Why Delisting of Grizzly Bears is Premature

The Fish and Wildlife Service (FWS) has decided to delist the Yellowstone grizzly bears, removing them from the protection given by the Endangered Species Act (ESA). And state wildlife agencies in Wyoming and Montana are anxious to start sport hunting the bears.

If you follow environmental politics, it is very clear why industries like the oil and gas industry, livestock industry and timber industry and the politicians they elect to represent their interests are anxious to see the bear delisted. Without ESA listing, environmentally destructive practices will have fewer restrictions, hence greater profits at the expense of the bear and its habitat.

Delisting is opposed by a number of environmental groups, including Center for Biodiversity, Western Watersheds, WildEarth Guardians, Alliance for Wild Rockies, Humane Society, as well as more than 100 tribal people. Conspicuously absent from the list of organizations opposing delisting is the Greater Yellowstone Coalition.

Proponents of delisting, including the FWS, argue that with as many as 700 grizzlies in the Greater Yellowstone Ecosystem, thus ensuring the bears are now safe from extinction.  Seven hundred bears may sound like a big number. But this figure lacks context. Consider that the Greater Yellowstone Ecosystem is nearly 28 million acres in total area. That is nearly the same acreage as the state of New York. Now ask yourself if 700 bears spread over an area the size of New York sounds like a lot of bears?

Many population ecologists believe 700 bears is far too small a number of animals to ensure long-term population viability.  Rather than hundreds, we need several thousand bears.

Keep in mind that the Yellowstone Grizzlies went through a genetic bottleneck when their population was reduced to an estimated 136 animals. Indeed, the Yellowstone grizzlies have the lowest genetic diversity of any bear population.

This lack of diversity is exacerbated because dominant male grizzlies tend to breed with multiple female partners, further reducing the genetic diversity in the population.

Add to this biological limitation is the changing food structure for the bear. Major food resources from elk to whitebark pine to spawning trout in Yellowstone have all declined, challenging bears to find new food resources.

Plus, state wildlife management agencies are generally hostile to predators, seeing them hindering production of elk, deer, moose, and other animals desired by hunters.

Without the protection of the ESA, and the loosening of restrictions on the killing of bears, more grizzlies will be killed for livestock depredations, as well as potentially by trophy hunters. Most predator biologists recognize that killing dominant animals, whether it is bears, wolves or cougars disrupts the social ecology of these animals, leading to more livestock depredation.

In ecology, there is the “precautionary principle” which admonishes all of us to err on the side of caution. Instead of using the minimum estimates of what constitutes a “recovered” population we should be careful and not rush to eliminate protections for an animal whose biological potential is low and is slow to recover from any declines.



  1. stan sheggeby Avatar
    stan sheggeby

    We need several thousand bears, rather than hundreds, to ensure long-term population viability!!

    1. Kurt Imhoff Avatar
      Kurt Imhoff

      What do you base that number on, Stan? The fact that is was used (without citations) in the article above?

      The original threshold for de-listing wasn’t pulled out of a hat, but based on an estimate of what a healthy core population would need to reach. Now we have exceeded that goal by a few hundred bears. Recent expansion of solitary males outside of the GYE is indicative of the core area being at capacity.

      I love grizzlies but do not love what heel-dragging their de-listing is going to do to the right’s perspective of the ESA. We need to celebrate the de-listing, not oppose it. Nobody involved at a local or regional level wants the population (post de-listing) to be hunted to where they would require re-listing under the ESA. That’s insane.

      1. Kurt Imhoff Avatar
        Kurt Imhoff

        …fact that it was used*

  2. Ted Chu Avatar
    Ted Chu

    The same groups argued that it was premature to delist this population when it first met recovery goals a decade ago at 500 bears. Now we are at 700 bears. Has anyone opposing delisting provided a number or bears for the GYE that would be acceptable for delisting? What is that number based on? How do we know that 700 bears is not “full” for this ecosystem, even at 28 million acres, with possibly declining foods – elk, whitebark pine nuts, cutthroat trout and increasing human conflicts? Opponents of delisting often point to the loss of whitebark pine and cutthroat as a reason to not delist. But the bear population has been at least stable and probably increasing during this decline food items over the same time period. Probably increasing because the total population has apparently remained stable in the face of increasing mortality. Whitebark pine only produce good nut crops every 2 or 3 years on average yet while more bears come into conflict during bad pine nut crops and birth rates may decline they don’t starve in any numbers in those years. This decline in bear food items can be viewed two ways. Either the bears have been able to adapt to other foods, which they seem to have done. If not then ultimately the loss of these foods will represent a loss of carrying capacity for bears in the ecosystem. That will eventually translate into a reduction in the population regardless of the legal status of the species. Being “listed” can only go so far in compensating for habitat loss or degradation for any species. Protect them all you want, the land can only support so many bears and there are indications from the bears that they are at carrying capacity in the GYE. The people who actually live with these bears, not hundreds or thousands of miles away, feel there are enough grizzly in the ecosystem now. This may be why the group closest to the ecosystem and the issue, the GYC, is not opposing delisting. The last thing the states of Wy, Mt and Id will do is risk a significant population decline and possible re-listing resulting from their management. They all put way too much effort in getting the bear population up to where it is now to do that. They will hunt them very cautiously. I would prefer they limit hunting to three strikes bears that will be removed from the population one way or another anyway although that may not be practical. Grizzly bear recovery in the GYE is an ESA success story. The population has exceeded the goals in the recovery plan for at least a decade. It’s time to let the Act work in this case which will strengthen it’s acceptance. Having congress delist the bear as happened with wolves(they know how easy it is now)is not a good conclusion.
    Regarding genetics of this population:


    1. Gregg Losinski Avatar
      Gregg Losinski

      Thank you Ted! It is great to have someone involved with the early work to recover the grizzlies speak up.

  3. Patrick Avatar

    A lot of the success of grizzlies in the recent past is likely due to having wolves in the ecosystem, providing them with a steady stream of carcasses to steal. This may be part of the reason they have been able to adapt to loss of other food sources like pine nuts and cutthroat trout. If wolves are allowed to expand, and cattle are reduced on public lands, I think the grizzlies could probably tolerate some trophy hunting and still expand their population and range. On the other hand, if wolves are hunted hard, the grizzlies will no doubt suffer as well. One cannot simply look at the grizzlies in isolation from the entire web of their food supply.

    1. Ted Chu Avatar
      Ted Chu

      Good points.

  4. Ida Lupine Avatar
    Ida Lupine

    The people who actually live with these bears, not hundreds or thousands of miles away, feel there are enough grizzly in the ecosystem now.

    Is this based on science, or simple inconvenience? I don’t know that all of the people who live with them feel this way, (I did read an article about a hobby sheep rancher recently who doesn’t ‘like’ them). The reason that the rest of us don’t have them is because they were killed off by similar interests for similar reasons to those of today, who felt they could decide for everyone else what was best, with nothing scientific to back them up – just corruption and bullying.

    I do no think that 700 bears is enough, because of the questionable food supplies, slow reproductive rates, questionable habitat, and further encroachment of humanity, and the great unknown about human behavior towards them. History shows us that we don’t have a lot to have confidence in, and I am sure that ‘hunting wolves hard’ is something we can count on. Did we forget that Idaho is going to pass a law legalizing baiting of wolves, and the Democrats of the Great Lakes are going to use them as a bargaining chip yet again?

    If steps were taken to have connectivity with other bears, a buffer zone around the park(s), I bet a lot of people would feel much differently about delisting, and take assurances about caring for the health of the species. But no one will give an inch on that either, so….we don’t.

    We’d like to think that bears won’t go extinct, as according to latest reports, the 6th mass extinction is currently well underway.

    1. Ida Lupine Avatar
      Ida Lupine

      ^^They are also part of the public trust, an so belong to everyone in the country.

    2. Ted Chu Avatar
      Ted Chu

      If 700 bears are already struggling with “….. questionable food supplies, slow reproductive rates, questionable habitat, and further encroachment of humanity, and the great unknown about human behavior towards them.” why would you want to add more bears? Just to create more conflicts and more bears killed by Wildlife Services?

      1. Ida Lupine Avatar
        Ida Lupine

        I don’t know that the bears are struggling yet, but it is a concern. I guess what I meant was, until these things are addressed, should the bears be delisted? There’s no safety net. Rather than kill them, wouldn’t it be better to look at white pine recovery, salmon recovery? Perhaps they need a wider range to feed? The biggest dangers are what people will do to them once they are delisted, more so than anything else IMO.

        The slow reproductive rate would seem to imply that the bear population would not increase much. “Carrying capacity” is going to continue to diminish the more the human population grows.

        A big thing is to continue to drive home to tourists to keep a safe distance, not make bear spray a ‘personal choice’, and to continually educate. People just seem to run wild.

        I don’t think there should be hunting, and there should be a buffer zone around Gardiner, which seems to be a place that some take advantage of, whether hunting wolves, bears or elk. It appears to me that Scarface was shot by a poacher, and yet nothing was done.

        I also think that ‘carrying capacity’ is a term

        1. Ted Chu Avatar
          Ted Chu

          No, “nothing” is not what was done. The incident was thoroughly investigated by profession law enforcement officers and they concluded the “poacher” who turned himself in, killed scarface in self defense and that he feared for his life. He was shot at very close range. I wasn’t there so that’s about all I can offer.

        2. Ted Chu Avatar
          Ted Chu

          “Carrying capacity” is going to continue to diminish the more the human population grows.”

          I agree.

  5. Ida Lupine Avatar
    Ida Lupine

    oops, that should read:

    “If steps were taken to have connectivity with other bears, a buffer zone around the park(s), I bet a lot of people would feel much differently about delisting, and take assurances about caring for the health of the species seriously.”


    It’s just too iffy just now to abandon them to killing, no matter what the assurances. Why is it so important to kill them? Even Yellowstone has been excluded from the decision-making – it just isn’t right. I’ll take independent scientists’ word for it, not those who have agendas, or are under the thumb of special interests.

  6. Ida Lupine Avatar
    Ida Lupine

    Do we want to see what happened with wolves happen to grizzlies? Once they lose Federal protections, all bets are off, except for the divvying up of the population for trophy hunts. There’s no telling what will happen to them!

    The argument that the Federal gov’t will step in again if too many are killed falls flat, because by that time the damage has been done!

    Wolf hunting gets increasingly more severe just about every year. To say that grizzlies ‘maybe can rely on leftover wolf kills, moths and ladybugs’ really doesn’t make one feel they are ready to be delisted. For a reassuring grizzly recovery, if and maybe don’t really give much confidence.

    As George says, what about the precautionary principle? That’s been thrown up in the air it seems, replaced with ‘we know it all, and nothing can go wrong’. Until it does.

    But perhaps if there were buffer zones around the park(s) and tribal lands, that would be a reassurance? I don’t know if tribal authorities can move for a buffer zone around their lands independently?

    1. Ted Chu Avatar
      Ted Chu

      “Do we want to see what happened with wolves happen to grizzlies? Once they lose Federal protections, all bets are off, except for the divvying up of the population for trophy hunts. There’s no telling what will happen to them!”

      We can only hope that grizzlies do as well under hunting as wolves have. From a handful in Glacier NP there are now approx. 1700 wolves in nearly 250 packs in the northern rockies and they have re-colonized the Cascades in Wa & Or, now the Sierras in Ca, and I predict soon Ut and Colo.

      1. Nancy Avatar

        “From a handful in Glacier NP there are now approx. 1700 wolves in nearly 250 packs in the northern rockies and they have re-colonized the Cascades in Wa & Or, now the Sierras in Ca, and I predict soon Ut and Colo

        So what?

        On average, there are far more than 1,200 head of cattle within a 5 mile radius of me, Ted Chu, on any given day. And a good number of those cows, just headed into public lands for the next 4 months.

        So I have to ask, what’s your point?

        That the thousands of acres of wilderness areas (just in my area alone) available to all sorts of predators and other wildlife (native to the area) should just continue to be “managed” in the name of livestock producers/ hunting interests?

        “We can only hope that grizzlies do as well under hunting as wolves have”

        And where the hell did you pull that sorry ass comment from?

        How many decades did it take for grizzlies to actually reach that recent, so called, magic number of 700 ? In what is still impressive when it comes to wilderness areas left in the US?

        1. Ted Chu Avatar
          Ted Chu

          Did you actually read my comments? It doesn’t seem so. 1.I mentioned the huge success of the wolf re-introduction in spite of very liberal hunting season in response to the question “Do we want to see what happened with wolves happen to grizzlies?” We can only hope that what happened to wolves would happen to grizzlies – approximately a 15X increase in numbers and a significant expansion of range into adjacent states. It won’t of course in part because of the different reproductive rates of the two species. 2. I have always supported the removal of all managed and feral livestock from our public lands. 3. It took approximately 4 decades for the Yellowstone grizzlies to reach 700. Most of the increase in the last couple decades has been outside of the parks and much of it has occurred outside of statutory wilderness, in eastern Idaho for example. No one in their wildest dreams expects to recover grizzlies throughout their historical range. But they seem to be secure and at carrying capacity in the Yellowstone ecosystem. Removing cows from the remaining high conflict areas might get you a few more bears, and I support that effort, but not a huge increase in the population.

  7. Ida Lupine Avatar
    Ida Lupine

    More tourists behaving badly around grizzlies, without anything to deter them, and putting the bears at risk of being killed:


    And a good article int WaPo with some good quotes from Chris Servheen, about people not taking proper precautions – Scarface’s killer ran into the bear accidently and then, you know how it plays out. It’s really too bad that we can’t have a buffer zone in Yellowstone in the area around Gardiner:


  8. Gary Humbard Avatar
    Gary Humbard

    As Ida correctly stated, all flora and fauna species on public land belongs to all Americans, thus grizzlies should be “managed” as such.

    “Protect them all you want, the land can only support so many bears and there are indications from the bears that they are at carrying capacity in the GYE”.

    I believe there are potential land linkages for grizzlies between the GYE, NCDE and Bitterroot Recovery Zones (Big Belt and Centennial Mountains and Rattlesnake Hills) of which right or wrong, de-listing could have negative consequences for these connections to occur.

    I agree with Mr. Chu that the states will take a very conservative approach to hunting and thus will be the least concern. The vast majority of grizzly bear mortality within the GYE is due to livestock conflicts, human habituation and vehicle collisions.

    NGO’s are buying out problematic federal grazing permits and working with ranchers to implement non-lethal practices to reduce the first issue. NGO’s are also helping to purchase and install bear proof garbage and food containers within numerous campgrounds and to reduce the third threat, wildlife friendly road overpasses and underpasses are being installed. Now if we could only get folks to take a chill pill and slow down within mountainous areas.

    As Mr Chu correctly stated, grizzly bear recovery within the GYE is a success story. However, this story is not finished until all FWS grizzly bear recovery zones have stable populations and are connected to one another with dispersing bears. The end!

    1. timz Avatar

      “I agree with Mr. Chu that the states will take a very conservative approach to hunting and thus will be the least concern.”

      Just like they said with wolves. Some people never learn.

      1. Ted Chu Avatar
        Ted Chu

        I don’t recall the states ever saying that about wolves, certainly not Idaho which issued a ridiculous number of tags right off the bat. Yet wolves continue to thrive in the northern rockies. Prior to 1996 there were 2-3 packs in GlacierNP. Now there are at least 1700 wolves in nearly 250 packs and they have re-colonized Wa, Or and now Ca. Ut & Colo will be next. All this in spite of hunting and killing by Wildlife Services. The population dynamics of wolves are vastly different from grizzlies. Wildlife biologists will manage grizzlies accordingly, which will be very conservative.

        1. timz Avatar

          BullCrap they’ve expanded the wolf hunt multiple times and now they are talking about allowing baiting them. Thriving, hardly I used to see them at least a couple times per year and I haven’t seen one in at least 4 years (outside of Yellowstone) Grizzly haters are of the same ilk as wolf haters. We can only hope the courts stop the delisting.

          1. Ted Chu Avatar
            Ted Chu

            I don’t support the extremely liberal wolf seasons that the states have implemented and I am opposed to wolf or bear baiting. I don’t know exactly where you are used to seeing wolves and maybe they are gone from that specific area but you can’t deny the facts of the situation which are that there are approx. 15X more wolves in 250 packs in the northern rockies now than there were 20 years ago in spite of your local anecdotal observation. There are very few grizzly haters and very many wolf haters and they come from different perspectives. They are not in my experience of the same ilk at all.

    2. Ida Lupine Avatar
      Ida Lupine

      +1 Thanks, everyone. I forgot to point out that Dave Wenk is also quoted in the WaPo article, and he would like better communication among the groups concerned with the well-being of the grizzly population. I thought it said that he wasn’t informed about Scarface’s killing.

      Mr. Servheen said that after the delisting, penalties will be lower. How can they be less than what they are now? And I mean no disrespect with my posts.

      1. Ida Lupine Avatar
        Ida Lupine

        or all of the details about the investigation into Scarface’s killing, I should say.

        Why was the guy hunting at dusk? I wasn’t aware anyone could do that, and he went back afterwards and tampered with the scene.

  9. Elk375 Avatar

    Ida shooting hours in the State of Montana are 1/2 hour before sunrise and 1/2 hour after sunset. The best elk hunting is in the early morning and the late after noon. I generally quite hunting around 11 in the morning and start again between 2:30 and 3:00 PM.

    1. Kathleen Avatar

      Scarface was killed in the dark, after 6pm and by light of the killer’s headlamp. This article was just published today in the Chicago Tribune:
      “Now we know why beloved Yellowstone grizzly bear Scarface was killed” and addresses de-listing:


    2. Nancy Avatar

      And I’d be willing to bet you are also very aware of when the sun rises and sets when you are out hunting, Elk.

      The sun sets before 5 pm in November. The bear was shot after 6 pm.

      A neighbor of mine was out in the woods recently when he and a friend surprised a cinnamon colored, black bear. The bear bounced on its front feet gnashing its teeth at them. His comment was “I’d left my handgun in the truck, if I’d had it with me, that would of been one dead bear!” That, too often I’m afraid, is the mentality of locals (and the guy is an avid hunter)

      So what did they do? Picked up some big sticks and chased it off.

  10. Yvette Avatar

    This is not over yet.

    Native Americans have other avenues of recourse, and sued the United States on June 30 in Federal Court. The four-count lawsuit, filed by nine tribes or their representatives, plus three spiritual societies and spiritual leaders, claim the defendants failed to consult with them in developing the delisting documents, in violation of the Administrative Procedure Act, and that the delisting violates their religion and the Religious Freedom Restoration Act.

    The Crow Indian Tribe, the lead plaintiff, is joined by the Crow Creek Sioux Tribe, the Standing Rock Sioux Tribe, the Piikani Nation of Canada, the (Blackfeet) Crazy Dog Society, the Northern Arapaho Elders Society, the Hopi Bear Clan, the chairman of the Northern Cheyenne Tribe, a Zuni religious leader, and others.

    As Fish and Wildlife prepared to delist the Yellowstone grizzly, it sent notification in April 2014 to just four tribes. A year later, after acknowledging that was probably insufficient,(emphasis mine) Fish and Wildlife sent letters to 53 tribes, saying they could participate in a online seminar. The tribes refused to participate, saying federal rules require that consultation be direct and meaningful government-to-government collaboration.


    “Letters to four tribal leaders? and an ‘online seminar?” It wasn’t ‘probably insufficient, it was absolutely insufficient. That is based on the foundation of Indian law that goes all the way to the Marshall Court in the 1830’s.

    The legal case, Worcester v. Georgia, 1832, served as the United States Supreme Court Case that first recognized the sovereignty of the tribal nations within the United States (Johnson & Martinis, 1995). When the governmental authority of tribes was first challenged in the 1830’s,
    U.S. Supreme Court Chief Justice John Marshall articulated, “Indian Nations had always been considered as distinct, independent political communities, retaining their original natural rights, as the undisputed possessors of the soil…the very term nation so generally applied to them means “a people distinct from other” (NCAI,2000). The Indian Country preemption analysis of Worcester posited that the federal recognition of Indian tribes as separate polities through treaty, or later, through statutes or executive agreements,, (emphasis mine)setting apart and protecting separate tribal communities in reservation or other federally guaranteed lands preempted the exercise of state authority in those areas (R. N. Clinton, 1981).

    The Executive Order, 13175 established by President Clinton in 2000 required all federal agencies to consult with tribes on a government-to-government basis and to develop a written policy for the agency’s approach to consultation.This EO is based on the foundation of Indian Law; it was not simply pulled out the air for a ‘feel good’ moment. This is why when the ‘grizzly czar’ sent letters to four tribal leaders it is not ‘probably insufficient’ but it is insufficient. It fails to follow the USFWS’s own written policy on tribal consultation that was required by EO 13175. https://www.fws.gov/TCG.pdf

    A lot has transpired since 2014 when those four letters were first sent. I’ve not followed or stayed on top of the discord over the delisting decision. I do hope that the tribes are able to tie this up in court long enough to slow down this delisting. These bears may not be important to your religion but they are important to many tribe’s religious beliefs. Even if they eventually get delisted based on their populations, why must they be hunted? There is no sound reason, no scientific reason, no religious reason, to trophy hunt them.

    One a similar vein, I have question to those of you who trophy hunt.

    When bald and golden eagles were removed from the ESA because their populations had recovered, based on science, why is it they were never legally hunted? No trophy hunting for eagles? Why?
    I propose it is likely because the bald eagle is an iconic representation of America. Not quite religion, but darned close. If there is another reason, what is it?

    The tribes may not win this case but I hope they slow down the delisting.

    1. rork Avatar

      I will say nothing you did not know already. Migratory bird treaty act protects them, as well as other national laws. What citizens want can and should matter, but the people can be perverse, ignorant, lazy, or stupid.

      It seems “no sound reason” is a subjective value statement, and another person can just as easily disagree. As we all know, a problem in many states is people having almost no power over their game laws. In MI we are a bit better, but have forbidden the hunting of mourning doves by referendum. Democracy ain’t perfect.

    2. Ted Chu Avatar
      Ted Chu

      In partial answer to some of your questions – I don’t trophy hunt and I have never killed a bear, lion, wolf, coyote or bobcat and I never will. I have been gifted bear meat and it was delicious so that would be one incentive to hunt gbears. Unfortunately many states don’t require hunters to salvage the meat of bears which is just wrong IMO. If the states allow hunting of gbears I hope they require them to salvage the meat. Of course they will take the hide and claws and skull. Those items may be worth a lot of money which may provide one incentive for some people to hunt them. EAGLES The tribes can hunt eagles and they do for ceremonial uses of the feathers & talons. Some have been busted for selling to non-Indians. The USF&WS collects dead eagles killed by electrocution or collision, etc. for the tribes as well. Now there is a new program of turning over injured eagles that can never be returned to the wild to the tribes to keep alive and then salvage their moulted feathers. Hopefully that will reduce or end the killing of healthy birds.

      1. Yvette Avatar

        Thank you, Ted Chu. I knew about the repository and knew it was usually a long wait when a request was made. I was not familiar with the 1978 amendment to the 1940 Bald Eagle and Golden Eagle Protection Act allowing Natives to to ‘take’ eagles’ for religious purposes. I also didn’t know about the conflict with the Wind River Arapaho over being allowed to take two eagles.
        The tribe I work for has a large aviary/sanctuary, The Grey Snow Eagle House. It’s well run and they now have more birds than just eagles but they are mostly raptors. They disperse feathers that have naturally molted to tribal members. One of their recent rescues was able to be released a little over a month ago.

  11. Ida Lupine Avatar
    Ida Lupine

    From the NYT. Check out the gorgeous drawing of the bears’ food supply connection – I especially love the fish:


  12. Ida Lupine Avatar
    Ida Lupine

    “The only way Yellowstone’s grizzly bears can be expected to thrive in the long run is for their ecosystem to be connected by a corridor of occupied habitat to other grizzly populations — the one centered in Glacier National Park to the north and others up the Rocky Mountain chain to Alaska. That’s still possible, if grizzly hunting remains forbidden and the connecting lands are safeguarded in perpetuity against incursion and development, which they are not today.”

    This would be a dream. If only there would be a little consideration given, or a little compromise, instead of a constant dictatorship for the West – people would feel much better about a delisting.

  13. Mickey Kaufman Avatar

    How exciting to see wild bears, there are not that many wild things left anymore. Leave the bears alone! Let nature prevail and allow us to wonder at Gods great Earth!
    Remember Yogi Bear? A positive image for children. and what about Smokey the Bear? A bear that protects us!
    I say leave the innocent creatures alone, they are not running us down.


George Wuerthner is an ecologist and writer who has published 38 books on various topics related to environmental and natural history. He has visited over 400 designated wilderness areas and over 200 national park units.

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George Wuerthner