Montana Grayling Final Push for ESA Listing

The U.S. Fish and Wildlife Service is taking comments on the proposed listing of the Distinct Population Segment (DPS) of Arctic grayling (Thymallus arcticus) under the Endangered Species Act (ESA). Following the status review, the Service will either publish a proposed rule to protect the Arctic grayling under the ESA, or a withdrawal from candidate status in the Federal Register by Sept. 30, 2014. This may be the final step in the long drawn out effort to provide federal protection for this iconic fish.

The plight of the grayling, like many native fish in the West is tied to livestock production. Directly and indirectly livestock production is the major factor in grayling decline. As a result of the political clout of the ranching industry, the agencies responsible for grayling recovery including the Montana Dept of Fish, Wildlife and Parks (MDFWP) as well as the US Fish and Wildlife Service (FWS) have had to operate with one hand tied behind their backs. Their walking orders are to do nothing that would antagonize the ranchers. The machinations that have befallen the grayling are a clear example of how political considerations trump the biological criteria that are supposed to guide ESA decisions.


In 1990 I was clandestinely contacted by several Montana Dept. Fish, Wildlife and Parks fishery biologists who were concerned that their department was not aggressively addressing the threats to the grayling. They asked me to seek federal protection on behalf of the grayling under the ESA.

In 1991 I and the Biodiversity Legal Foundation filed a petition to list the grayling. It was our collective hope that ESA listing would provide the legal muscle to implement changes in habitat management to the benefit of the grayling that MDFWP, the US Forest Service, US Fish and Wildlife Service and other agencies were unable or unwilling to do without the club of the ESA hanging over their heads.

By 1994 the Fish and Wildlife Service (FWS) had determined that the grayling was indeed headed for extinction and warranted protection under the ESA. However, listing was precluded according to the Service because other species were in greater peril—a common ploy to avoid listing controversial species.

Numerous attempts to gain listing since 1991 have failed as a result of political interference from Congressional members and the Bush administration, opposition from the Montana Dept. of Fish, Wildlife and Parks as well as the co-opting of environmental groups by ranching interests. Groups like Montana Trout Unlimited (TU) have actively fought against listing. Instead TU and other organizations have sought to cozy up to the ranchers and advocated modest modifications in livestock management instead of actively seeking ESA protection.


The effort to list the grayling and provide the federal protection it deserves under the ESA is a good example of Machiavellian logic and deceit.  During the next decade, grayling numbers continued to plummet, but listing was avoided by numerous political machinations. After the initial decision by the FWS to list the grayling as a candidate but with no further movement I and others made repeated follow up requests to the Service to upgrade the grayling’s status.

In March of 2004 the FWS finally bumped the grayling priority from a level nine to a level three, the highest priority level for a candidate listing. In May 2004, I and others, petitioned for emergency listing of the grayling to try to move it from candidate to protected status.  After nearly three years of delay, the Fish and Wildlife Service responded to our petition in April of 2007. Instead of listing the grayling, the FWS reversed itself due to interference from the Bush administration, and determined the grayling no longer deserved special Distinct Population Status at all and removed it from candidate status. This decision was legally challenged by the Center for Biological Diversity and others.

In 2009, after the election of Barack Obama, the FWS again reversed itself, and remanded the 2007 decision, and conducted a new review of the Distinct Population Status (DPS). In September of 2010 the FWS concluded that the grayling was indeed listable under the DPS. It was once again given a priority level three candidate status where it remains today.


Whether listing in 1991 when I first petitioned for ESA protection would have reversed the decline of grayling can be debated, but collaboration with ranchers has not produced the desired recovery of the fish. During this intervening period, Missouri River grayling populations have declined by an average of 7 percent a year and now number less than half of their 1990 numbers. In many remaining waters, the effective breeding population of fish numbers in the low hundreds—and grayling are in essence already functionally extinct. For instance, in the 113 miles of occupied grayling habitat in the Big Hole River, it was estimated by the early 2000s there were around 200 adult fish—or little more than one grayling per river mile.  In 2012 researchers found an average of three grayling of 1 year age per mile in a 19 mile stretch that was surveyed.  Whether grayling can be recovered in most of the remaining occupied habitat at this point is questionable, but certainly worth trying.


Arctic Grayling are found in cold clear waters across the Boreal Ecoregion in both North America and Eurasia. The Missouri River Arctic Grayling are an ice age relict and considered a genetically distinct population. The ancestral Missouri River once flowed north to Hudson Bay and the predecessors of today’s fish were isolated in the Upper Missouri when Continental Glaciers blocked the river’s northward flow and shifted its waters east and eventually to the Mississippi drainage and ultimately the Gulf of Mexico.

A beautiful fish with a large dorsal fin and shimmering purple sides, the species reaches its southern limits in the colder waters of Montana’s Upper Missouri River drainage. Lewis and Clark were the first to record the species. At that time, grayling were found in the Sun, Smith, Gallatin, Madison, Red Rock, Beaverhead, Jefferson, and Big Hole rivers. (There are unconfirmed reports that grayling may be native to the St. Mary’s River near Glacier National Park). The next closest population of grayling is found hundreds of miles further north in the Pembina River west of Edmonton, Alberta.

By 1990 when I became involved in grayling issues, the fish was restricted to the Big Hole River drainage, Upper Red Rock River drainage, and a small portion of the Madison River near Ennis, Montana. Natural populations of grayling were also found in a number of lakes in these drainages, including Miner Lakes and Mussigbrod Lake in the Big Hole drainage and Upper Red Rock Lakes in the same named river drainage.  (Note that Arctic Grayling have been stocked in lakes outside of its historic range so one may find them in various other water bodies). The last significant refuge for Missouri River grayling is the Big Hole River where the fish are found in approximately 113 miles of the main stem and 45 miles of tributaries between Glen and Jackson, Montana. Today Arctic Grayling only occupy about 4-5 percent of their historic range in the Upper Missouri River.

The FWS estimates that, with the exception of the fish in Mussigbrod Lake, the remaining strongholds for grayling including the Big Hole River have a 13-55% change of extinction in the next 30 years simply due to random stochastic events.


The major factor in grayling decline can be summarized in one word—cows. Livestock production has multiple negative effects on grayling.

The biggest impact is dewatering of rivers for hay irrigation. Dewatering of the Big Hole River in particular has been exacerbated by a number of drought years. In June the river often runs at over 2000 CFS, but in summer during irrigation season, it can be drawn down to 20 CFS, with some portions of the river dried up completely.

Water draw downs affects grayling in several ways. First, reduction in water flows forces all fish into smaller pools of habitat, increasing the competition among grayling as well as other fish for food and security.

Reduction in water flow creates shallower river channels that heat up more in summer sun, with in-stream temperatures often climbing to lethal levels during extended hot periods. Indeed, in most summers, the Big Hole River exceeds Clean Water Act standards for temperatures.  For instance in during the summer of 2012, ten out of eleven temperature monitoring stations in the river exceeded 70 degrees, the thermal threshold for salmonid species (like the grayling).

Run off water from irrigated fields that is not lost to evaporation also tends to be warmer, and sometimes full of pollutants such as manure and fertilizers.

Irrigation barriers and diversions in streams (small dams designed to shift flow into irrigation channels) also act as barriers to upstream migration of grayling that might otherwise seek out colder headwater streams.

Dewatering for irrigation often completely dries up grayling spawning streams, killing any eggs or fry that are in them. Entire recruitment for a season can be lost.

Young grayling that are hatched in tributary streams and move downstream during the summer months can wind up in irrigation ditches instead of the main river. At the end of the season when irrigation gates are closed, grayling are trapped in irrigation ditches that subsequently dewatered killing all fish in them.

Loss of adequate flows is probably the biggest factor in grayling demise. But cattle also impact grayling habitat by trampling and compaction the wet meadows, headwater springs, and other natural sponges that are a source for up to half of the late season flows in these rivers.

Trampling by cattle of the riparian streamside vegetation also harms grayling. Breakage of banks by cattle hooves contributes to widening of stream channels (and subsequently less pool habitat and higher water temperatures) with fewer deep pools which is the ideal grayling habitat.  Cattle browsing on willows, as well as changes in hydrology due to livestock impacts, have significantly reduced streamside vegetation, eliminating shade which contributes to higher and often lethal temperatures for grayling. Trampling of stream banks by cattle also contributes to higher erosion and sedimentation in streams.  Even non-grazed areas are impacted. For instance, portions of Red Rock Lakes National Wildlife Refuge that are closed to livestock grazing, still suffer from sedimentation flowing into the refuge from upstream livestock grazing damage.

This sedimentation flow resulting from accelerated erosion not only smothers grayling spawning beds,  but fills in and reduces the deep pools that are a necessary component of grayling over-winter habitat. For instance, due to livestock induced sedimentation, the average depth of Upper Red Rock Lake in Red Rock Lakes NWR has shrunk from 25 feet to 16 feet in the last century.

Unlike northern grayling populations that co-evolved with top predatory fish like bull trout, lake trout, and northern pike, throughout its Missouri River range, the grayling has lived without an apex predator. Except for small grayling populations that co-existed with lake trout in Miner Lake in the Big Hole drainage, and Elk Lake in the Red Rock drainage, grayling did not co-exist with any top predatory fish.

Although the evidence is unclear, it is assumed that competition with non-native trout like rainbow trout, brown trout and brook trout have impacted grayling populations.  Circumstantial evidence suggests non-native fish do limit grayling since nearly all attempts to restore grayling in streams with competing non-natives have thus far been unsuccessful (though there is limited evidence for grayling recruitment in the Ruby River). Competition that may exist with non-native fish like brook trout is exacerbated by irrigation dewatering and the shrinkage of habitat associated with water draw downs. So once again, livestock production may be culpable for grayling decline induced by non-native fish competition.


Another suspected cause of the grayling decline in the Upper Missouri River system is the loss of migratory function. Many grayling populations migrate long distances between spawning habitat and over winter sites. I once witnessed a grayling migration in the Kobuk River in Alaska where thousands of fish stream past me as they were descending the river as it froze to overwinter in deep holes in the lower river.  Similar migrations once likely occurred in the Upper Missouri River. However, numerous dams have been built on these rivers, including on the Big Hole, Beaverhead, Madison, Ruby, Jefferson, Sun, and Red Rock. For instance, the Ennis Dam on the Madison River is known to block grayling migrations, and any fish that fall below the dam cannot return back upstream and are lost from the population.  Nearly all of these dams were built for irrigation water storage—thus yet another impact of livestock production upon grayling survival.


Historic effective breeding population of grayling in the Upper Missouri system was an order of magnitude of 10-100 times greater than today. Due to the fragmented nature of grayling populations, combined with current small population numbers, random genetic drift may jeopardize the future of the fish as maladaptive alleles are spread throughout the remaining fish populations. At least in the short term, reestablishing grayling populations across entire river drainages like the Big Hole and Red Rock River seems highly unlikely, which makes modification of grazing practices and livestock operations even more critical to the fish’s survival.


The wild card in the grayling’s future is climate change. Regional temperatures are predicted to rise an average of up to 10 degrees in the next century. Warming temperatures could prove even more lethal to grayling populations if water flows are not substantially improved. Earlier spring run-off could also influence grayling by reducing late season flows.


MDFWP has spent many man hours studying and attempting to restore grayling with limited success—manly because they are not permitted to address the fundamental issue of livestock production impacts in a meaningful way. Nevertheless, the agency has attempted to restore grayling in several rivers including the Sun River upstream from Gibson Reservoir and in the Upper Ruby River near Twin Bridges, Montana. The Ruby River efforts appear to be paying off, with reproduction reported for four years in a row.

However, all these efforts seem to be motivated more from a desire to preclude listing than to recover the grayling.

One of the ways that the FWS has avoided listing of the grayling so far (even though it determined as early as 1994 that the species listing was warranted) was by signing off in 2006 on a Candidate Conservation Agreement with Assurances (CCAA). The CCAA was implemented by Montana Dept. of Fish, Wildlife and Parks in an attempt to preclude listing of the fish. Ranchers, who agreed to voluntarily implement habitat improvement mechanisms like planting of willows on riparian areas or releasing more water during drought periods, would be protected against any future restrictions designed to restore the grayling, should the fish be listed.  Over 30 landowners in the Upper Big Hole River have signed on to the CCAA.

The CCAA has spent $3.6 million (most of it tax dollars) to subsidize various projects designed to improve grayling survival and preclude listing. Among some of the improvements resulting from the CCAA and other efforts is a small increase in summer stream flows, removal of some barriers on tributary streams, and fencing of riparian areas. However, the overall effect has been far short of what is needed to stabilize, much less recover the grayling.

Groups that have supported the CCAA and generally thwarted efforts to list the fish include Trout Unlimited and the Nature Conservancy. In their view, listing would have had little positive on the ground effects on the fish. They believe that the CCAA offered the best opportunity to improve conditions for the grayling. While undoubtedly some of the habitat improvements that have resulted are positive for the fish, the outcomes thus far are not very promising, as the grayling continues to slide towards extinction. If the grayling should be listed, the CCAA will limit  the legal options for recovery.

Even in the face of obvious political machinations and duplicitous manipulation of data and biological information during the past two decades, these groups remained silent. Personally, I will consider them culpable if the grayling goes extinct for their failure to alert the public to the fish’s plight and work EVERY angle, including legal protection of the ESA designed to recover the fish.

Listing would have created a legal mandate for enforcement of the Clean Water Act minimum standards for water temperate, mandated grazing changes on federal lands managed by the Forest Service and BLM which control 50% of the grayling habitat, including much of its spawning habitat. It may also create opportunities to challenge dewatering of the Big Hole River by irrigators.

At this point, it is my sincere hope that the FWS finally lists the grayling, and provides a legal safety net that can result in significant changes in grayling management.

Anyone wishing to submit information regarding the Arctic grayling may do so by writing to Public Comments Processing, Attn: FWS-R6-ES-2013-0120; Division of Policy and Directives Management; U.S. Fish and Wildlife Service; 4401 N. Fairfax Drive, MS 2042-PDM; Arlington, VA 22203, or electronically at After accessing the website, Search for Docket No. FWS-R6-ES-2013-0120 and then follow the instructions for submitting comments. Information must be received by Dec. 26.

Additional information is available in the Federal Register announcement initiating this status review. For more information on the Arctic grayling go the FWP website or contact the FWP Service, Montana Field Office, 585 Shepard Way, Suite 1, Helena, MT 59602 or by telephone at 449-5225.


  1. Robert House Avatar
    Robert House

    As a professional fish biologist with over 40 years of experience working on salmonids, I believe the arctic grayling needs to be listed.

  2. rork Avatar

    Nice. Thankyou very much.

    I don’t get TU not helping more, though I admit their folks here in MI are often on the side of those salmonids that are more fun to catch, no matter if native or alien. Sports opportunity and the local economies they understand.

    The trout thing may have been part of why we are failing so miserably to restore grayling in our Au Sable and Manistee (and others in MI). These are our crown jewel rivers, formerly full of grayling, and troutless, now with many species but no grayling. We have a town called Grayling, with no such fish anymore. Perhaps high grayling densities prevent (brook) trout colonizing, and vice versa, just cause they predate each other’s eggs and fry (double negative feedback loops – they’re touchy things with molecules too, and we have a walleye/alewife one in some places that is really interesting too). We have other issues too of course – water temp, erosion smothering gravel, less in-river wood, less next-to-river timber. At least we aren’t emptying them for irrigation. If Au Sable ran 20 CFS in the “Holy Water”, there might be violence. Have folks computed the value of a gallon of water left in the Big Hole unextracted? Cause I thought that was holy water too.
    PS: I’m not trying sound expert, particularly about grayling and trout predation – I’m trying to drum up more education of the kind I just got.

  3. jdubya Avatar

    George, you write: “Groups like Montana Trout Unlimited (TU) have actively fought against listing. Instead TU and other organizations have sought to cozy up to the ranchers and advocated modest modifications in livestock management instead of actively seeking ESA protection.”

    Why is this? Why isn’t TU out in front of this mess? They of all groups should be fighting for listing. What do they hope to gain by not kicking some ass?

  4. C. Scott Avatar
    C. Scott

    Thanks George for all your great work on grazing and for these magnificent fish.

    From what I can find the maximum depth of upper Red Rock lake is about 2 meters, with the average being much less.

    I’m not sure if Lake Trout were native to Miner Lake in recent times, but they apparently still exist as a small population in Twin Lakes also in the upper Big Hole valley.

  5. Ida Lupine Avatar
    Ida Lupine

    I hope they can save this fish. What a shame that human interests and politics can allow for preservation of an endangered species.

  6. George Wuerthner Avatar

    The reason TU opposed listing is that the Montana director believed that little on the ground effects would result from listing. TU believed that it was better to work with the ranchers to garner some concessions rather than work for listing. The CCAA has definitely resulted in some minimum benefits for grayling, but it also precludes any further changes on these lands to save grayling. So if the grayling is listed, the CCAA supported by TU may greatly limit future options.

  7. Bruce Farling Avatar
    Bruce Farling

    This just in:

    George W. doesn’t know what the hell he’s talking about. It is a complete fabrication, as George claims, that Montana TU, “…actively fought against listing” of the fluvial arctic grayling. As MTU’s executive director for he last 20 years I can tell you that this is patently false. Further, I can’t ever recall having a conversation with George about it. But that’s not important. He apparently thinks he can read minds. Here’s the deal. We have never opposed listing. Period. And that is the same for my local chapters and my national organization. On the other hand we have never felt that actively supporting it, especially by going to court, is a good use of our resources and credibility. Let other interests do that. That’s what they like to do. They like lawyers. We like working with fish, habitat and people. Our focus has and will continue to be working on the very type of initiatives that would occur under a recovery plan anyway, if it wasn’t being prevented by court battles once the fish is listed. Things like: Fixing severely damaged riparian habitats to provide overhead cover, thermal protection, healthier channel geometry (which cools streams and provides depth, without necessarily adding stream discharge) and improved floodplain function (which conserves water by improving bank storage; eliminating dozens of grayling movement barriers in the river and tributaries; eliminating grayling entrainment in ditches; improving streamflows from the historical practices; using scientific methods to monitor fish movement and population trends; evaluating the role of introduced species on grayling populations; and, yes, trying to get some buy-in from local landowners for conservation of fish and river health. All the things that George apparently disdains because they don’t involve lawyers and ESA lawsuits. And all things that are being done today in the upper Big Hole Valley using a formal, legal tool — the candidate conservation agreement — that, whaddya’ know?…is embedded in the ESA. Agreements using these tools are legally binding agreements by landowners to do certain, specific habitat improvements on their lands that benefit fish, in exchange for not being charged with “illegal take” — which in practice is a hard legal case to make on individuals — should the fish be listed. These activities, by the way, are the very things that would probably, theoretically anyway, be required if the fish are listed, provided the underfunded Fish and Wildlife Service has the resources to enforce them, which it doesn’t.

    In our view, the science and law are clear: These fish merit listing. But listing and successfully conserving and restoring grayling populations are not necessarily the same thing. The ESA is a wonderful, necessary and important law. And TU is a strong proponent of the ESA. But it doesn’t necessarily work real well for recovering dwindling populations of native fish. If George would bother to look he might understand that if listing under ESA was all we had to do to recover fish species, then Montana’s pallid sturgeon and Kootenai white sturgeon wouldn’t still be on the brink of extinction. They have been listed for decades, and we support that. But ESA has largely failed them. If George had bothered to ask I could have told him that 13 Columbia river stocks of salmon and steelhead have been listed for years — listings that my national organizations and colleagues in three Pacific Northwest States have supported strongly, as have I — yet these fish are still perilously close to extirpation. Similarly, listing of bull trout has been merited, and we support that, too (and would have petitioned in the late 1990s to see that occur, except that some other groups, friends of George’s, were worried that if TU and its allies petitioned, then we might “control” the listing process, which is supposed to be a bad thing, I suppose. So they these interests did it themselves. Good for them. Moving on now…) On the other hand, people shouldn’t be deluded. All bull trout listing has done is hold the line on some potential habitat damage. But the fish continue to dwindle throughout their range because of construction of barriers such as dams and habitat damage that occurred many years ago, and, most importantly, because introduced, nonnative species such as lake trout, northern pike and brook trout are eating them, creating competitive pressures or creating hybrids. The number one threat today to bull trout is that posed by introduced fish. George and his friends are doing zero about that, much like they are really doing zero about grayling on the ground. But not us. We’re fixing habitat — and you can measure the success on the ground in places like the Blackfoot River – and we’ve been willing to take lots of lumps for pushing and helping fund programs that suppress lake trout and brook trout.

    It’s good that George provides some background on the natural history of grayling in Montana. What he omits to tell you is that if we are to recover both the fluvial and lake-dwelling versions of this species in its historical range, it will require a much wider focus than the Big Hole, which is all he talks about. It also requires reintroducing the fish to historical habitats, and that includes more projects like the successful venture that occurring in the upper Ruby River drainage. There we now have a reproducing population of grayling — the result of a project that we partnered in to develop egg sources from aboriginal strain, near-neighbor stocks (from the Big Hole), so that they could be introduced using incubators and imprinted to the Ruby. We are involved in similar efforts to reintroduce reproducing populations of westslope cutthroats into historical range. Because of TU and, importantly, state and federal agencies who get hammered for supposedly doing nothing for grayling, historical habitat in the Ruby is now reoccupied by fluvial grayling. George had nothing to do with this.

    What George also omits telling you is that if the fish get listed, and by all rights they will and should be, folks should be careful what they wish for. It will be very difficult, if not impossible, to reintroduce grayling to other drainages, which is a primary goal of grayling recovery in Montana. That’s because most of the historical habitat that has potential for reintroduction implicates private land and private water rights. And even the ESA can’t force landowners to have to host, or provide water for, listed species that don’t currently exist on their land or in streams they have a water right for.

    Among other challenges.

    Finally, often overlooked by the ESA-first-and-only approach to grayling conservation is this: These fish are glacial relicts. They have been isolated from Canadian populations for millennia. They are at home in and best adopted to boreal habitats. But they are up against it in an era of a warming and drying climate in the high, dry, sagebrush habitats of Southwest Montana. I will concede this: They could use more water, and yes, irrigators could use less, a primary and legitimate concern of George’s. But the challenges to conservation and recovery is a lot more complex than simply demanding more water than what is being supplied today, which is not going to occur that easily, ESA listing or not. People are dreaming if they think that listing is the big solution.

    I will never question George’s belief that he is doing the right thing by appointing himself an expert, as he tends to do, and then sitting on a high horse and criticizing others for not doing what he wants. However, convincing yourself you are right is not the same as being right. He could help rectify some of this by not making things up about interests he disagrees with.

    Bruce Farling
    Montana TU

    1. Ida Lupines Avatar
      Ida Lupines

      I hope with all my heart for this. I think for some of us (who may not appreciate how hard you work and the pressures you must be under), we worry that without the Federal government to enforce, special interests will rule even more.


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George Wuerthner