Carnivore Coexistence Collaborative
Public scientists have a duty to advocate for the interests of the broadest public including future generations, for good governance, for fulfilling the duties of public trustees, and for the best available science. Carnivore Coexistence Lab created this website for the Carnivore Coexistence Collaborative (CCC) to report on advocacy and outreach. CCC also presents a new 2019 webpage on standards of evidence and scientific integrity.
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 scientists most 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 andor starting assumptions. See our transparent statement of value judgments here.. 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. The following is my current rebuttal to scientists who believe they are neutral and objective but others have an agenda because they advocate for democracy, ethics, or their evidence. I believe many scientists are fooling 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.
Adrian Treves' Advocacy activities and disclosures
Public comments, petitions, sign-on letters, and letters to agencies led by Carnivore Coexistence Lab experts
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.
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: 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.
All funding awarded to Adrian Treves as of 13 April 2022, which we provide for transparency and a CV for disclosure of potential competing interests.
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).