Opinion: Recovery was the promise; delisting Is the test

American Stewards of Liberty petitioned Fish and Wildlife on Aug. 21 to delist the gray wolf, arguing listed wolf groups fail the ESA's own species definition.
American Stewards of Liberty petitioned Fish and Wildlife on Aug. 21 to delist the gray wolf, arguing listed wolf groups fail the ESA’s own species definition.

Gray wolves rebounded. The Endangered Species Act will not admit it.

Nancy Churchill
Dangerous Rhetoric

On Aug. 21, American Stewards of Liberty and a coalition of industry groups and nonprofits petitioned the U.S. Fish and Wildlife Service to take the gray wolf off the Endangered Species Act list. The filing asks the federal government to stop treating a recovered apex predator like a museum piece. Recovery was supposed to end in local control. Instead, ranchers still lose calves while anti-ranching activists keep the lawsuits alive.

Nancy Churchill

Nancy Churchill

Margaret Byfield, executive director of American Stewards, put the new argument in plain English. The unique question is “whether the gray wolf is a species under the current definition of the Endangered Species Act.” The wolf was listed before Congress changed that definition in 1978. If the listed animals do not even meet the statute’s first test, the rest of the fight is a sideshow.

Not a species? Not a listing.

The petition does not ask anyone to hate wolves. It asks the agency to read the law it is paid to enforce.

The wolves still listed in parts of the lower 48 are only a fraction of a far larger population across Canada, Alaska, Asia, and Europe. They do not qualify as a species, a subspecies, or a distinct population segment under the Act. If they fail that test, they should be delisted.

That is the first gate in the statute. Before Fish and Wildlife can ask whether an animal is endangered or threatened, it must decide whether the group is a “species” under the law. If there is no valid species, the inquiry stops. The animal comes off the list.

In its 2020 delisting rule, the Service found the two listed groups do not encompass an entire species or subspecies. One is threatened in Minnesota. The other is endangered in all or parts of 44 states and Mexico. Those groups would be listable only as distinct population segments. The petitioners say they are not, that the original species call was in error, and that the usual five-factor analysis is not required. They address those factors anyway, out of caution.

The agency’s own science

U.S. Fish and Wildlife previously concluded the gray wolf had rebounded enough that it is no longer in danger of extinction in the foreseeable future. That was the 2020 rule. Environmental groups sued. A federal judge reversed it two years later. The science did not vanish. Neither did the cattle losses.

In its most recent Western assessment, the Service said human-caused mortality is the primary stressor: regulated harvest, lethal control to protect livestock, and illegal take. However, those stressors have not stopped wolves from recolonizing Oregon and Washington, “where known wolves now total close to 400 individuals,” or California and Colorado. The Eastern assessment said current mortality has not caused significant reductions in the Western Great Lakes, and has had “minimal impact on wolf abundance or distribution” there.

The agency that keeps the listing already said the population can take the pressure. Rural families are living with the bill.

Northern Rocky Mountain wolves were delisted by Congress in 2011. Those states now manage their own packs. Livestock groups say leftover federal protections block honest management when wolves hit cattle. They are not guessing. They are counting dead calves.

A law that cannot admit success

The Endangered Species Act became law in 1973. After fifty years of enormous federal and private expense, only 62 species out of 1,667 listed are officially recovered. Thirty-six of those claimed recoveries were not conservation victories. They were listing errors. The data was wrong from the start.

That is the record. A statute that cannot admit a recovered predator, and cannot admit a listing that never met the definition of “species,” is no longer protecting wildlife. It is protecting process. Process does not fence a night pasture, or stay up late guarding the herd. Process does not replace a heifer.

Wolf impact in Washington state

On April 17, 2026, the Washington Department of Fish and Wildlife reported the state’s highest wolf count to date. As of Dec. 31, 2025, WDFW and partnering tribes counted a MINIMUM of 270 wolves, 23 breeding pairs, and 49 packs. That is more than a 17 percent jump from the year before.

WDFW also documented 17 depredation events involving 19 cattle in 2025. Eight calves were confirmed killed. That is not a theory. That is a ledger. The documented depredation events are a minimum number, as many frustrated producers don’t even bother to report depredation to the authorities anymore.

Congress already knew the answer

The House has already voted. On Dec. 18, 2025, it passed H.R. 845, the Pet and Livestock Protection Act, with bipartisan support. The Senate companion is S. 1306. That bill would direct the Interior Department to reissue the November 2020 rule delisting gray wolves in the lower 48, return management and predator control to the states, and shield that decision from another round of activist lawsuits.

Livestock producers say failure to restore state management leaves rural economies open to an apex predator the federal government will not admit has recovered. The Senate bill then stalled in committee after Sen. Cory Booker of New Jersey blocked it from passing by unanimous consent.

A senator from New Jersey does not run cattle in Eastern Washington. He does not walk a calving pasture at 2 a.m. He does not write off a year’s work because a recovered predator is still treated like an emergency. Rural Washington got the consequences. New Jersey got the veto.

What you can do this week

Congress hesitates. So ranchers, timber men, and property-rights groups must take action.

American Stewards has already filed the petition. That is not a petition you sign online. It is a legal demand that the federal government follow its own statute and its own science.

Do three things this week.

First, write the U.S. Fish and Wildlife Service (www.fws.gov/contact-us), the Secretary of the Interior, Doug Burgum (@SecretaryBurgum on X) and the Department of the Interior (www.doi.gov/contact-us#no-back). Ask them to grant the American Stewards of Liberty’s petition to delist the gray wolf and return wolf management to the states.

Do not let distance keep you from the fight in Washington, D.C. while Eastern Washington losses keep mounting. Your letters and phone calls do make a difference. Short letters work. Name your county. Name your livestock. Give your personal testimony of the impact of wolves on your operation.

Second, call or write both Senator Patty Murray and Senator Maria Cantwell as well as your representative. Tell them the House already passed H.R. 845, the Pet and Livestock Protection Act. Ask the Senators to support S. 1306 and work to protect Washington’s rural agriculture.

Third, stand with the people who live with the wolves. Share the news about this important petition with the producers you know. Support the organizations that are fighting for delisting.

The wolf recovered. The ESA listing never changed. Recovery was supposed to lead somewhere. That somewhere is the states, the counties, and the families who still run livestock in the remote areas of Eastern Washington.

Nancy Churchill is a writer, educator, and conservative activist in rural eastern Washington state. She chairs the Ferry County Republican Party and advocates for effective citizen influence through Influencing Olympia Effectively. She may be reached at DangerousRhetoric@pm.me. The opinions expressed in Dangerous Rhetoric are her own. Dangerous Rhetoric is available on Substack and X.


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