Dear European Commission,  

Following the Commission’s invitation to submit data on wolves, I want to underline facts that clearly show that the growing populations of wolves in Europe and Sweden is a predominantly very positive development. As an apex predator, wolves are important for the functioning of ecosystems and worth a continued strong protection. 

Please let the strict protection of wolves remain. There are several good reasons for that, as listed below.

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 

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

Best regards,

lou fallenius
stockholm