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41 Ariz. St. L.J. 905 (2009)
Unlucky Number 13: The Endangered Species Act, Subdelegation, and How Standard Operating Procedure 13 Jeopardized Mexican Wolf Reintroduction

handle is hein.journals/arzjl41 and id is 913 raw text is: UNLUCKY NUMBER 13: The Endangered Species Act, Subdelegation, and How Standard Operating Procedure 13 Jeopardized Mexican Wolf Reintroduction Natalie Greavest The female wolf hides in the undergrowth, watching for her opportunity in the growing dusk. The cows and calves continue eating grass, their heads down, intent only on what is in front of them. They are oblivious to her presence-not nearly as skittish as elk, her main prey. A calf wanders near. She lays her ears back and readies for the attack. Her mate and the rest of the pack tensely await her signal. At just the right moment, she launches from her hiding place, easily pulling down the unsuspecting calf and snapping the small backbone. The mother cow's eyes roll wildly as she plunges toward her calf Her alpha male mate and the rest of the pack seize the opportunity, taking the large cow down as well. The pups will eat well today, but success will not be without price. The she-wolf does not understand that she has just signed her own death warrant in cattle's blood. I. INTRODUCTION Endangered species protection, and wolf reintroduction specifically, seems to invite extensive litigation. A ten member consortium of environmental groups recently filed a case in the Arizona District Court alleging mismanagement of the Mexican Wolf Recovery program.' The legal issues presented in the case are extremely important in the area of environmental law. While several claims are alleged in the Complaint,2 this t Research Editor, Arizona State Law Journal, J.D. Candidate, Sandra Day O'Connor College of Law at Arizona State University, May 2010. Special thanks to Sawyer, Aspen, Caleb, and Roger. 1. First Amended Complaint for Plaintiffs Defenders of Wildlife, et al., Defenders of Wildlife v. Tuggle, 607 F. Supp. 2d 1095 (D. Ariz. 2009) (Nos. CV-08-280 DCB, CV-08-820 DCB). 2. Id. The First Amended Complaint alleged that: 1) the Fish and Wildlife Service (FWS) violated the National Environmental Protection Act (NEPA) by failing to prepare and circulate an environmental impact statement prior to its approval of a memorandum of understanding; 2) FWS violated NEPA by not preparing and circulating an environmental

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