August 1, 2020

To Governor Bullock and Montana Grizzly Bear Advisory Council:

Re: Future of Grizzly Bears in Montana

Dear Governor Bullock and Montana Grizzly Bear Advisory Council: 

The Gallatin Wildlife Association (GWA) would like to thank each individual council member and the council itself for the time and effort all have chosen to provide the state of Montana in discussing the future management of grizzly bears. GWA has participated in the public commenting process multiple times in both written and oral form prior to these comments of today and would like these comments to be considered as an addendum to those. We would like to take this opportunity to comment on what is known as the Consolidated Draft Recommendations as presented on the Governor’s Grizzly Bear Advisory Council (GBAC) website dated July 28, 2020. 

GWA is a nonprofit volunteer wildlife conservation organization representing hunters, anglers and other wildlife advocates in Southwest Montana and elsewhere. Our mission is to protect habitat and conserve fish and wildlife. GWA supports sustainable management of fish and wildlife populations through fair chase public hunting and fishing opportunities that will ensure these traditions are passed on for future generations to enjoy.

Guiding Principles:

One goal GWA has had from the beginning is for the GBAC to provide thoughtful consideration to and the implementation of mechanisms for successful connectivity between the six (6) existing northwestern ecosystems in the lower United States having a population of grizzly bears.1 Four (4) of these six ecosystems either border or exist in the state of Montana, making Montana critical to the success of the species existence. The Vision as presented by the GBAC establishes fifteen Guiding Principles, a set of goals and rationale for the Councils existence. Connectivity is incorporated into one of those Guiding Principles. Guiding Principle 13 specifically states the following:

“Connectivity is important to the long term sustainability, persistence, and resiliency of grizzly bears. Connectivity areas will exist in diverse social and environmental settings. Not all of these settings are conducive to permanent habitation, but should be managed to promote genetic and demographic connectivity in biologically suitable and acceptable habitat, being mindful that biologically suitable does not always mean appropriate.”

This statement recognizes that connectivity needs to be considered in the long-term management plan for the grizzly bear. What we might change in that statement, is to substitute the word “critical” for “important”. We feel connectivity cannot be given just lip service, but needs to be included in word and deed. Guiding Principle 12 feeds into that concept of connectivity and is exactly what is needed to secure those lanes for corridor development. For it says:

“The Council recognizes the importance of large tracts of remote secure habitat. Sustaining and improving habitat security, managing road densities, and identifying and protecting natural food resources and other needs will contribute to long term survival and resiliency of grizzly bears.”

We applaud Principle 12 for being contained within the Vision of the GBAC.

However, with the good, there always seems to be the bad. GWA has great concern over Guiding Principle 9, for it states the following:

“The council supports and understands that as expansion of grizzly bears occurs East of the Rocky Mountain Front and North of Interstate 90, that do not contribute to connectivity of recovery zones, dictates special attention, management and allocation of resources and those areas needs to be clearly articulated in MTFWP management plans.”

This statement seems to make the assumption that connectivity routes and habitats which exist east of the Rocky Mountain Front and north of Interstate 90 are not considered important or worthy to the overall connectivity of the bear. If this assumption is correct, GWA strongly disagrees. For if, this assumption is correct, it is contrary to the science as we know it. GWA has long been a wildlife advocacy organization in support of connectivity among several recognized, scientific corridors northward of the Gallatin and Absaroka Front. This statement in the proposed recommendations either needs to be corrected or restated to allow for the recognition of grizzly bear corridors to the north and east of the Continental Divide. 

Besides, Recommendation 18 of Section 1, under the partition entitled “Grizzly Bear Distribution, Relocation, and Connectivity” states the following:

“Allow natural movement to new areas between all four identified recovery zones in Montana.”

This statement alone seems to contradict the assumption of Guiding Principle 9. Both texts are in “red” which apparently means “those principles have yet to be discussed or decided upon”. We question and disapprove of the phrasing of Guiding Principle 9, but wholly support Recommendation 18 of Section 1. Connectivity and corridor protection, whether it be through management or procurement of existing or new habitat must be contained as a guiding principle.

Before we move on, GWA also wants to recognize Guiding Principles 7 and 8 stated here.

7. The effects of climate change should be considered when making decisions about grizzly bears.

8. The best available science should inform decisions in all aspects of grizzly bear management and conservation.

We want to applaud the recognition and inclusion of these two principles as they should provide a just result for future generations. Science needs to guide the management and the acknowledgement of climate change should help bring the realization of a changing world to bare. There needs to be an adherence to both.

Section 1:

Section 1 contains 30 recommendations subdivided over three (3) categories, which the document describes, as topics reached during deliberations. Even though, as previously stated, those in red have “yet to be discussed or decided upon”. GWA is not quite sure how to take this discrepancy, if indeed there is one.

GWA appreciates those recommendations listed under the categories of Education and Outreach and Conflict Prevention. There needs to be a renewed interest and perseverance in both so the public (in state and out) can have the understanding and knowledge of bear behavior and ecology. Mankind needs to know how to co-exist with this iconic species. One of the recommendations that GWA specifically wants to bring attention to is found in Section 1, recommendation 16 entitled Public and State Land, I, 4. For it states:

“Recreation use on our public lands is rapidly increasing. Montana Fish, Wildlife and Parks (MFWP) should coordinate with public land managers to develop plans to address the impacts from recreational use and prevent conflicts between grizzly bears and people on the landscape. This should include a mix of actionable items (i.e. temporary trail closures, special use permits) and consistent and comprehensive outreach and education.”

We appreciate the acknowledgement that recreation and grizzly bear activity has the potential of conflict. The U.S. Forest Service needs to recognize this fact in their 2020 Final Plan. Land-management and wildlife management agencies need to realize that it does not make sense to intentionally overlay activities of one over the other. Grizzly bears and other species require space and lack of noise from man-made activities in order to feel protected in their natural habitat.

Recommendations 27-29:

27. “To inform its grizzly management plan, the Council recommends that FWP and all relevant agencies clearly define the landscapes in between the four recovery zones in Montana that are important for connectivity and the long term sustainability of the grizzly bear, as well as those areas that are not a priority to grizzly bear connectivity.

28. If the expansion of grizzly bears does not contribute to connectivity of recovery zones, it dictates special attention, management, and allocation of resources, and those areas need to be clearly articulated in MTFWP management plans. OR The council recognizes that as expansion occurs outside of the four identified recovery zones located in Montana and landscapes in-between, Montana Fish, Wildlife and Parks will have to balance expansion with the need to prioritize resources.

29. FWP should, in consultation with relevant entities, identify areas that are not “critical to the long-term vitality” of grizzly bears and prioritize relocation or removal of management bears in these areas.”

GWA has a philosophical problem with the intent of these recommendations. It assumes that “man knows best”, that he is the “best purveyor of what is right and wrong”. We should know and recognize by now that is not the case when it comes to environmental norms. We disagree with that assumption. It is not the place for MFWP to determine landscapes where grizzly bears may or may not exist, within reason of course. We do not believe that manufactured zones or man-made delineations of landscape should rule over the connectivity options of the grizzly bear. Recommendation 29 is of particular concern.

“FWP should, in consultation with relevant entities, identify areas that are not “critical to the long-term vitality” of grizzly bears”

GWA suggests that we let the bear determine which locations and under which type of habitat will be best suited for corridor placement. It is the obligation of MFWP to provide and promote the habitat containing those necessary food and security protections when science and the bear makes those determinations. This of course, necessitates an increased role in observation on MFWP’s part.

Section 2: Hunting

Section 2 leaves open the possibility of hunting as it appears the Council has not reached an agreement on how to address the issue. As Section 2 states, they did not reach consensus. GWA does not support the commercial hunting of grizzly bears, trophy or otherwise as we do not see the hunting of grizzly bears being warranted. Many of our prior comments have already addressed this issue and those comments still stand. Hunting at this point in time seems contradictory to the overall goal of having bears reach full connectivity. Presently, bears reaching outward to their full expansion of habitat would be the ones most likely shot as they try to connect northward from the Greater Yellowstone Ecosystem.

According to an article in the Missoulian newspaper2 entitled “What is killing Montana’s grizzly bears? Humans and bullets, biologists say”, there was this quote dated December 18, 2019.

“The IGBC finally undertook the analysis after last year’s spike in grizzly bear deaths in both the Greater Yellowstone and the Northern Continental Divide ecosystems. Last year, U.S. Fish and Wildlife Service grizzly bear coordinator Hillary Cooley told the committee that conflict with humans is the main cause of grizzly bear mortality, accounting for 85% of known deaths in the GYE and 91% in the NCDE.”

The mortality of grizzly bears is an obvious reason as to why these iconic bears have a hard time reaching connectivity, but why should we make it worse by allowing hunting? The question, as the article discusses, is why is there such a high rate of mortality? The answer to that question is multifold. Increased population growth into the wildland-urban interface causes an increase in those grizzly bear/human conflicts. But whether those deaths be from accidental shootings, vehicle/animal collisions, or the killing of bears from domestic animal conflicts or man/animal conflicts, the result is the same; the mortality is taking an important toll in preventing grizzlies from reaching their full potential of habitat recollection. Habitat fragmentation or the loss thereof, or the loss of food supply whether that be from climate change or other reasons are all driving the bear into searching for new areas of suitable habitat. Hunting would only decimate that population, not enhance it.

In Summation:

As we said above, we would like these comments to be considered in addition to those already submitted. For more specifics on our rationale on hunting and other issues, we would refer you to our previous written comments dated May 7, 2020 and our oral comments provided to the Council on July 23, 2020. GWA’s position all along has been to see implementation of actions and policies that will actually produce the results desired. This will not be accomplished unless there is an entity that will possess the desire, authority and public support to see it through. The GGBAC appears to be on the right track through the establishment of their guiding principles and recommendations to help protect the future of grizzly bears. 

But there needs to be some adjustments made. MFWP cannot be allowed to run roughshod over the goals and visions of the citizens of Montana in order to provide traditional hunts of grizzlies. The grizzly bear is not a traditional species; it is an iconic species, one that deserves special protection and one that has spiritual meaning to Native and non-Native residents alike.

We fear that MFWP will resort to traditional management practices; managing a species by specific zones or areas interrupting the consistency needed, failing to see the grander picture. We disapprove of a management practice of overseeing species based upon an imaginary line or man-made boundary. There is something to be said of having a species determine their own habitability. 

Consequently, the recommendations to the Governor’s office cannot just write off certain areas of the state that perhaps man or MFWP would like. Connectivity must include those areas east of the Rocky Mountain Front and north of I-90 if the science and the bear decide it is a workable and natural solution. The science models currently suggest their availability and importance.

Finally, we have said all along that the problem with grizzly bears is not the bear, but of our understanding and management of the bear. It is a problem multifold, of our own making. Habitat fragmentation, climate change, loss of food supply and encroachment of man into their home causing man-made/animal conflicts have taken their toll on the grizzly bear. This document seems to address these specific concerns albeit indirectly at times or in unspecific detail. But the expected results, hopefully will be the same. 

We want to thank the Governor and the Council for providing the opportunity for public comment. We will be watching to see how this process unfolds. As the Executive Order states, the Advisory Council is not a regulatory body, its recommendations are advisory only. This is one way that MFWP can regain trust of the Montana citizenry, by fulfilling the science and conservation recommendations of the Governor’s Grizzly Bear Advisory Council. This is why it is important to get these recommendations right.

Sincerely,

Clinton Nagel, President

Gallatin Wildlife Association

The Hunting of Grizzly Bears in Montana 

May 7, 2020

Montana Grizzly Bear Advisory Council Facilitators:

Shawn Johnson

Heather Stokes

Re: Hunting Grizzly Bears in Montana

Dear Montana Grizzly Bear Advisory Council:

The Gallatin Wildlife Association (GWA) would like to thank each individual council member and the council itself for the time and effort all of you chose to provide the state of Montana in discussing the future management of grizzly bears. It has come to our attention that the council has been discussing the possibility of hunting (trophy hunting no less) of grizzly bears on public land. We would like to take this opportunity to comment on this discussion as currently being undertaken by the Governor’s Grizzly Bear Advisory Council (GBAC).

GWA is a nonprofit volunteer wildlife conservation organization representing hunters, anglers and other wildlife advocates in Southwest Montana and elsewhere. Our mission is to protect habitat and conserve fish and wildlife. GWA supports sustainable management of fish and wildlife populations through fair chase public hunting and fishing opportunities that will ensure these traditions are passed on for future generations to enjoy. We as a wildlife organization do not see the hunting of grizzly bears being warranted due to the several reasons that we have detailed below.

Conflicting Aspirations:

As we begin, we note up front that there seems to be a discrepancy within the goals of Montana Fish, Wildlife and Parks (MFWP) on the overall management of grizzly bears. In the 2013 Grizzly Bear Management Plan for Southwest Montana1, MFWP released their Final Programmatic Environmental Impact Statement (FPEIS). On page 6 under MFWP Goals for the Grizzly Bears, it mentions the Governors Roundtable’s continued support of Primary Conservation Areas (PCA). It states the following:

“The group also recommended that the states of Wyoming, Idaho and Montana develop management plans for the areas outside the PCA to:

2. Support expansion of grizzly bears beyond the PCA in areas that are biologically suitable and socially acceptable,

3. Manage the grizzly bear as a game animal including allowing regulated hunting when and where appropriate.”

We believe Goals 2 and 3 conflict with each other. If you want grizzly bears to expand beyond PCAs into areas that are biologically acceptable, how can you manage the bear as a game animal and allow regulated hunting when and where appropriate? Those bears that are more likely to expand beyond PCAs are also the ones more likely to be shot because they are outside the protection of PCAs. GWA believes this policy is inconsistent to the overall goals it says it wants to achieve. If MFWP is serious about supporting the expansion of grizzly bears outside of PCAs, the goal of allowing the bear to expand must be achieved first, prior to the hunting of the species.

Goal number two above in MFWP document also matches what is found in the 2016 Conservation Strategy for the Grizzly Bear in the Greater Yellowstone Ecosystem2. The first two visions listed in that strategy are summarized as stated.

• The PCA will be a secure area for grizzly bears, with population and habitat conditions maintained to ensure a recovered population is maintained for the foreseeable future and to allow bears to continue to expand outside the PCA

• Outside of the PCA, grizzly bears will be allowed to expand into biologically suitable and socially acceptable areas.

The goals of these two documents support one another in that they are proposing to allow grizzly bears to expand outside PCAs. On the other hand, they also conflict each other by goal 3 in the FPEIS and the last goal in the Conservation Strategy of 2016 where it states on page 3 the following:   

“Manage grizzly bears as a game animal; including allowing regulated hunting when and where appropriate.”

Before we move on, GWA would like to preempt the argument that this hunting goal will only be done in those areas where the number of bears are plentiful and so are the conflicts. The argument continues on with the thought this act would not affect the population. We counter that by saying, where’s the science proving that point? This sounds more like wishful thinking than anything else. Bears are generally solitary animals once arriving at adulthood and how do we know their wandering wouldn’t venture into areas outside PCAs?

Again, by managing the bear as a game animal before the species has reclaimed any of its original habitat or regained any connectivity is self-defeating. It will guarantee this iconic species will never achieve connectivity, will never achieve reclamation of its original territory outside of PCAs, and will never achieve social tolerance which is another goal of the MFWP and the GBAC. This inconsistency highlights a weakness in the strategy and the GBAC should not be giving credence to it.

Misguided Justification:

Back to the FPEIS, the document as stated on page 6 lists goals which it proclaims could best be achieved if they address “human safety, nuisance bear management, livestock conflicts, property damage.” GWA does not see the scientific evidence that the open-hunting of grizzly bears would help address or reduce any one of these human-grizzly conflicts. Where is the evidence that supports this summation? What ensures that open-hunting of grizzly bears would actually reduce the population of problem bears? For in this scenario, the bears that would be hunted would rarely be the same ones causing conflicts. If nothing else, GWA believes that open hunting of bears would actually increase the human-grizzly conflict potential, posing a greater risk to human safety. We urge that the GBAC do not justify the necessity of hunting as a way to curtail bad bear behavior.

All of this has been said because there is this illogic and convoluted thought out there in the expanse of the universe that hunting will make bears learn to be afraid of humans. Before you devote too much thought into that idea, we should all know that bears are solitary animals. If you kill it, how is it going to learn? There was an interesting article in the Missoulian several years back, Nov. 30, 2017 to be exact, entitled “Dead bears don’t learn anything – Biologists balk at notion hunting makes bears wary.” This article by Perry Backus3 quotes Kim Annis, a MFWP grizzly bear management specialist from Libby, stating the following:

"If the argument is that hunting bears will teach them to be afraid of humans, I don't understand how that would play out," Annis said. "Bears are solitary animals. If someone kills one, it's dead. It would have to stay alive to actually learn something."

Think about this for a moment. There is not so much science in this, although if there is, it is perhaps the most basic science lesson of all. You have to be alive to learn. But it is common sense.

Now after having said that, we can think of scenarios where bears can learn people are a hazard to their health. Bears can learn to shy away from us. Bears are intelligent, yet solitary beings. But those scenarios would be the exception rather than the rule. We should not manage any wildlife species based upon exceptions. Perhaps a better way to state this is: it is very improbable that bears who are hunted can learn to avoid humans. 

We feel that the Council would do better by spending their time on issues that promote safe habitat for grizzlies because bears are going to remain inhabitants on our public land for generations to come. The council would do better by providing information on how the public can better exist in harmony with this species. In fact, on page 6 of the FPEIS, there is the statement that to achieve those listed goals, it’s necessary that they address the issues of “habitat and restrictions on human use of bear habitat”. We should be talking about how man can conduct himself on their land. We are the intruders in that scenario.

Establish Connectivity:

In Montana Fish, Wildlife and Parks’ GRIZZLY BEAR Management Plan for Southwestern Montana 2013 FINAL PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT1, it lays out these preferred management approaches under the title of Future Distribution on page 41 and 42:

• “Continue to monitor grizzly bear expansion from historically occupied areas along with changes in population numbers.

• Continue to address grizzly/human conflicts in areas outside the core recovery area in a manner that considers overall grizzly conservation as well as human safety and social tolerance.

• Continue to work with Idaho, Wyoming, and the Interagency Grizzly Bear Committee to address the issue of linkage between grizzly recovery areas and follow the goal set forth in the IGBC work plan to promote linkage between the GYA and the NCDE grizzly populations.

• Implement habitat programs that provide for wildlife needs to include working with the DOT to address issues of wildlife movement across roads (especially Interstates 90 and 15; and Highways 287, 191, 89, and 20).”

Then on page 44, there is this statement:

“Management of non-conflict grizzly bears in areas between the NCDE management area and the DMA of the GYA (Figure 7) will be compatible with maintaining some grizzly occupancy. Maintaining presence of non-conflict grizzly bears in areas between the NCDE management area and the demographic monitoring area of the GYA, such as the Tobacco Root and Highland Mountains, would likely facilitate periodic grizzly movements between the NCDE and GYA.”

Here MFWP is suggesting locations that would actually enhance grizzly bear connectivity. Yet we are suspicious. We’re concerned that if a bear did actually appear on these lands, how likely is it that these bears would be shot? GWA assumes this likelihood would be greater than any other. The rationale would be someone felt threatened or that these bears were outside their normal range or habitat. In other words, MFWP is saying the right thing, but can we as a people do the right thing. GBAC could spend more time in educating the public about what to expect as grizzlies explore lands outside of what has been their PCA.

GWA would now like to refer the GBAC to a MFWP document, 2019 Conservation Strategy for the Grizzly Bear in the Northern Continental Divide Ecosystem4. On page 29, there is this statement, perhaps the most optimistic view yet about grizzly bears establishing that genetic connection between the Greater Yellowstone Ecosystem and the Northern Continental Divide Ecosystem:

“Based on analyses of movements made by NCDE and GYE bears fitted with GPS collars, Peck et al. (2017) delineated potential movement paths that would provide the opportunity for male-mediated gene flow between the NCDE and GYE. Model predictions indicated that male grizzly bear movement between the ecosystems could involve a variety of routes, and verified observations of grizzly bears outside occupied range supported this finding. Peck et al. (2017) reported that the closest proximity between the estimated occupied range for these two populations was about 68 mi in 2014 and similar analysis indicated the distance decreased to 56 mi by 2016. This distance is within the range of maximum dispersal distances (42–109 mi) documented for populations in the Rocky Mountain region (Blanchard and Knight 1991, McLellan and Hovey 2001, Proctor et al. 2004), indicating that male dispersal between the populations is plausible. Human-caused mortality is a limiting factor for nearly all grizzly bear populations in the lower-48 States.”

GWA would like the GBAC to pay attention to that last sentence above. Grizzly bear connectivity is almost achieved, even without much if any assistance by man. Just think, a little effort by man in setting the right policy could go a long way to help reach that goal. Yet that last sentence comes back to haunt all of this potential:

“Human-caused mortality is a limiting factor for nearly all grizzly bear populations in the lower-48 States.”

So why would we want to jeopardize a goal that MFWP and nearly all conservation groups have been targeting for years. We may have decades to go before true connectivity can be reached, but if we allow hunting by any dimension, we fear that goal of establishing corridor connection could be lost for several future generations.

In Conclusion:

To properly manage the future of grizzly bear habitat, population, and distribution, state and federal agencies need to mitigate habitat loss, habitat fragmentation, climate change, loss of food sources, and to encourage and facilitate connectivity. Very little of this is being done. What progress has been made in the role of increased connectivity, very little of that can be traced back to the actions of man. Hunting, trophy or otherwise, will just detract from that progress and further hinder the goal of having this iconic species from re‑establishing residency on their once historic range. Until that is done, grizzlies will be on the fringe of circulating the drain of extinction.

Dr. Jim Bailey5, a fellow board member of GWA, states this on his webpage:

“Montana (FWP 2013:49) asserts it is a long-term goal to allow bears in southwest and northwest Montana to reconnect through maintenance of “non-conflict” grizzly bears. However, this plan fails to note that hunting, including of non-conflict bears, will be contrary to achieving this goal.”

This is the belief of GWA as well. We have a hard time understanding how hunting can facilitate grizzly bear expansion, social tolerance, ensure a recovered population, or reach the goal of grizzly bear connectivity. Science does not draw that conclusion. Our common sense does not draw that conclusion, and our morality prevents us from justifying that conclusion.

Thank you for accepting our comments and giving us an opportunity to give voice on behalf of this great bear.

Sincerely,

Clinton Nagel, President

Gallatin Wildlife Association

Cited References:

1.Montana Department of Fish, Wildlife and Parks, 2013 Grizzly Bear Management Plan for Southwest Montana, Final Programmatic Environmental Impact Statement, 2013, page 6, 41, 42, 44.

2.2016 Conservation Strategy for the Grizzly Bear in the Greater Yellowstone Ecosystem, 2016, page 3.

3.Backus, Perry, Dead bears don’t learn anything – Biologists balk at notion hunting makes bears wary, The Missoulian, Nov. 30, 2017.

https://missoulian.com/news/local/dead-bears-don-t-learn-anything-biologists-balk-at-notion/article_930fd1e3-31ad-571c-ad30-78d11bcd3b73.html

4.Montana Department of Fish, Wildlife and Parks, 2019 Conservation Strategy for the Grizzly Bear in the Northern Continental Divide Ecosystem, 2019, page 29.

5.Dr. Jim Bailey, 

https://www.jamesabailey.com/endangered%20genes/Genetic%20Adequacy%20of%20Greater%20Yellowstone%20Grizzly%20Bears.pdf