Dear European Commission,  

Following the Commission’s invitation to submit data on wolves, I want to point out that we need growing populations of wolves in Europe and Sweden! As an apex predator, wolves are important for the functioning of ecosystems and worth a continued strong protection. I work with threatened grouse, and recently attended a conference where we discussed the quickly disappearing presence of these enigmatic birds in Europe. The majority of populations have disappeared, and black grouse only exists as transplants in Belgium and the Netherlands. A big issue is predation by smaller predators, that historically had lower densities with the help of wolves. We have messed up the balance, disturbing complex interactions.

It's disheartening that we are not able to let wolves flourish. Other parts of the world struggle with dangerous carnivores, and live side by by side with tigers, lions, and elephants. We realize that there are solutions that don't necessarily mean eradication. Instead of learning how to deal with the protection of domestic animals, we want to take the easy path and limit wolves that will make their existence unsustainable in the future. Please let the strict protection of wolves remain. Below are some examples that support my reasoning.

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 

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 

I am a geneticist, and urge that you consider how such a small population size will constrict local adaptations and the potential to evolve in our rapidly changing world. I ask that the Commission take action to protect Europe’s valuable wolves, and not weaken the necessary protection. 

Best regards,

Lena Larsson, PhD
Tyresö, Sweden