Dear European Commission,  

I am writing in regard to the Commission’s invitation to submit up-to-date data on wolf populations and their impact. 

I strongly advise against weakening the protection of wolves in the European Union and in Sweden in particular. A weakening of the protection would have a vastly detrimental effect on nature preservation in the Union and could very well lead to the extinction of the already fragile wolf population in Sweden. 

I call for the Commission to proceed with the ongoing infringement case concerning Swedish wolf management. This year, Swedish authorities decided to allow the hunting of 75 wolves. A record-breaking 57 wolves were shot – more than 12 per cent of the population. This evident transgression of the strict protection in the Habitats Directive gives strong reason for the Commission to bring the infringement case to the Court of Justice of the European Union.  

In line with the invitation, I would especially like to draw the Commission’s attention to the following facts and data: 

The Scandinavian wolf population is small, isolated and fragile. In the winter of 2022-2023, the Swedish wolf population was estimated to 450 wolves, according to an official monitoring report:https://hdl.handle.net/11250/3068933

Due to decisions on hunting allowances from Swedish authorities, illegal hunting, accidents and natural mortality, the Swedish wolf population was estimated to have drastically decreased to 368 wolfs in the autumn of 2023, by Swedish University of Agricultural Sciences: https://www.slu.se/globalassets/ew/org/centrb/vsc/vsc-dokument/vsc-publikationer/andren-et-al-2023-berakningar-av-jaktuttag-varg-2024.pdf 

Contrary to the Swedish Government’s official standpoint, the Swedish wolf population has not reached Favourable Conservation Status. Due to flawed management, small numbers and isolation, the Swedish wolf population still suffers from severe genetic problems. The inbreeding coefficient (0.24) shows that Swedish wolves in average are as closely related to each other as descendants from siblings (0.25): https://hdl.handle.net/11250/3068933. In April 2020, the Swedish wolf was classed as Endangered in the National Red List: https://www.artdatabanken.se/det-har-gor-vi/rodlistning/dagens-rodlistade-art/varg/ 

Wolves have a considerably positive effect on Swedish nature and ecology. Swedish research reports show for example that remains from prey killed by wolves benefit other species (Wikenros 2011). Wolves prey on weaker specimens of elk in average than hunters (Sand, Wikenros et al. 2012) which shows that the species has an important role as an apex predator in the natural selection: 
https://www.slu.se/globalassets/ew/org/inst/ekol/forskning/projekt/skandulv/publikationer/doktorsavhandlingar/wikenros-2011-the-return-of-the-wolf---effects-on-prey-competitors-and-scavengers.pdf 

https://cdnsciencepub.com/doi/10.1139/z2012-007 

Wolves contribute to a well-functioning ecosystem and non-Swedish academic experts in a governmental panel found that the Swedish wolf population should reach 600 wolves to fulfil the criteria of ecological viability (see ‘Joint Statement’). Despite this, the Swedish Environment Protection Agency used this statement as the scientific foundation for a Favourable Reference Population of only 300 wolves: https://www.naturvardsverket.se/globalassets/amnen/jakt-vilt/bilder/ru-utreda-gynnsam-bevarandestatus-varg.pdf 

The damage caused by wolves on domestic animals in Sweden is comparatively low and has stabilized over time. Wolf predation on sheep, the most common damage to domestic animals in Sweden, was limited to 250 sheep in 2022; less than a tenth of a percent yearly. https://www.slu.se/globalassets/ew/org/centrb/vsc/vsc-dokument/vsc-publikationer/rapporter/viltskadestatistikrapporter/viltskadestatistik-2022.pdf 

A vast majority of Sweden’s citizens are in favor of wolves in Sweden (69 percent) and few are in opposition (12 per cent). https://pub.epsilon.slu.se/25129/1/dressel_s_et_al_210827.pdf 

To conclude, I strongly urge the Commission to take action to protect Europe’s valuable wolves, and not weaken the necessary protection. 

Best regards,

Sanna Törneman
Gothem Gotland