
By Jen Schumann | Rocky Mountain Voice
The fight over Colorado wolves has landed in a federal review process.
Opponents of wolf reintroduction are asking federal officials to reconsider Colorado’s wolf program after submitting a report that claims Proposition 114 did not actually pass.
Colorado Conservation Alliance filed the report June 5 with the U.S. Fish and Wildlife Service during a federal review of Colorado’s gray wolf program. Michael Clark, chairman of Colorado Conservation Alliance and CEO of Petrox Resources, signed the submission.
The filing takes aim at a message Clark says Coloradans have heard for years. “The message has been both constant and assertive, Colorado’s wolf program is ‘the will of the people’ because Proposition 114 passed,” Clark wrote to U.S. Fish and Wildlife Service Director Brian Nesvik.
Clark argues federal officials should take another look.
“Proposition 114—the validation behind Colorado’s entire wolf program—did not pass with a 1.8 percent margin—it failed,” he wrote.
The filing asks federal officials to review a report prepared by election analyst Seth Keshel.
“At minimum, USFWS should reconsider the MOU with CPW pending verification of the Proposition 114 report,” Clark wrote.
How the report came about
The report, titled Critical Analysis of 2020 Election in Colorado – Impact on Proposition 114, was prepared for Colorado Conservation Alliance.
Clark didn’t hire an unknown analyst. Keshel arrived with a track record that had already attracted attention beyond election-integrity circles.
In the foreword to his book The American War on Election Corruption, former House Speaker Newt Gingrich wrote that Keshel “correctly called every one of the swing states” in 2024 and said the results “confirmed the decisive power of Keshel’s methodology.”
Keshel said he came to the project as an election analyst, not a wolf-policy advocate. Colorado Conservation Alliance and the Colorado Independent CattleGrowers Association approached him to examine Proposition 114 and its connection to Colorado’s 2020 election.
“I didn’t even know that it was a down-ballot issue in the 2020 election until the groups approached me about doing an analysis.”
What caught his attention was not the wolf issue itself, but what he believed the data showed about ballot measures and down-ballot races.
“I was shocked at the impact that top-of-the-ticket election rigging has on down-ballot propositions and candidates,” Keshel said.
The report argues Proposition 114 is one example.
Why El Paso County stood out
Keshel’s report reviews all 64 Colorado counties, but El Paso kept showing up in his analysis.
Of the seven largest counties in the state, five voted for Proposition 114 and two voted against it. El Paso stood apart because it voted for wolf reintroduction while also backing Trump for president.
During an interview with RMV, Keshel said the county’s vote growth between 2016 and 2020 is what first caught his attention.
“This is by far the largest gain in votes in the history of Democrats in El Paso County,” Keshel said.
Trump added more than 23,000 votes in El Paso County between 2016 and 2020, according to Keshel. Democrats added more than 53,000.
“How did El Paso County, with the largest population in the state, spike so in favor of wolves while also supporting Trump?” he wrote.

Page 17: El Paso County became a focal point in Keshel’s analysis.
What the report concludes
Colorado’s certified results show Proposition 114 passing by 56,986 votes.
Keshel’s report reaches a different conclusion.
“My comprehensive statistical review of Colorado’s vote exposed a high probability of 264,389 excess ballots in the state’s 2020 presidential election,” he wrote.
He continued: “Colorado’s ballot count for Joe Biden was 264,389 higher than any reasonable forecast would predict.”
Colorado certified Proposition 114 as a winner. Keshel’s report says it lost.
Clark’s letter summarizes the result as a 5.7 percent margin in favor of the “No” vote.

Page 23: Keshel’s calculation of Proposition 114 under his statewide analysis.
“If you reduce the count for Biden … then it’s a certainty across the seven counties that I analyzed that the wolf referendum would have failed.”
How Keshel says he reached that conclusion
One example appears in the report’s review of county-level registration trends between 2016 and 2020.
According to Keshel, 26 Colorado counties became more Republican in voter registration during that period. Of those 26 counties, 10 shifted Republican in the certified presidential results. Meanwhile, 35 of the 38 counties that became more Democrat in voter registration also shifted Democrat in the election results.
“This finding requires a focused investigation into Colorado’s raw ballot totals of the Democrat nominee, Joe Biden,” he wrote.
The report does not argue Trump won Colorado.
“My analysis of Prop 114 does not call into question whether or not Joe Biden should have carried Colorado’s electoral votes,” Keshel wrote.
Colorado’s certified result still shows Proposition 114 passing by 56,986 votes.
What the coalition wants federal officials to do
The filing asks federal officials to review the report and reconsider whether Proposition 114 should continue to serve as the foundation for Colorado’s wolf program.
Clark argues federal resources have been committed to a program that rests on the approval of Proposition 114.
“Federal staff time and federal dollars have been spent on an action that was not authorized as CPW, other Colorado officials, and Governor Jared Polis in particular have asserted,” Clark wrote.
What began as a review of wolf management now includes a challenge to the vote that set the program in motion.
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