The Devil is in the Details: USFWS and Grizzly Bear Management “Blank Check of Death”
in a Post-Delisting World
By Tom Mazzarisi
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A lot of deserved attention has been directed at grizzly management plans that will subject the bears to trophy hunts after delisting. But, there is a more sinister threat that is being downplayed by the feds and state game and fish agencies. The devil is in the details. More grizzlies will be subject to lethal management actions. Don’t believe me? Let’s dive further into the legal jargon that is in the United States Fish and Wildlife Service (USFWS) and Wyoming Game and Fish Department (WFGD) management proposals for delisting.
“Therefore we do not consider management removals a threat to the GYE grizzly bear population now or into the future.”
The above quote comes from the USFWS proposed rule to delist the grizzly bear. The report points out, from 2002-2014, 311 grizzlies died directly at the hands of man. Of the 311, 135 grizzlies were “removed” from the Greater Yellowstone Ecosystem (GYE) through management actions, accounting for 43% of all known grizzly mortality over this 12-year period.
I don’t hold a PhD in grizzly biology, but the last I checked, 311 is a lot of bears. The USFWS bureaucrats want us to believe 135 of those dead bears will not threaten the grizzly’s future. This travesty has occurred while grizzlies have been afforded protection by the Endangered Species Act (ESA). With grizzly management about to be handed over to the states, please explain to me how management sanctioned killing of grizzlies will not threaten the bear’s future?
Rounding out the 311 dead grizzlies are 97 bears killed in “self-defense” by big game hunters, 22 known poaching incidents, 45 (management removals) for livestock conflict, 34 in accidents, and 23 by hunters unable to decipher the difference between grizzlies and black bears. For those that maybe unaware, one of these hunters is a WGFD bear management specialist. In a rush to illegally shoot a black bear from the road, he ended up illegally killing a grizzly. This person is surprisingly still employed by the WGFD. It doesn’t instill a whole lot of confidence in the process that transfers grizzly management over to a state that employs people who recklessly violate their own game and fish regulations.
If the USFWS is not going to consider management killing of grizzlies a threat, they better make sure they are accounting for all potential losses to the population. The experts can rewrite math equations to manipulate grizzly bear numbers, yet they are unable to estimate how many grizzlies are poached as a result of “shoot, shovel, and shut-up” practices. The USFWS delisting proposal claims a “statistical estimate of the number of unknown/unreported mortalities” is factored into the Total Mortality Rate Limit, but it does not offer much else in the way of specifics. It should be reasonable to ask the question. How many grizzlies are really being poached throughout the GYE? The delisting proposal identifies over 17 thousand square miles of suitable bear habitat; a massive area with little to no reliable law enforcement presence. 22 known poaching incidents over 12 years sounds low; less than 2 incidents per year. With so much overt, anti-predator rhetoric, it is highly likely there is a significant number of illegal killings that are not being factored into determining grizzly mortality limits; limits that will determine how many grizzlies can be killed by trophy hunters.
Now for a little background involving the bureaucratic boundaries that will determine the fate of grizzly bears. A Primary Conservation Area (PCA) was originally set up to monitor grizzly bear recovery by meeting and sustaining certain population thresholds involving grizzly sows with cubs. This area consists of Yellowstone National Park, only part of Grand Teton National Park, and sizeable portions of surrounding forest and wilderness areas. This has not been updated or revised to account for current grizzly bear distribution that has moved well beyond the invisible boundary of the PCA. Parameters for monitoring grizzlies in the PCA after delisting, in theory, should still fall in the bear’s favor. What happens to bears outside the PCA is cause for great alarm. Especially when looking at the USFWS’s assessment that management removals don’t threaten the future of grizzlies.
The area inside and outside of the PCA is now referred as the Demographic Management Area (DMA). The “boundaries” of the DMA include most of the remaining habitat currently occupied by grizzlies, but not all of it. Populations of grizzlies and a lot of suitable habitat still fall outside the DMA.
Grizzlies will be “allowed to expand into biologically suitable and socially acceptable areas.”
The USFWS and WGFD delisting proposals will only allow bears outside of the PCA “to expand into biologically suitable and socially acceptable areas.” What defines socially acceptable, especially in western states historically hostile to wild predators? The future of the grizzly is going to be relegated to the “back of the bus”.
“Significant consideration will be given to humans.”
Wyoming’s plan to manage grizzlies outside the PCA states, “significant consideration will be given to humans”. State game personnel responding to deal with “nuisance” bears will find it much easier to resolve the problem, lethally, to protect the interests of outfitters, ranchers, loggers, and oil and gas companies. Interests that have powerful influence over the decision making body of the Wyoming Game and Fish Commission.
Grizzlies outside of the PCA will take a backseat to people that will never “socially accept” sharing public lands with wild predators. In layman terms, a “one strike and you’re out” policy will result in greater numbers of bears being killed in management actions. This “blank check of death” most certainly will equate to the demise of grizzlies that unfortunately find themselves eking out a living beyond the boundary of the DMA. These bears not only will be victims of swift and lethal punishment by state game officials, trophy hunting will go relatively unchecked since quotas outside the DMA will not be subject to the mortality limits that will be deducted from state hunting quotas within the DMA.
Even the USFWS recognizes the states will look to hammer bears outside of the DMA. “Because it is also reasonable to expect that GYE grizzly bears may not be managed as conservatively outside the DMA boundaries where they could be exposed to more intensive hunting and management pressure, we considered these peripheral areas where known grizzly bear range extends outside the DMA boundaries to warrant further consideration to determine if they are a significant portion of this population's range.”
Why not decipher this now, before delisting?
Of specific concern, out of the 45 grizzlies killed for livestock predations, 44 of these management actions occurred outside the PCA. This number will increase, possibly exponentially, once the grizzly is delisted. In looking at the illustrations within the delisting proposal, there is a set of maps with black dots depicting the locations of known, human-caused mortality. From the onset of grizzlies being listed as endangered in 1975, the amount of these dots have vastly increased, especially outside of the PCA to the east, south and southeast. Yes, there are more bears, but there are exponentially more people living within and visiting grizzly country. As alluded to earlier, these human-caused mortalities have occurred while the bear enjoyed protection as an endangered species. How will having less protections improve the outlook for grizzly bears, especially with western states’ willingness to cave to the special interests responsible for the degradation of our public lands and decimation of our wildlife?
"Grizzlies displaying natural aggression may be removed from the population."
Natural aggression is defined as a grizzly acting in the defense of itself, offspring, or food source. The very essence of grizzly evolution selected this trait of natural aggression to ensure survival in a prehistoric landscape dominated by other large predators. In a world with more people crowding into grizzly habitat, bears are dying for simply trying to defend themselves. From 2002-2014, 97 bears died by resorting to their natural tendency to defend themselves from two-legged predators stalking silently through the woods intent on killing big game. The Grizzly Bear Coordinator himself has repeatedly given the green light to destroy bears exhibiting only natural aggression. If his management decisions were common place under the veil of the ESA, the situation will worsen under state management.
Since the USFWS does not consider management action removals to be a threat to the future of the grizzly, the states have no reason to give bears a second chance. The bear-hating politicians and citizens of Wyoming, Montana, and Idaho will continue to justify their lack of “social acceptance” through ignorance, fear, and hate. Hunters may be chomping at the bit for their chance to kill GYE grizzly bears, but they are going to have to contend with the state game agencies for their chance at killing Ursus arctos horribilis.