to develop a recovery plan when it would not benefit the species through contributing to its recovery.
2. RECOVERY PLANNING EXCEPTION FINDINGS
The Service’s most recent status reviews for listed gray wolves determined that neither listed entity (44-State or MN entities) meet the definitions of a threatened species or endangered species under the Act according to the best scientific and commercial data available (85 FR
ο CO (nonessential experimental population)
• Threatened species in the state of Minnesota.
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69778, November 3, 2020).1 With these determinations, we conclude that listing is no longer appropriate under 4(a)(1) of the Act and measures provided pursuant to the Act are no longer necessary. Both listed gray wolf entities are no longer in need of conservation under the Act due to recovery. We therefore conclude that recovery plans for these two entities would not promote their conservation.
We base these conclusions on our 2020 status reviews for gray wolves in the 44-State and MN entities. We also reviewed subsequent analyses for information or conclusions that could cause us to reconsider these conclusions. We summarize our 2020 status review and subsequent analyses below.
Summary of 2020 Status Review and Determinations
In our 2020 status review (85 FR 69778, November 3, 2020), for each listed gray wolf entity, we evaluated human-caused mortality (Factor C); habitat and prey availability (Factor A); disease and parasites (Factor C); genetic diversity and inbreeding (Factor E); commercial, recreational, scientific, or educational uses (Factor B); climate change (Factor E); and other threats singly and in combination. We also evaluated state, Tribal, and federal agency wolf management and regulatory mechanisms that will be in place following delisting.
Based on our analysis, we concluded that Minnesota will maintain an abundant and well- distributed wolf population that will remain above recovery levels for the foreseeable future (85 FR 69881), and that the primary threat of human caused mortality has been sufficiently addressed. Minnesota’s wolf management laws, plans, and regulations adequately regulate human-caused mortality (85 FR 69881).
We also concluded that Wisconsin and Michigan will maintain an abundant and well distributed wolf population in their states above recovery levels for the foreseeable future (85 FR 69883), and that the threat of human-caused mortality has been sufficiently reduced (85 FR 69883). Both states have wolf-management laws, plans, and regulations that adequately regulate human- caused mortality (85 FR 69883). Further, while relatively few wolves occurred in the west coast portion of the 44-State entity at the time of the status review, the state wolf-management plans for California, Washington, and Oregon include recovery objectives intended to ensure the reestablishment of self-sustaining populations in these states (85 FR 69883). In addition, we expected wolves in the delisted Northern Rocky Mountain Distinct Population Segment (DPS) and western Canada to continue to expand into unoccupied suitable habitats in the Western United States, as envisioned in state wolf conservation and management plans (85 FR 69883).
1 Our 2020 delisting rule was vacated and remanded by a district court in Defs. of Wildlife v. FWS, 584 F. Supp. 3d 812 (N.D. Cal. Feb. 10, 2022). We are appealing the district court’s decision to the 9th Circuit Court of Appeals.
The Appellate court has not yet ruled on our appeal (and has not yet scheduled oral argument; briefing was completed in the spring of 2025). However, in Center for Biological Diversity v. Halaand, 2023 U.S. Dist. LEXIS 139815 (D.D.C. Aug. 11, 2023), the U.S. District Court for the District of Columbia acknowledged that although the 2020 delisting rule had been vacated by the Northern District of California, the vacatur did not change the fact that the Service had conducted 5-year status reviews for the two listed gray wolf entities (44-state and MN entities) as part of that rule.
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We determined that none of the factors we evaluated are of sufficient imminence, intensity, or magnitude to indicate that the 44-State or MN entities are in danger of extinction or likely to become so within the foreseeable future throughout all or a significant portion of their ranges. We also determined that recovery efforts resulted in a significant expansion of wolves in the listed entities over the past decades. We also determined that state, Tribal, and federal agency wolf management and regulatory mechanisms that will be in place following delisting will be adequate to ensure the conservation of wolves in the 44-State and MN entities (85 FR 69881; 85 FR 69884).
Thus, our November 3, 2020, status review included the following determinations:
44-State Entity: Final Determination
“After a thorough review of all available information and an evaluation of the five factors specified in section 4(a)(1) of the Act, as well as consideration of the definitions of ‘threatened species’ and ‘endangered species’ contained in the Act and the reasons for delisting as specified at 50 CFR 424.11(e), we conclude that removing the 44-State entity of the gray wolf (Canis lupus) from the List of Endangered and Threatened Wildlife (50 CFR 17.11) is appropriate. Although this entity is not a species as defined under the Act, we have collectively evaluated the current and potential threats to gray wolves in the 44- State entity, including those that result from past loss of historical range. Wolves in the 44-State entity do not meet the definition of a threatened species or an endangered species as a result of the reduction of threats as described in the analysis of threats and are neither currently in danger of extinction, nor likely to become so in the foreseeable future, throughout all or a significant portion of their range.
Although substantial contraction of gray wolf historical range occurred within the 44- State entity since European settlement, the range of the gray wolf has expanded significantly since its original listing in 1978, and the impacts of lost historical range are no longer manifesting in a way that threatens the viability of the species. The causes of the previous contraction (for example, targeted extermination efforts), and the effects of that contraction (for example, reduced numbers of individuals and populations, and restricted gene flow), in addition to the effects of all other threats, have been ameliorated or reduced such that the 44-State entity no longer meets the Act's definitions of ‘threatened species’ or ‘endangered species (85 FR 69885).’”
MN Entity: Final Determination
“After a thorough review of all available information and an evaluation of the five factors specified in section 4(a)(1) of the Act, as well as consideration of the definitions of ‘threatened species’ and ‘endangered species’ contained in the Act and the reasons for delisting as specified at 50 CFR 424.11(e), we conclude that removing the gray wolf (Canis lupus) in Minnesota from the List of Endangered and Threatened Wildlife (50 CFR 17.11) is appropriate. Although this entity is not a species as defined under the Act, we have collectively evaluated the current and potential threats to gray wolves in Minnesota, including those that result from past loss of historical range. Wolves in Minnesota do not meet the definition of a threatened species or an endangered species as
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a result of the reduction of threats as described in the analysis of threats and are neither currently in danger of extinction, nor likely to become so in the foreseeable future, throughout all or a significant portion of their range within the State (85 FR 69882).”
Analysis & Determinations Conducted Since Our 2020 Status Determinations
The Service has also considered additional analyses and determinations conducted since our 2020 status determinations that provide further information on aspects of the current gray wolf listed entities. Specifically, we considered two species status assessments (SSAs), one for gray wolves in the Western United States and one for gray wolves in the Eastern United States, and our 2024 12-month finding for wolves in the Northern Rocky Mountains and the Western United States. We summarize each of these below.
Species Status Assessment for the Gray Wolf (Canis lupus) in the Western United States (U.S. Fish and Wildlife Service, 2023): The geographic scope of the analysis in the SSA includes the states of: Arizona, California, Colorado, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, Washington and Wyoming. Within this 11-state geographic scope, gray wolves are delisted in the Northern Rocky Mountain Distinct Population Segment (NRM DPS), which includes all of Montana, Idaho, and Wyoming, and portions of eastern Washington, eastern Oregon, and north central Utah. Gray wolves in the remaining states in the analysis area (California, Colorado, and Nevada, northern Arizona, northern New Mexico, western Oregon, western Washington, and most of Utah) make up a portion of the 44-State entity that is listed as an endangered species.
The stressors that we evaluated for wolves in the Western United States included: human-caused mortality, disease and parasites, inbreeding depression, climate change, disease in prey species, and other sources of habitat modification. We also evaluated the state, Tribal, and federal management that provide for the conservation of wolves in the Western United States by reducing the influence of stressors, improving the condition of wolf habitat, or improving wolf demographic factors. In the Western United States, the primary stressor influencing wolf populations is human caused mortality. Within current wolf range, most states, Tribal Nations, and federal agencies have management protocols and regulations that govern conservation and take of wolves.
In the SSA, we concluded that habitat and prey for wolves are abundant and well distributed in the Western United States. This, in conjunction with the high reproductive potential of wolves and their innate behavior to disperse and locate social openings or vacant suitable habitats, has allowed wolf populations to withstand relatively high rates of human-caused mortality (Service 2020, pp. 8–9). Our analysis of the current condition of gray wolves in the Western United States demonstrates that, despite current levels of regulated harvest, lethal control, and episodic disease outbreaks, wolf abundance in the Western United States has generally continued to increase and occupied range has continued to expand since reintroduction in the 1990s. This large population size and broad distribution contributes to the resiliency and redundancy of wolves in the Western United States. Moreover, wolves in the Western United States currently have high levels of genetic diversity and connectivity, further supporting the resiliency of wolves throughout the
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West. Finally, based on several metrics for assessing adaptive capacity, wolves in the Western United States currently retain the ability to adapt to changes in their environment.
In the Western SSA, we also modeled projections of future wolf populations. Based on our stated assumptions and accounting for uncertainty, our model projections indicate that wolves will avoid extirpation in the Northern Rocky Mountains (NRM) and Western United States over the next 100 years. More generally, gray wolves in the NRM and the Western metapopulation will retain the ability to withstand stochastic and catastrophic events in the future (resiliency and redundancy). We also expect the population size to remain large enough, with sufficient connectivity and genetic diversity, to avoid consequential levels of inbreeding or inbreeding depression in the future. Given this maintained connectivity, combined with wolves’ adaptable life history characteristics, we expect wolf populations in the NRM and Western United States will be able to maintain their evolutionary potential and adapt to future change (representation). The likelihood of additional wolves in California and Colorado (and possibly in Arizona, New Mexico, and Utah in the long term), the continued recolonization of Western Oregon and Washington, and the availability of suitable wolf habitat and prey further support the continued viability of the gray wolf in the NRM and the Western metapopulation under the existing management commitments, albeit at potentially reduced population sizes compared to current numbers.
Species Status Assessment for the Gray Wolf (Canis lupus) in the Eastern United States (U.S. Fish and Wildlife Service, 2025): The geographic scope of the analysis in this SSA includes the states of: Connecticut, Illinois, Indiana, Iowa, Kansas, Maine, Massachusetts, Michigan, Minnesota, Missouri, Nebraska, New Hampshire, New Jersey, New York, North Dakota, Ohio, Oklahoma, Pennsylvania, Rhode Island, South Dakota, Texas, Vermont, and Wisconsin. These 23 states encompass the current range and the potential historical range for gray wolf in the Eastern United States. Within this analysis area, the gray wolf is listed as a threatened species in Minnesota. The remaining 22 states within the geographic scope of our analysis are part of the 44-State entity that is listed as an endangered species.
The stressors that we evaluated for gray wolves in the Eastern United States included: human- caused mortality, disease and parasites, inbreeding depression, hybridization, climate change, disease in prey species, and other sources of habitat modification. We also evaluated the state, Tribal, and federal management that provide for the conservation of gray wolves in the Eastern United States by reducing the influence of a stressor, improving the condition of gray wolf habitat, or improving gray wolf demographic factors. All states and some Tribal Nations within the current range of gray wolves have statutes, regulations, and management plans that govern conservation and take of gray wolves. Federal agencies also have rules and regulations in place to minimize disturbance to gray wolves, when necessary. In the Eastern United States, gray wolves occur in one large metapopulation in the Western Great Lakes, distributed across the states of Michigan, Minnesota, and Wisconsin. To date, the best available science indicates that current levels of human-caused mortality have not caused significant reductions in gray wolf abundance throughout the Western Great Lakes.
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Despite past harvest seasons, ongoing lethal depredation control, and periodic disease outbreaks, the population in the Western Great Lakes has maintained a large population size and broad distribution. The wolves in the Western Great Lakes States occupy areas of high-quality habitat with abundant prey. The Western Great Lakes’ metapopulation’s large size, the metapopulation’s broad pack distribution, the metapopulation’s high levels of genetic diversity and connectivity, gray wolves’ high reproductive potential, and gray wolves’ innate behavior to disperse into vacant suitable habitats contribute to the species’ current ability to withstand stochastic and catastrophic events within the Western Great Lakes. Finally, based on multiple contributing factors to adaptive capacity, wolves in the Western Great Lakes currently retain the ability to adapt to changes in their environment. In sum, while the gray wolf currently occupies only a portion of its historical range in the Eastern United States, within its current range (i.e., within the Western Great Lakes), the gray wolf currently retains the ability to withstand stochastic and catastrophic events and adapt to changes in its environment.
We also modeled projections of the future gray wolf population in the Western Great Lakes under scenarios with varying levels of mortality from lethal depredation control, harvest, and disease. While projected population sizes represent a decrease relative to the metapopulation’s current size due to these stressors, after this initial decline the population stabilizes around a large equilibrium population size and does not fall to a level that indicates risk of quasi- extinction or inbreeding, demonstrating the population’s ability to withstand the sustained human-caused mortality and disease rates we model (both stochastic events (resiliency) and catastrophic events (redundancy)). The continued availability of suitable habitat and prey further support the Western Great Lakes metapopulation’s resiliency into the future. Moreover, the metapopulation’s currently high levels of genetic diversity are unlikely to decrease in the future, given maintained connectivity within the metapopulation and with the larger gray wolf population in Canada. This sustained genetic diversity and connectivity also contribute to the species’ continued ability to withstand stochastic events (resiliency) into the future within the Western Great Lakes (the extant metapopulation in the Eastern United States).
Finally, given this maintained genetic diversity, and gray wolves’ innate characteristics that contribute to the species’ ability to live in and disperse to multiple different habitat types, the adaptive capacity of the species (representation) within the Western Great Lakes is unlikely to decrease in the future relative to current condition. Due to the risk of human-caused mortality, gray wolves are unlikely to recolonize areas outside of the Western Great Lakes within the Eastern United States in the future, which means redundancy and representation is unlikely to increase in the future. However, based on our analysis, the gray wolf in the Western Great Lakes will likely retain sufficient resiliency, redundancy, and representation to avoid extirpation for the next 100 years, meaning that, even without this recolonization, the gray wolf will successfully maintain populations in the wild in the Eastern United States into the future, despite the continued occurrence or introduction of various stressors.
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12-month finding for gray wolf in the Northern Rocky Mountains and Western United States (89 FR 8392, February 7, 2024): The geographic scope of the analysis in this finding is the same as for the SSA for gray wolf in the Western United States and includes the states of: Arizona, California, Colorado, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, Washington and Wyoming. The finding, which was informed by analyses in the SSA for gray wolf in the Western United States, addressed petitions to list the delisted NRM DPS of gray wolf or a gray wolf DPS in the Western United States. A gray wolf DPS in the Western United States would include a portion of the 44-State entity that is listed as an endangered species.
Based on the analyses in the SSA for gray wolf in the Western United States, which is summarized above, we found that gray wolves throughout the Northern Rocky Mountains and Western United States do not meet the definitions of an endangered species or threatened species and therefore do not warrant protections of the Act (89 FR 8392, February 7, 2024).2
Summary of review of analyses conducted since our 2020 status review: While these analyses and determinations were conducted for gray wolf metapopulations in the contiguous United States that do not align perfectly with the current gray wolf listed entities (44-State and MN entities), together their evaluations comprehensively encompass all the currently listed gray wolf entities. None of the new information or analyses provided in these documents cause us to reconsider our 2020 status determinations. These analyses, which take into account state management plans, generally conclude that the wolf metapopulations that make up the currently listed entities will retain the ability to withstand stochastic and catastrophic events in the future (resiliency and redundancy) under future scenarios. We also expect the population sizes to remain large enough, with sufficient connectivity and genetic diversity, to avoid consequential levels of inbreeding or inbreeding depression in the future. Given this maintained connectivity, combined with wolves’ adaptable life history characteristics, we expect wolf populations in the contiguous United States will be able to maintain their evolutionary potential and adapt to future change (representation). These analyses and conclusions are consistent with our 2020 status review determinations that neither gray wolves in the 44-State entity nor the MN entity meet the definitions of a threatened or endangered species.
2 The District Court of the District of Montana in Ctr. for Biological Diversity v. FWS, 2025 U.S. Dist. LEXIS 150500 (D. Mont., Aug 5, 2025) vacated in part and remanded our 2024 “not warranted” finding for the Gray Wolf in the Northern Rocky Mountains and the Western United States. This court opinion is not at issue in the appeal of the 2020 delisting rule. This court’s opinion did not disagree with our finding that the gray wolf population for the western United States has recovered under the Act.
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Summary of the Recovery Planning Exception Findings
Based on our 2020 status review for gray wolves in the 44-State and MN entities, and our review of subsequent analyses for other populations of gray wolves in the United States that include all or portions of the 44-State and MN entities, we find that a recovery plan for the listed gray wolf entities would not promote their conservation because listing is no longer appropriate under 4(a)(1) of the Act, and measures provided pursuant to the Act are no longer necessary.
APPROVED BY: __________________________ DATE: November 3rd, 2025 Acting Assistant Director, Headquarters Ecological Services Program
