Carnivore Coexistence Collaborative

'While the wave of scientific reform is influencing scientific practices and norms globally, the current model of higher education is largely outdated with respect to open science' (Center for Open Science 13 June 2023)

A note about advocacy and science

Sometimes scientists criticize each other for advocacy. All scientists advocate for our science including the process, methods, interpretations, and communication of it. Even if they don't realize they are doing it, each scientific communication we make is advocating for our science. It seems the activist part of that advocacy is what some scientists are actually shying away from - the idea of being vocal and out there in advocacy for science.

The other misconception might be the idea that ANY advocacy is biasing. But that myth has been debunked by several fields of scholarship proving that we scientists all approach questions (and how we answer them) with some viewpoint that shapes the questions we ask and don't ask, as much as the answers we get and emphasize. So, subjectivity enters into science and may create bias. The trick lies in reducing bias and making it transparent if some remains. That trick is a work in progress for most (all?) scientists and we here have chosen transparency about our value judgments or starting assumptions.  See our transparent statement of value judgments here.Beware of the scientists who do not make their value judgments transparent.

We believe many scientists are intentionally or unintentionally misleading themselves and their listeners about the nature of objectivity.  No one is neutral or perfectly objective – there is no perspective from nowhere, everyone asks questions that interest them and the answers we get to our questions depend on our values to some extent – but scientists are trained to be objective and place their own values as alternatives to other values, their answers as alternatives to other answers. That doesn't make us neutral but we are trained to be more objective than the average person, so at our best, we might overcome our own biases and support conclusions that our values seem to contradict. Beware of the scientists who do not make their value judgments transparent.

I see scientific evidence as the bedrock on which policy decisions should be made by all three branches of our constitutional democracy. Good decisions start with 'what do we know? and how certain are we about it?'. That's the bedrock. Then the ethical judgments enter the picture, reflecting our values and worldviews, to help us answer the question 'how should we behave toward others? And who are we and the others?'. This helps to answer why I engage with policy-makers in all three branches.

Public comments, petitions, sign-on letters, and letters to agencies led by Carnivore Coexistence Lab experts

2024

Dr. Treves supported a broad coalition to write the Trinity Act to protect grizzlies, wolves, and bison nationwide, which was announced by Senator Booker (D-NJ) on 19 September 2024. Senior aide Adam Zipkin and his team were critical in pushing the Act to this launch. That draft is here along with a press release. We expect push-back but in part the strategy is about messaging about the importance of federal-tribal government collaborations, indigenous stewardship, and the need for stricter preservation of these iconic species that play disproportionately important roles in maintaining ecosystem health.

As a member of the Board of Directors of P.E.E.R. (Public Employees for Environmental Responsibility, Dr. Treves signed on to several petitions and letters to the federal government. For a complete list of these, please email and identify who you are, with what organizations you are affiliated, and for what purpose you are inquiring.

As a member of the board of P.E.E.R. ( Public Employees for Environmental Responsibility), Dr. Treves signed onto at least 4 petitions led by P.E.E.R.

Consulted two Oregon state legislators on wolf management and preservation including discussing compensation payments, non-lethal methods, and poaching.

July 2024 sign-on letter to abolish the McKittrick policy of the US Department of Justice. Prof. Treves was a co-author of that letter and signed onto it. Click on the prior link to understand why this is both an issue of good science and of good governance.

21 May 2024 Public comment to Washington Department of Fish & Wildlife and the Washington State Commission concerning the science policy proposed to govern the science-policy interface for the Commission.

3 May 2024 Public comment to Washington Department of Fish & Wildlife and the Washington State Commission concerning the science behind the proposed down-listing.

Treves will serve as a 'standing declarant' and will write an affidavit for Great Lakes Wildlife Alliance v Wisconsin DNR and NRB, filed in Dane County Court in December 2023. See an Isthmus article about it and read the petition here.

2023

Adrian wrote a letter to the Washington state commission with concerns about scientific integrity in the Washington Department of Fish & Wildlife.

Coming soon: Treves signed on to two sign-on letters about science or law relating to grizzly bear delisting proposals by the USFWS and one relating to the North American model of wildlife management (which is not a model but a mantra because models are supposed to be simplifications of reality to teach us how a system works, not a value judgment about how the system should work. The NAM is a mantra perpetuated by scientists who believe in hunting, trapping, hounding, fishing, etc. and by lobbyists and agency staff captured by narrow, special interests.

Treves comment on he Silvio O. Conte NFWR supplemental Environmental Assessment and revisions to its Hunt/Fish Plan, Vermont, 10 May 2023.

Treves' public comment, 16 April 2023, and EPA comment on draft EIS dated 25 April 2023citing Treves' work.

Petition challenging legality of the appointment of USFWS Director M. Williams, 14 April 2023.

COlorado 10j Letter to President Biden about federal beaver policy, 26 Feb 2023.

Alaska NWR Treves comment on Alaskan NPS Wildlife refuges, 26 Feb 2023.

In 2023, numerous jurisdictions undertook revisions of wolf management and called for public comment. Because many did not permit the upload of large numbers of scientific articles yet omitted high-quality science that was inconvenient to their policies, I filed all public comments with a link to this archive of relevant science. If you find your state, tribal, or federal government agency in charge of wildlife did not include the attached articles in their administrative public record, please inform me. Also, please hold them accountable to the rule of law. Our comments cannot be ignored for cause of state of residence, citizenship, or any other discriminatory criterion, including your opinion of their policies.

Wolf policies in

Idaho here.

Colorado here.

Wisconsin here.

2022

Comment on New Jersey’s 2022 proposal for another black bear hunt in 2023. click here.

Treves, A., Santiago-Ávila, F.J. 2023. Estimating wolf abundance with unverified methods. Academia Biology in press, Pre-print posted for pre-publication review. Compressed source documents from the state (WDNR 2022 population reports, greensheet and Stauffer et al. 2021).

Video from April 2022, Adrian Treves speaks with Oregon commissioners. Also see the q&a with all participants here.

Treves A, Elbroch, LM, Koontz F, Papouchis CM. 2022. How should scientific review and critique support policy? PLoS One Comment on Laundre & Papouchis 2020. Access PLoS One site and our full disclosure of potentially competing interests because the word limits on the journal site required us to abridge it..

Public Employees for Environmental responsibility (PEER) petition to Department of Interior. 27 October 2022.

Treves expert declaration in Wildearth Guardians and Western Watersheds Project v USDA-APHIS, S-Wildlife Services, U.S. Forest Service, And Bureau of Land Management, United States District Court District of Nevada Case No.: 3:21-CV-00508-LRH-CLB Filed 19 Sep 2022

Treves, Darimont, Santiago-Ávila 2022. calling out irreproducible research underlying the State of Wisconsin's wolf policy set by the Department of Natural Resources. Also attached to the original article here.

Treves and louchouarn 2022. recalculating our 2022 model of the Wisconsin wolf population in April 2022 see here using a different estimate of infant survival. We also enumerate the (now) five cases in which current or former WDNR employees failed to correct, retract, or inform the public of errors or omissions of important information about wolf science that could affect public policy.

July 2022 Treves public comment on science in the Minnesota and Michigan the wolf management plan revisions send updates.

January 2022 Michigan, July 2022 Michigan, and July 2022 Minnesota.

15 April 2022: Treves signed a scientific sign-on letter opposing a California black bear hunt because of lack of evidence. Also, rebutting false or unsubstantiated claims by "Sportsmen" Full text here.

7 April 2022: Treves signed a scientific sign-on letter clarifying the concerns about how Department of Interior was monitoring Idahos' wolf-killing Full text here.

6 February 2022: Treves commented on compensation for wolf damage to the Oregon subcommittee hearing public comment on HB 4127 Full text here.

12 January 2022: Treves signed a scientific sign-on letter petitioning Secretary of Interior Deb Haaland for emergency re-listing of gray wolves int he Northern Rocky Mountains Full text here.

2021

11 October 2021: Treves filed an affidavit in state court on behalf of plaintiffs Great Lakes Wildlife Alliance et al. Full text here.

10 August 2021: Treves public comment (written and oral on 11 August) for the NRB on the likely harms to the state wolf population if they approve or raise the NR's recommended quota of 130 wolves for the Fall 2021 wolf-hunt. Full text here.

4 August 2021: Treves public comment on the DNR's recommended quota of 130 wolves for the Fall 2021 wolf-hunt Full text here.

28 July 2021 Treves wrote to the White House Office of Science & Technology Policy in response to their call for public comment on scientific integrity Full text here.

13 July 2021: Treves, Santiago-Ávila, Putrevu share their 2021 paper and respond to criticisms from the DNR. Full text here.

6 July 2021: Petition to USFWS to retract proposed rule 50 CFR Parts 32 and 71 2021–2022 "Station-Specific Hunting and Sport Fishing Regulations" across the National Wildlife Refuge system. Full text here.

2 July 2021 Letter to Wisconsin DNR's Jennifer Price Tack and Randy Johnson alerting them to (mis)interpretation of the Adams et al. 2008 model and misuse for design of wolf hunting. Click here for full text.

18 June 2021 and 23 June 2021, Prof. Adrian Treves, PhD, offered a comment on Wisconsin Wolf management. For the full text of the comment, Click here

16 June 2021, regarding the scarcity of evidence making the goals of WDNR regulations impossible to achieve and the scarcity of evidence making hounding, night-time hunting, and snowmobile pursuit risky and unscientific. For the full text of the comment, Click here

4 June 2021: The WDNR has often claimed that hunting wolves and other predators will generate net benefits for society. The common benefits claimed are protection of livestock, human safety, and improved tolerance for the survivors in the same population. The scientific evidence does not support these claims. For the full text of the comment, Click here

15 May 2021: regarding all aspects of wolf science. For the full text of the comment, click here. For the Appendices click here and for references cited click here.

15 May 2021: Comment to WDNR by Dr. Francisco J. Santiago-Ávila Full text here.

Related public comments sent to tribal and Wisconsin state officials can be found here.

13 May 2021, >100 scientists urge USFWS to delist the gray wolf nationwide in this letter.

On 29 September 2020, Dr. Treves met virtually with the White House Office of Management and Budget's office of Information and Regulatory Affairs to warn of likely outcomes of nationwide gray wolf delisting. The attached memo describes the content of Dr. Treves' communications to the following attendees: Maricela Constantino  - DOI Sean Gallagher  - DOI, Bivan Patnaik  - DOI, Kristen Floom  - DOI, Austin Mudd  - OIRA, Maureen Trnka  - OIRA, Julie Hewitt  - OIRA, Matthew Oreska  - OMB, and Ellen VanGelder  - DOI.

The official record of that meeting is here.

In December 2020, Gary Frazer Assistant Director of USFWS sent a letter to the California Fish & Game Commission to try to reassure them that California's fledgling wolf population would not be harmed by federal delisting of gray wolves. Dr. Treves responded, correcting poor science and inaccuracies in the USFWS letter. For the California FGC letter that started the discussion click here, then see the USFWS response to CA FGC and Treves reply.

In 2019, the U.S. Fish & Wildlife Service proposed to delist gray wolves nationwide.

Dr. Treves served as an official peer reviewer for the 2019 proposed rule and draft biological report. Read his report here. And listen to a radio show that addresses this and other wolf policy issues on WPR here.

Read all 5 peer reviews and the contractor's summary here. The views in this report do not necessarily represent the views of Dr. Treves or the Carnivore Coexistence Lab.

Dr. Treves also submitted a public comment on 14 July 2019 to supplement his official peer review.

Dr. Treves filed this report to the French Ministry of Environment for the FrenchGovernment's Scientific Council on Wolves, starting in 2019.

Working with the Union of Concerned Scientists: Scientists Push for Independent Science at the Fish and Wildlife Service. Scientists working together to advocate for better use of science in species listing and delisting decisions can lead to real change in ESA implementation.

In 2015, a group of scientists, working with the Union of Concerned Scientists and Project Coyote, launched a petition asking the Department of the Interior (DOI) and the Department of Commerce (DOC) to follow a process for obtaining independent scientific advice on listing and delisting decisions under the Endangered Species Act (ESA) See the scientific petition sent to Secretaries Jewell and Pritzker (of the U.S. Departments of Interior and Commerce).

Led by UCS Science Network member and associate professor at the University of Wisconsin-Madison Adrian Treves and attracting nearly a thousand signatories, the scientists’ letter outlines how the ESA mandate for best available science could be improved by relying on external, independent scientific input, without interference from non-scientists. The scientists asked the DOI and DOC to entrust the scientific evaluation of species listing and de-listing determinations to an external committee of scientists who are best suited to assess the scientific evidence and make a public recommendation to the agency, based solely on the best scientific and commercial data available, as the ESA requires.

Following the petition launch, the FWS issued a new and improved peer review policy for the agency. The new policy is a step forward in safeguarding the science that informs endangered species listing; it provides a clear and consistent, agency-wide framework that improves the separation between scientific status assessments and policy decisions, provides more clarity around agency procedures when decisions are controversial, and increases transparency (Goldman et al. 2016). While the provisions could be stronger in a few areas, the new policy takes strong steps toward more robust and transparent peer-review at the agency.

2019-2020 Update: After Dr. Treves participated in a scientific peer review for nationwide delisting of the gray wolf Linkhere., he found the process had improved by (a) preventing the USFWS from cherry-picking its external scientists to get the results it wanted politically an d (b)creating a transparent document without editing or outside modification of the peer reviewers’ writing in a format easily obtained by the public. However, the Trump Administration still ignored the science despite all 5 external peer reviewers finding shortcomings in the biological summary and the conclusions drawn from it. Four out of five found major shortcomings and few if any of the suggestions led to improving the proposed delisting. Therefore, in my opinion, the decision to delist was politically motivated and prejudged, while the science was ignored.

For complete disclosures of potentially competing interests whether financial or non-financial, see the following links: Adrian Treves funding (to protect the privacy of individual donors, I have withheld their names and details but can make these known to legitimate scientific integrity organizations upon request) , and complete, latest CV 2024. Also collaborators offer CVs to support disclosures for publications and comments above on which they are co-authors or signatories: Dr. Naomi Louchouarn CV from 2024; and Dr. Francisco Santiago-Ávila CV.

Reports to the Michigan government on wolf management 2013 and 2015: in collaboration with the Little River Band of Ottawa Indians.

Minor public comments and letters to governments

click here for mypublic comment on the USFWS plan for cross-fostering Mexican wolves in 2021.

2020: Public comment on 15 June 2020 regarding Mexican wolf management under the modified 10j rule following USFWS loss in federal court.

2016: Letter to the Michigan government on wolf management.

2016: Letter to the Michigan government on wolf management.

November 30, 2015 : 70+ scientists, legal experts, and scholars recommended that wolves be kept under ESA protection.

October 28, 2015 : Dr. Adrian Treves commented on the Oregon state wolf delisting proposal. He found (1) Oregon’s delisting criteria have not been met, and (2) The main threat to wolf population viability is not adequately understood by any state or federal agency yet, therefore the expected benefits of delisting are unlikely to manifest and the likely costs are not well addressed by current regulatory mechanisms. February 2016 Multiple scientists weigh in on Oregon's wolf delisting process.

June 13, 2014 and October 17, 2014: We opposed proposed predator killing derbies and wildlife killing contests as serving no value for management or science, and contrary to the government agency policies responsible for land and wildlife management.

Petition to USFWS to list the Florida black bear hunt as federally threatened or endangered.

Letter to the U.S. Fish & Wildlife Service from scientists concerned about Wisconsin wolf policy and management. (updated October 15th, 2014).

Click here for the government documents we cite.