Dear President von der Leyen,

With this letter, I would like to contest the proposal to change the protection status of wolf Canis lupus within the EU.

As a matter of fact, I think the Council Directive 92/43/EEC on the Conservation of natural habitats and of wild fauna and flora and the Council Directive 2009/147/EC on the conservation of wild birds should reflect the endangerment status of a species, using the Red List as a template. That would mean a more continual assessment, but it would reflect the results from the scientific community better.

Since the wolf Canis lupus have not reached favourable conservation status in all areas withing the EU it would therefore remain in Annex V of the EU Habitats Directive.

In Sweden, where I live, the wolf population is endangered (EN, see reference 1), even though Member States are under an obligation to maintain favourable conservation status. Removing the species from Annex V could harm the citizens’ trust in the EU and the conservation Directives, since EU would not act on current scientifical knowledge.

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 (reference 2).

At least 300 individuals are needed for favourable conservation status (reference 3). For a good conservation situation with the possibility of long-term survival, the value of the genetically effective size of the contiguous population needs to be at least 500 (reference 4 & 5), which means at least 2,000 individuals (reference 6).

The Scandinavian wolf population is inbred; it has lost 10%–24% of the diploid genomes after about 20 years or around 5 generations of inbreeding, which means a loss of 160,000 SNP alleles (reference 7). The genetical exchange must increase between Scandinavia and Finland before the population could have a chance to be viable (reference 6).

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 (reference 8). Wolves prey on weaker specimens of elk in average than hunters (reference 9) which shows that the species has an important role as an apex predator in the natural selection: 
 

Neither how we hold farm animals, nor our hunting culture, are excuses for hunting wolves. We must change our ways in order to decrease conflicts, and it is possible, by other ways of hunting and in a more active engagement when holding farm animals. I have worked with nature conservation in pastures and meadows and would say that the animals most suitable for pastures with high biological diversity, such as cattle and horses, are least likely to become wolf prey. Sheep often consume threatened and signal species of herbs.

It is extremely rare to meet wolves in nature, and they do not attack humans. The arguments hunters and farmers use to argue for removing the species from Annex V are incomplete.

In view of all this, I would strongly urge you and the Commission to continue the infringement case against Sweden with regards to the licensed wolf hunt. I feel embarrassed as a citizen and as a conservation biologist that my Member State has allowed this for almost 13 years, especially since very few Swedish citizens are affected by the species in a negative way. We must be better to protect the ecosystems, that are the very foundation for our society and economy, and the species in it.

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

Best regards,

Johan Moberg

Conservation biologist
Uppsala