Smart Wolf Submits Public Comments to the US Fish and Wildlife Service.

Based upon the failing, dramatically over-budget, “Wolf Reintroduction” program by the State of Colorado and mismanaged by its’ Colorado Parks & Wildlife (CPW)(department) it is requested the USFWS immediately take over all wildlife management responsibility of these non-native, foreign sub-species of transplanted Wolves in Colorado.

We formally request that the United States Fish & Wildlife Service:

1. Take over this experimental wolf population and end the current Colorado Wolf Program,

2. Evaluate immediate removal of wolves sourced and/or released in violation of federal or state law.

The term “reintroduction” was consistently used throughout the ballot Petition 114 language and public campaign. To the average voter, this implied the restoration of the same wolves historically native to Colorado.  However, the wolves released into Colorado have not been the historic Southern Rocky Mountain subspecies. Instead, Colorado has transplanted foreign, non-native, Northern Rocky Mountain wolves sourced from:

• Oregon (whose wolves were originally sourced from British Columbia)

• Northern British Columbia, Canada

These wolves are not the historic subspecies that once occupied Colorado. Therefore, the program constitutes a transplantation of a foreign/non-native and different subspecies, not a true biological reintroduction. This distinction is central to both voter intent and statutory compliance.

In summary, all wolves that have been transplanted / released into Colorado are Northern Rockies Canadian Wolves that never previously resided in the state of Colorado and do not qualify as “reintroduction” as noted in Colorado Petition 114.

It appears the State of Colorado and its’ CPW Department and CPW Commission have and continue to mislead the resident (voting) public the previous resident wolves were reintroduced into Colorado.

Reintroduction vs. Transplantation of a Foreign Subspecies

The original Southern Rockies wolf subspecies historically native to Colorado is extinct. All wolves released into Colorado to date are Northern Rocky Mountain wolves originating from British Columbia, Canada. These animals are a foreign, non-native species to Colorado

Proposition 114 lists the overly broad Genus and Species classification “Canis lupus” in which encompasses multiple subspecies from across the world’s continents. Reliance on this broad classification allows virtually any global wolf population to be eligible to be introduced under the label of “reintroduction,” which undermines the biological and legal meaning of that term. Colorado has recently expressed concern about cross-breeding with the Mexican wolf (Canis lupus baileyi), acknowledging that subspecies distinctions do matter biologically. This recognition further reinforces that subspecies differences are significant and cannot be dismissed when convenient.

Colorado cannot simultaneously argue that subspecies are irrelevant for introduction but relevant for cross-breeding prevention.

Evidence shows that wolves known to have histories of livestock depredation were released into Colorado, including wolves associated with the Copper Creek Pack. The former CPW Director Jeff Davis publicly acknowledged mistakes in the handling of these wolves and their re-release.

Releasing known depredating wolves appears inconsistent with the Colorado Wolf Plan and raises serious concerns about program compliance and administrative integrity.

It appears Colorado has also acted against its own laws violating the release of “Foreign/Exotic Animals” into the Colorado landscape.  Colorado statutes strictly regulate the importation and release of wildlife:

• C.R.S. 33-6-114 prohibits releasing native, nonnative, or exotic wildlife except in accordance with commission rules.

• 2 CCR 406-0-009 restricts release of terrestrial wildlife absent narrow exceptions.

• C.R.S. 33-1-106 vests authority in the commission to regulate wildlife for ecological balance.

These laws exist to prevent ecological disruption and disease introduction. The central legal question is whether the introduction of a non-historic subspecies qualifies as lawful “reintroduction” or constitutes release of a foreign subspecies inconsistent with this statutory intent.  This issue warrants federal review.

Since 2021, state expenditures related to the wolf program have exceeded $8 million. Between May 2024 and August 2025 alone, reported expenditures reached $3.5 million. At a time when Colorado faces an approximately $1.5 billion budget deficit, these costs substantially exceed initial projections presented to voters.

Depredation losses have included at least 60 confirmed livestock and working animals, with producers estimating significantly higher numbers.  There are also current 2026 livestock and cattle dog depredations now under review.  Compensation funding is not guaranteed long-term, placing producers at financial risk. 

VII. Federal Oversight and the 10(j) Rule

Colorado’s wolves are classified as a nonessential experimental population under Section 10(j) of the Endangered Species Act.

USFWS has since clarified that sourcing must come from Northern Rocky Mountain states. However:

• Those states have declined to provide additional wolves.

• Colorado previously sourced wolves directly from British Columbia.

• Questions remain regarding written USFWS authorization for the international transfer of 15 wolves from Canada.

If required approvals were not properly obtained or enforced, this raises federal compliance concerns under ESA and 10(j) provisions.

Additionally, with 14 of the originally transplanted 25 wolves are now deceased (56%), and program sustainability is in question. (The CPW has recently announced on-going efforts to remove a documented depredating wolf.)

The Colorado program is legally and structurally distinct from the Yellowstone National Park wolf reintroduction.  Colorado’s ballot-driven implementation does not establish precedent through Yellowstone.

Summary:

This document outlines significant concerns regarding the implementation of Colorado’s Wolf Reintroduction Program under Proposition 114. Based on the facts summarized here, we formally request that the United States Fish & Wildlife Service:

1. Assume federal management authority over the experimental wolf population in Colorado; and

2. Initiate immediate review and consideration of removal of wolves unlawfully sourced or released in violation of applicable state and federal law.

3. We, the undersigned, formally request that the United States Fish & Wildlife Service:

1.     Initiate a full federal compliance review of Colorado’s wolf sourcing and release actions;

2.     Clarify whether proper written authorization was granted for international wolf transfers;

3.     Take authority over the experimental Colorado Wolf population and end the Colorado Wolf Program.

4.     Evaluate immediate removal of wolves sourced and/or released in violation of federal or state law.

Federal oversight is necessary to restore compliance, protect agricultural producers, ensure ecological integrity, and uphold both voter intent and statutory law.

Signed,

Colorado Advocates for Smart Wolf Policy