Why the Feds Say Wolves Don’t Need a Recovery Plan

Written by Justin Park| 11/18/2025

The gray wolf was nearly wiped out in the lower 48 states by the early 1900s, surviving only in Alaska and a remnant population in northern Minnesota. After being listed under the Endangered Species Act in 1978, wolves rebounded in several regions, including Idaho, Wisconsin, Montana, and Wyoming.

Today, thousands of wolves live in the lower 48s and are concentrated mainly in the Great Lakes and Northern Rockies. Yet lawsuits from environmental groups have repeatedly pushed the species on and off the endangered list. 

The newest flashpoint came this month when the U.S. Fish and Wildlife Service announced it would not create a national recovery plan. This was required under a settlement with the Center for Biological Diversity unless the agency provided a legally sound explanation for declining to do so.

In its announcement, FWS argued that wolves do not qualify for listing under Section 4(a)(1) of the ESA. This is the section that outlines the factors used to determine whether a species is threatened.

“Recovery plans would not promote the conservation of the gray wolf…because listing these entities is no longer appropriate under the Endangered Species Act,” the agency wrote. 

FWS also emphasized that wolves exist in distinct regional populations and argued that a single national recovery plan is not biologically meaningful for how the ESA is designed to work.

This builds on a finding where FWS stated that “the gray wolf in the Western United States is not in danger of extinction or likely to become so in the foreseeable future.”

But a federal judge in Montana ordered the agency to revisit environmental groups’ petition, ruling that FWS had not fully addressed certain threats, including state-level hunting policy changes.

Meanwhile, a new bill called H.R. 845, the Pet and Livestock Protection Act, sits in Congress. The bill would reinstate the 2020 delisting of wolves nationwide and, critically, states that the delisting “shall not be subject to judicial review.” The intent is to halt the cycle of lawsuits that has repeatedly overturned FWS decisions.

As litigation and politics continue to collide, the lack of a national recovery plan signals a shift in federal posture. Wolf management may increasingly default to states and tribes, leaving the species’ future to a patchwork of regional policies rather than a single federal roadmap.

AUTHOR BIO: Justin Park is a Colorado-based writer, editor, and avid hunter with a passion for the outdoors. He contributes to leading publications such as GearJunkie, Popular Mechanics, Powder, and Men's Journal, and serves as Editor of Wild Snow. Park is deeply involved in conservation and recreation advocacy, serving as Chapter Chair of the Rocky Mountain Elk Foundation (RMEF) in Summit County. He also represents RMEF on a state recreation committee focused on proactively addressing land use conflicts.