Breath of Clarity

Comment on Reconsidering Stakeholder Analysis

Original Post by Kevin Barry:

In examining stakeholders for the implementation of Proposition 114 and RMEF’s involvement, I failed to expand upon two groups that endorsed the legislative change, the Global Indigenous Council and the Rocky Mountain Tribal Leaders Council. These groups represent Native American tribes residing in Colorado, which represent approximately 50,000, or just under 1% of the state’s population (ALA, 2017). Most tribal land in Colorado is located in the southwest corner of the state, which falls within the geographic realm of where CPW intends to reintroduce a sustainable population of wolves west of the Continental Divide. Hypothetically speaking, wolves could migrate into the Southern Ute, Ute Mountain, and Navajo Indian reservations in Southwest Colorado.

As sovereign nations, tribes have authority over their lands and a unique relationship with federal agencies. Many tribes support protection for wolves and view them as sacred or religious in their culture. The gray wolf was recently delisted from the Endangered Species Act, though it is expected to be challenged in federal court this year. The species remains listed as a state endangered species in Colorado, however. The unclear outcome of its federal listing and anticipated reintroduction of the gray wolf creates a unique issue for CPW, federal agencies, and tribes if populations were to inhabit tribal land. As it stands, states and tribes have the authority to reintroduce and manage wolf reintroduction without approval from the U.S Fish and Wildlife Service. This could change, pending the outcome of litigation challenging the delisting of the gray wolf.

CPW has worked closely with Native American tribes on similar conservation and reintroduction efforts, including the cutthroat trout conservation program in 2014 (CPW, 2014). Cooperation between the state, tribes, and federal agencies will be necessary for the proper management of gray wolf populations moving forward. Not all of the indigenous community supports wolf reintroduction, however. The Southern Ute Council recently passed a resolution opposing “any effort to reintroduce or expand the population of gray wolves in Colorado.” The Ute Mountain Ute, another tribe located in western Colorado, has yet to take an official position (Marshall, 2020). Due to the passing of Proposition 114, it will be important for the state to engage Native American tribal stakeholders to ensure that their input into reintroduction and management decisions that impact tribal territories are heard.

Native American tribes should be considered a top stakeholder in wolf reintroduction in Colorado, especially with the implication of wolves migrating further southwest onto reservations. Their role in Proposition 114 is unique, as they represent a minority class that is directly impacted by the repercussions of the issue. As is the common theme this week, Proposition 114 and a majority of its stakeholders are white. Interest groups in favor of re-introduction include the Sierra Club and other environmental advocacy groups, which are overwhelmingly white, as studies have suggested (Finney, 2014). On the other side of the aisle, hunting groups, farm agencies, and private landowners are comprised of mainly white men. In the middle of the issue, agencies such as NPS are made up of around 53.5% white males, with minorities accounting for 20%. Minority numbers are much lower in the Forest Service (Hendricks 2006, 4). It is imperative that CPW and federal agencies work with Native American tribes during reintroduction planning because historically, the concerns of these individuals have been largely ignored throughout history. CPW should be responsible for including Native American tribes in their discussions with other stakeholders. I was on a Zoom call with many stakeholders earlier this week and now realize that there were no representatives in attendance from either the Global Indigenous Council or the Colorado Commission of Indian Affairs. I am not sure whether this was unintentional nor if this was the correct venue due for input. Regardless, controlling interests in the matter must seek out input from Native American stakeholders. Our government should never intentionally or unintentionally overlook minority parties in any matter in which actions and outcomes will directly affect a group, no matter the issue.

American Library Association. 2017. Indigenous Tribes of Colorado. to an external site.

Marshall, Sage. 2020. Election Night Could Be Rob Edward’s Time to Howl. to an external site.

Colorado Parks and Wildlife. 2014. Colorado signs on to Rio Grande cutthroat trout conservation agreement. to an external site.

Finney, Carolyn. 2014. Black Faces, White Spaces: Reimagining the Relationship of African Americans to the Great Outdoors. Pp. 25-31, 32-51, 67-91.

Comment by Professor Frank Turina:

It is true that Native American Tribes have a unique relationship with federal agencies.

In 2000, Presient Clinton issued Executive Order 13175 Consultation and Coordination with Indian Tribal Governments. The EO recognized tribal rights of self-government and tribal sovereignty, and affirmed and committed the federal government to a work with Native American tribal governments on a government-to-government basis.

Federal agencies have an obligation to initiate government-to-government consultations with tribes to solicit comments on any proposed actions. It’s important to remember that this is a separate process from more traditional public outreach efforts that are often conducted during development of NEPA documents or rulemaking processes. Technically, Tribes are not part of the U.S. “public.” They are sovereign nations that must be consulted through a different process than the “public.”

My Comment:

Hi Kevin and Professor Turina,

It is interesting to see the value Executive Order 13175 places on tribal knowledge in natural resource management. One positive consequence of this policy is tribal management is relatively uninfluenced by national or state politics which do not necessarily yield scientific-based outcomes (Kenney 2012). Also, tribal management is intrinsically stabilizing because tribes have an inherent interest in both the health of their aboriginal lands and local economies (Kenney 2012). Further, in November 2009, President Obama issued a Memorandum for the Heads of Executive Departments and Agencies, Subject: Tribal Consultation, which required each agency to submit a plan to implement Executive Order 13175 (Kenney 2012). One result of the initiative is in Idaho, where the U.S. Fish and Wildlife Service (USFWS) and the Nez Perce Tribe have implemented a tribally crafted wolf recovery plan with great success (Kenney 2012). This plan called for management actions both on and off the Nez Perce reservation lands and on and off treaty ceded lands (Kenney 2012). The USFWS executed a cooperative agreement, under the broad authority of the Endangered Species Act, authorizing the tribe to perform a variety of management activities both on and off the tribe’s ceded territory with USFWS funding (Kenney 2012). Today, the USFWS-sponsored wolf recovery project represents a sustained thirty-year effort by the tribe (Kenney 2012).


Kenney, Brett. 2012. “Tribes as Managers of Federal Natural Resources”. Natural Resources & Environment. 27(1): 47-50.