We reviewed the 2015 N.H. State Wildlife Action Plan (SWAP), which recognized the eastern wolf (Canis lycaon) as both state and federally endangered.  Since 2015, recent genetics work provides substantially more in-depth research on the hybridization among northeastern canids, as well as the ancient origins of C. lupus, C. lycaon, C. latrans, C. latrans x lycaon (i.e., the eastern coyote or coywolf) and C. lupus x lycaon.  As the eastern wolf’s ancestral range included New Hampshire, its return is “important due to the potential impacts as a rare species” (SWAP, 2015), and because it is an endangered species.  

The SWAP of 2015 also recommended that New Hampshire should seek guidance from Minnesota, Wisconsin, and Michigan regarding recovering wolf populations. We would caution that the situation there, while similar, differs due to the presence in the Northeast of a much larger canid, the eastern coyote/coywolf (35–50+ lbs.), which breeds readily with the eastern wolf and is about 25-30% wolf (See Endnote 5).  The conservation implications of ‘similarity of appearance’ between coyotes and wolves in the northeast requires further consideration for different management efforts regarding canid populations.  

We would like to be considered stakeholders in the upcoming SWAP 2025 as we can offer some insight into possibilities for wolf recovery.  Below are some of our concerns and questions:

1. Does NH have a protocol for responding to possible live or dead wolves?  

2. If the USFWS has standards for the DNA analysis of wolves in the northeast sector, does NH adhere to these standards?

3. Does NH have a protocol for dealing with wolf sighting reports and possible dead wolves or for large canids killed? If yes, what is that protocol?

4. What is the status of implementation of NH’s 2015 State Wildlife Action Plan with regard to wolves?

5. Does NH provide any information to hunters and trappers on how to distinguish between admixed eastern coyotes and eastern wolves to prevent misidentification?

Regulatory Actions

The Northeast Wolf Recovery Alliance recommends the following regulatory actions to ensure the future of wolf recovery in New Hampshire, including the full enforcement of legal protections for wolves provided by the federal Endangered Species Act and constructive participation in a national wolf recovery plan. 

In order to reach a middle ground between complete legal protection for all wild Canis—which would provide the greatest protection for wolves—and current regulations allowing an open ‘coyote’ (we use the word coyote here but acknowledge that the canid that inhabits the northeast is a coyote-wolf hybrid) season with no bag limit or reporting, we ask that New Hampshire Fish and Game amend its regulations to institute the following protective procedures:

1. Regulate and limit the current open season on coyotes by establishing a limited hunting season from October 1st – December 31st. Also, bag limits should be applied to “coyotes”, similar to deer, bear, and moose.

2. All Canis killed in New Hampshire should be checked-in, similar to the check-in requirement that currently exists for deer and bear. Canis taken by hunting or trapping should be tagged and possession of untagged canids should be prohibited and penalized. This requirement will provide better regulation and needed data on the numbers, body sizes and characteristics of canids being taken in New Hampshire.

3. Checked-in canids that meet certain regulatory criteria (e.g., weight, size, canine spread, head and ear size) should be subjected to a DNA analysis to assess the genetic composition of the animal. This will provide critical data concerning the genetic makeup of large canids in New Hampshire and will identify wolves that are taken. The results of all DNA analyses performed on checked-in canids should be made available to the public annually on the Department’s website. The state should work with canid experts to use reputable labs that have prior experience genotyping hybridized canids in the eastern United States. We suggest that around 50 pounds is a good benchmark to use for possible wolf-like canids.

4. A two-year canid hunting moratorium should be imposed as soon as possible within the geographic area where a wolf kill has been documented. This measure is critical to protect other wolf pack members that may be present in the area. It may also deter hunters from taking large wolf-like canids to avoid the possibility that the take of a wolf will trigger a canid hunting moratorium.

5. Night hunting of “coyotes” should be prohibited due to the fact that hunting in nighttime conditions makes field identification of canid size exceptionally difficult. Additionally, the coyote hunting season should be shortened, and bag limits should be established. It should be recognized that eastern coyotes are already >25% wolf and this can confuse the public in differentiating existing hybridized canids (aka eastern coyotes) from wolves. Essentially, this similarity can create situations where people kill a small wolf (e.g., 60-65 pounds) thinking it was a large ‘coyote’.

Wolves are federally protected under the Endangered Species Act throughout most of the Lower 48 United States. In late 2022, the Center for Biological Diversity filed legal action against the U.S. Fish and Wildlife Service to seek a national wolf recovery plan; the lawsuit specifically notes the Northeastern U.S. as being one of several regions of the country where suitable wolf habitat exists and where wolves could thrive if protections are enforced, and recovery measures undertaken (see Endnote 6). A 2023 settlement of that lawsuit resulted in a court-ordered commitment by the U.S. Fish and Wildlife Service to develop a national wolf recovery plan for the gray wolf by the end of 2025, unless the Service finds that such a plan will not promote the conservation of the species (see Endnote 7). In addition to the wolves we have described that were killed in Vermont in the past 25 years, there is growing evidence of wolf recolonization attempts in other states across the Northeast. Similar documented events have occurred in New York, Maine, Massachusetts, and south of the St. Lawrence River only 20 miles from the New Hampshire border (see Endnotes 8 and 9). And all those individuals were found within wolf dispersal range of New Hampshire. There also certainly may have been wolves that have been taken/documented in NH as well, but without reporting requirements, those specimens could have gone unreported.

Indeed, wolves are attempting to reestablish in the Northeast. But without state and federal actions and commitments to protect these dispersers, the killing of individual wolves will continue, and wolves will not be able to gain a toehold here, especially considering our existing canid is a coyote-wolf hybrid that looks very similar to full-bodied wolves. New Hampshire has committed through its SWAP to take steps to protect the wolf as a Species of Greatest Conservation Need. It is time to begin a collaborative effort to facilitate wolf recovery and its concomitant ecological and social benefits. We look forward to collaborating with you in the very near future.

Sincerely,

Chris Amato

Conservation Director and Counsel

Protect the Adirondacks

Joseph S. Butera, 

President & Co-founder

Northeast Ecological Recovery Society

Brenna Galdenzi

President

Protect Our Wildlife, Vermont

John M. Glowa, Sr., 

President

The Maine Wolf Coalition, Inc.

Anne Jameson

Wildlife Advocacy Coordinator

Green Mountain Animal Defenders, Vermont

Sadie Parr

Founder & Program Director

WeHowl

Dan Plumley

Program Coordinator

The Wolf CLAN Initiative - Rewilding Institute

Jennifer Rosado, MS

Biological Field Technician

Maine Wolf Coalition

Lesley Sampson

Founding Executive Director

Coyote Watch Canada

Christine Schadler, MS 

Project Coyote Representative, Vermont & New Hampshire 

Founder, New Hampshire Wildlife Coalition

Renee Seacor, JD

Carnivore Conservation Director

Project Coyote 

Nadia Steinzor, MS

Northeast Carnivore Advocate

The Rewilding Institute

Jonathan Way, Ph.D.

Founder, Eastern Coyote/Coywolf Research

Author of Coywolf: Eastern Coyote Genetics, Ecology, Management, and Politics

Amaroq Weiss, MS, JD

Senior Wolf Advocate

Center for Biological Diversity

ENDNOTES

Endnote 1- In 2019, Maine Wolf Coalition volunteers began a massive effort over thousands of square miles to collect canid scat for DNA analysis to determine the status of wolves in Maine.  A scat we collected in 2019 was the first such proof of a live wolf ever documented in Maine.  https://www.mainepublic.org/environment-and-outdoors/2020-11-06/wolf-scat-discovered-in-maine-after-scientists-test-dna. Then, in December 2021, a hunter in New York shot and killed a large canid subsequently identified by genetic analysis at Trent University as 98% wolf. This was reconfirmed by Dr. Bridgett vonHoldt of Princeton University. See DNA analysis report here: https://extapps.dec.ny.gov/fs/programs/press/Fish&Wildlife/vonHoldt_report_NY_canid.pdf 

Endnote 2 - In November 1998, Eric Potter shot and killed an apparent 72-pound male wolf in Glover, Vermont (Zimmerman 2005). This animal was killed approximately twenty miles southeast of where a possible wolf was killed in Vermont in October 2006 (see below, #8). An analysis of its mitochondrial DNA conducted at the University of California at Los Angeles (UCLA) as noted in an undated letter from Jennifer Leonard of UCLA to Thomas Decker of the Vermont Dept. of Fish and Wildlife concluded, “…the control region of the mitochondria was amplified and 6 sequenced…(and the)…sequence matches that of the wolf (Canis lupus lycaon) endemic to the north east of the United States, and the south east of Canada….” The DNA of this animal was later analyzed by the USFWS. In a letter dated January 16, 2002 from Dyan J. Straughan, Forensic Specialist at the National Fish and Wildlife Forensics Laboratory, to Thomas Decker, Ms. Straughan stated, “The mitochondrial DNA type of this canid is most similar to that of coyote standards, but has also been observed in grey wolves in Southeastern Canada and Northeastern United States.” The actual examination results (Genetics Examination Report dated January 16, 2002) for mitochondrial DNA were as follows, “The mtDNA sequence of item LAB-2 differed significantly from reference mtDNAs of domestic dogs, red wolf (Canis rufus), grey wolf and fox, but was most similar to the mtDNA of coyote reference standards.” The results for Nuclear DNA were as follows, “The STR genotype of LAB-2 was intermediate between the coyote and Alaskan malamute reference samples included in the analysis.” We, the petitioners, respectfully disagree with and hereby challenge the USFWS’ interpretation of its DNA data regarding this animal. We refer to a November 26, 2001 email from Dr. Paul Wilson of the Natural Resources DNA Profiling & Forensic Center at Trent University in Ontario, Canada to Walter Jakubas, wildlife biologist with the Maine Dept. of Inland Fisheries and Wildlife. In his email, Dr. Wilson wrote, “The interpretation of the data depends on what evolutionary model one uses as a framework. All of the laboratories may generate exactly the same DNA sequence (sic). A mtDNA from lycaon will be interpreted as a coyote if the facility does not consider the newly proposed evolution of the eastern timber wolf/red wolf. The USFWS may not have classified their DNA sequences with a second North American wolf species in mind. The UCLA and USFWS results are entirely consistent with each other. We can all have the same databases and standardized approaches but the interpretation will always be laboratory-dependent.” To our knowledge, the State of Vermont has never officially acknowledged that the subject canid was not a wolf and they continue to question the DNA assessment generated by the USFWS. We refer to an October 24, 2003 email from Kim Royar, wildlife biologist with the Vermont Department of Fish and Wildlife, to Michael Amaral, a USFWS biologist in Concord, New Hampshire. Ms. Royar writes, “As far as we are concerned the genetic background of this animal is still unclear. We did send samples to 3 labs: UCLA, Ashland (USFWS), and Ontario (Wilson). UCLA extracted mitochondrial DNA and determined that the sequence matched that of “Canis lupus lycaon”. The mitochondrial results from Ashland suggested coyote but they only used 1 coyote reference and I’m not sure if any of their wolf references were from Canis lycaon (or from eastern Canada). Their nuclear DNA test suggested coyote and Alaskan malamute. I did review these results with a geneticist from UVM who felt their reference sizes were pretty low and suggested I ask for log likelihood scores…. They were not able to supply me with this information. I have yet to hear from Wilson.” “Anyway, you can see why we are still holding off regarding the labeling of this animal.” We, the petitioners, encourage additional DNA analyses of this animal and we maintain that the animal was a wolf, consistent with the aforementioned legal precedent for wolves in the Western Great Lakes DPS and known morphometric ranges for wolves.

Endnote 3 - On or about October 1, 2006, Charles L. Hammond of Newport Center, Vermont shot and killed a 91-pound male wolf in North Troy, Vermont. The animal was killed within twenty miles of a wolf pack that was being monitored by “wildlife workers” in Quebec, just north of the Vermont border (Harrigan 2005). We know of no evidence that the Vermont Fish & Wildlife Department, the USFWS, or the government of Quebec took actions to protect these animals. According to the Veterinary Medical Examination Report dated June 29, 2007, “The large canid carcass is a gray wolf according to both morphological and genetic studies.” Furthermore, according to a September 18, 2007, email from Dr. Roland Kays of the New York State Museum, this animal had “…the exact same mtDNA sequence…” as the wolf killed by Russell Lawrence in 2001. The fact that both animals had the same mtDNA sequence may be evidence of a breeding population of wolves south of the St. Lawrence River. On October 9, 2007, the Vermont Agency of Natural Resources issued a press release which falsely claimed that “The lab concluded that this animal was of captive origin.” In fact, the National Fish and Wildlife Forensics Laboratory concluded in its June 27, 2007, Genetics Examination Report that this “…male gray wolf is most likely of domestic origin.” A cover letter from the laboratory dated June 29, 2007, stated that, “…the animal is a gray wolf but perhaps from a domesticated origin.” The Vermont press release made no mention of the mtDNA match of the Vermont wolf with the 2001 New York wolf. It also made no mention of the October 5, 2006, email from Canadian Field Research Scientist Brent Patterson of Ontario’s Trent University that the face of the animal had “clear features of eastern wolves (but the over-all size and mass more typical of gray wolves).” The June 27, 2007 Genetics Examination Report from the Service stated that the mtDNA sequence was “…identical to the mtDNA of gray wolf reference standards found…in the western Great Lakes States DPS….” It also stated that the “…STR genotype…is most similar to gray wolf reference standards from the northern Rocky Mountain DPS” and that the “…Y-STR haplotype…is similar to that observed among gray wolves from…the Western Great Lakes DPS…(h)owever, the…haplotype is unique and has not been observed in our database.” We question and challenge any opinion/conclusion that this animal was “most likely of domestic origin” given its morphology, DNA, and diet (white tailed deer) and we disagree with this opinion, given the animal’s matrilineal relationship to the wolf killed in New York in 2001. As noted in the Service’s Report of Investigation, INV #: 2006505308 Report #3, “If the animal is determined to be a wolf it seems unlikely under the circumstances that federal prosecution would be sought pursuant to United States v. McKittrick. The subject indicated (he) believed the animal to be a coyote at the time (he) was pursuing it.” This is precisely why the commerce or taking of coyotes and wolf/coyote hybrids needs to be regulated due to their similarity of appearance to wolves, especially given the documented large body size of eastern coyotes (Way and Proietto 2005, Way 2007). Simply saying that you “thought the animal was a coyote” serves as a blank check when it comes to killing wolves. Mr. Hammond was subsequently not prosecuted for killing the animal. The McKittrick Instruction itself needs to be re-visited. It mistakenly requires that the killer of an endangered species must have known its biological identity before prosecution can take place.

Endnote 4 – In the Fall of 2013, a 78-pound canid was killed in North Hero, Vermont by Ray Beavolin.  The Vermont Fish and Wildlife Department sent tissue samples of this animal to Northeastern Wildlife Genetics, Inc. of Fairfax, Vermont.  Only the animal’s mitochondrial DNA was analyzed.  Further analysis is required to determine the identity of the animal.  Morphologically there is no such thing as a 78-pound coyote with eastern coyotes typically weighing between 30-50lbs.  

Endnote 5- Way, J.G. 2021. E-book. Coywolf: Eastern Coyote Genetics, Ecology, Management, and Politics. Eastern Coyote/Coywolf Research, Barnstable, MA. 277 pages. Open Access URL: http://www.easterncoyoteresearch.com/CoywolfBook/. 

Way, J.G., and J.L. Hirten. 2019. Wild Canis spp. of North America: a pictorial representation. Canadian Field-Naturalist 133: 295-296. 

Way, J.G. and Lynn, W.S. 2016. Northeastern coyote/coywolf taxonomy and admixture: A meta-analysis. Canid Biology & Conservation 19(1): 1-7. URL: http://canids.org /CBC/19/Northeastern_coyote_taxonomy.pdf 

Way, J.G. 2013. Taxonomic Implications of Morphological and Genetic Differences in Northeastern Coyotes (Coywolves) (Canis latrans × C. lycaon), Western Coyotes (C. latrans), and Eastern Wolves (C. lycaon or C. lupus lycaon). Canadian Field-Naturalist 127(1): 1–16. 

Monzón, J., Kays, R. and Dykhuizen, D.E. (2013), Assessment of coyote–wolf–dog admixture using ancestry-informative diagnostic SNPs. Molecular Ecology 23:182-197. doi: 10.1111/mec.12570.

Endnote 6 - https://www.biologicaldiversity.org/campaigns/gray_wolves/pdfs/Wolf- National-Recovery-Plan-Status-Review-Complaint-11-28-2022.pdf

Endnote 7 - https://www.biologicaldiversity.org/campaigns/gray_wolves/pdfs/Wolf_Stipulated_Settlement_Agreement_as_filed_and_approved_12_14_2023.pdf 

Endnote 8 - https://vtdigger.org/2022/07/26/dna-test-identifies-wolf-in-new-york-raises -questions-about-presence-of-population-in-northeast/ 

Endnote 9 – ESApetition2009final.pdf (easterncoyoteresearch.com)