DEADLINE: Please Comment Now to Save Grizzlies!

The U.S. Fish and Wildlife Service (FWS) wants to strip Endangered Species Act protection from the Greater Yellowstone Ecosystem grizzly bear. We have only until 11:59 p.m. on October 7 to comment on the FWS proposal. If you haven't yet commented, please do it now.

For our comments to be most effective, they should present reasons that show delisting is not a scientifically sound idea. A comment that simply says, “Don’t delist the grizzly!” may be heartfelt, but it will not carry much weight with the FWS. A comment that challenges specific FWS reasons for delisting will be much more effective.

Your comment doesn’t have to be a work of art, it just needs to address the flawed science behind the delisting.

Below you will find nine claims that FWS has made to support delisting. After each claim, you will find a short explanation from a scientist or conservation agency on why the claim is not valid. I have collected this information and posted it here so that you can use it to make your comment effective. Pick one or two or all nine of these reasons and craft a comment using your own words. 

If you have other reasons that show grizzly delisting is not scientifically supported, please add them here by writing a comment to this blog. 

Here’s the link to post your comment for FWS to read.

Thanks for taking the time to speak for the grizzly. Happy commenting!

Yellowstone Grizzly. Photo by Mary Strickroth

FWS claim: There are more than 700 grizzlies in the Greater Yellowstone Ecosystem (GYE), and that’s enough to delist them.

The reality: No one really knows how many grizzlies are in the GYE. David Mattson, an ecologist who spent more than 20 years studying grizzly bears in and around Yellowstone, doubts the FWS numbers. “…what you'll hear from the [U.S.] Fish and Wildlife Service is that the population has tripled and even quadrupled in size, and I think that's a gross exaggeration.”

FWS claim: The shortage of cutthroat trout and whitebark pine nuts—two of the grizzly’s primary foods—is not a threat to the grizzly’s long term survival.

The reality: Not so, says Sylvia Fallon, Senior Scientist with the Natural Resources Defense Council. She told Montana on the Ground: “Yellowstone grizzly bears are an isolated population that is experiencing high levels of conflicts with people and is likely declining in the wake of the loss of whitebark pine, a critically important food source.”

The Center for Biological Diversity says that climate change and other factors have caused key grizzly bear food sources to collapse, and grizzly mortality rates have been increasing. The result is hungry bears roaming outside Yellowstone National Park more often. If those hungry grizzlies lose their legal protection, they could be shot the minute they step outside of Yellowstone.

FWS claim: The Greater Yellowstone Ecosystem (GYE) grizzly has recovered enough range to be delisted. 

The Reality: Under the Endangered Species Act, species must be treated as a whole unless FWS can prove that the animals in one area are biologically different than the animals in another area. As reported by Montana on the Ground, “…groups such as WildEarth Guardians point out that the Yellowstone population of grizzly bears is no different from those in the Northern Continental Divide region or the Cabinet-Yakk region.” Therefore, the grizzly bear cannot be delisted in just the GYE.

Yellowstone Science magazine recently devoted an entire issue to the grizzly bear. A couple of the articles show that the population of the grizzly bear has not recovered enough to be delisted nationally either. In North America, grizzly bears once roamed from Northern Alaska south to Mexico and from the Great Plains west to the Pacific Coast.

But by the 1930s, grizzly bears in the Lower 48 had been reduced to less than 2% of their histori­c range. Grizzlies now survive in only 4% of their historic range in the Lower 48. 

The Greater Yellowstone Ecosystem (GYE), a region of Wyoming, Montana, and Idaho that includes Yellowstone National Park, has the largest grizzly population in the Lower 48. FWS estimates around 700 grizzly bears live in the GYE and perhaps as few as 800 to 1,000 in the entire Lower 48.  Compare that with the 50,000 grizzly bears that once roamed North America. The species is far from recovered nationally. 

USFWS photo by Terry Tollefsbol

FWS claim: Their agency will stay involved with protecting the grizzly population after delisting.

The reality: The Humane Society of the United States (HSUS) announced it would fight the FWS delisting and hand-over of management to Idaho, Montana, and Wyoming. 

HSUS said that if GYE grizzly bears are delisted, the three states have already signaled, in the form of a leaked memo, that they will open up trophy hunting seasons for the bears.  HSUS believes that opening such seasons is a prime motivation for the states in pushing for de-listing. 

FWS claim: The agency will monitor grizzly numbers to make sure they stay at sustainable levels after delisting.

The reality: When David Mattson, an ecologist who spent more than 20 years studying grizzly bears in and around Yellowstone, looks at the future after delisting, he sees the grizzly population tumbling to dangerously low levels. He told Montana Public Radio that if we looked two years into the future “…the grizzly population will be down to 600, at which point, even by [FWS] reckoning there will be no prospect of any sport hunting at all, and that not too long after that we will be below 600, headed to 500, using their methods.”

Climbing back up from this decline will be difficult. Grizzlies are one of the slowest-reproducing mammals in North America, says Roger Hayden, managing director of Wyoming Wildlife Advocates. If conditions are right, a female gives birth only every three years.

In short, FWS will have spent more than 40 years recovering the grizzly population, only to see it squandered in a couple of years of sport hunting.

Yellowstone Grizzly and friends. Photo by Rick Lamplugh

FWS claim: Montana, Idaho, and Wyoming will successfully use hunting to manage the recovered grizzly bear population.

The reality: The Greater Yellowstone Coalition (GYC) opposes sport hunting of grizzly bears and believe sport hunting is unnecessary for managing a stable bear population. At minimum, says GYC, a delay in the onset of hunting until the states have demonstrated their commitment to maintaining a stable population, particularly given the record high number (59) of bears killed in 2015, seems prudent. The leading cause of bear mortality is conflicts with humans.

FWS claim: Montana, Idaho, and Wyoming will each have a plan for managing grizzlies as each state sees fit.

The reality:  This approach is as flawed with grizzly bears as it is with wolves. The Greater Yellowstone Coalition (GYC) says that the Yellowstone grizzly bear population should be managed as an ecosystem population, not as separate Wyoming, Idaho, and Montana populations. These three states, along with the U.S. Forest Service, National Park Service, Native American tribes and the Interagency Grizzly Bear Study Team must continue to coordinate and communicate, with public input, on bear management.

FWS claim: The agency says it looks forward to hearing from the public about delisting.

The reality: A national poll on behalf of the Humane Society of the United States and Wyoming Wildlife Advocates shows the following:

• 55% of voters oppose the FWS proposal to delist grizzly bears in the Greater Yellowstone Ecosystem. Only 26% support delisting.
• More than two-thirds of Americans oppose opening up a trophy hunting season on grizzly bears in Idaho, Montana and Wyoming. Only 20% support trophy hunting.
• 50 percent of hunters nationwide oppose delisting of grizzlies. Only 33 percent support it.
• 62 percent of hunters support a five-year moratorium on delisting. Just 33 percent do not support the moratorium.

FWS claim: The agency claims to look forward to consulting with Native American tribes about the delisting.

Tom Poor Bear

The reality: Fifty federally recognized tribes and the Assembly of First Nations sent formal objections to delisting and trophy hunting to Interior Secretary Sally Jewell prior to the FWS delisting proposal. Native News Online.Net also reported that the Oglala Sioux Tribe presented an eight-page resolution that details spiritual, scientific, political, and environmental objections to delisting.

Tom Poor Bear, Vice President of the Oglala Sioux Tribe, sees delisting as a way to allow the hunting of their sacred relative, the grizzly bear. “These so-called state game and fish agencies exist to serve a clientele that is 95% white, 95% male, and many of who kill for trophies. They are the vocal minority, and under the systems that exist through colonialism and patriarchy they have been able to dominate, lie and cheat their way into control.”

Tom Poor Bear concludes: “I warn you from experience gained in many fights with the US government and states, that this is not just about the grizzly bear, it is about the land the grizzly walks upon. If the grizzly is delisted, you will witness a two million acre land grab by energy and mining companies, livestock interests, and timber operations.”

Here’s the link to post your comment for FWS to read.

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