January 6, 2023
Montana Fish, Wildlife & Parks P.O. Box 200701
Helena, MT 59620-0701
Re: Montana Grizzly Bear Management Plan and EIS
To Whom It May Concern:
The Montana Chapter of Backcountry Hunters & Anglers is a volunteer-led organization consisting of approximately 3,000 dues-paying members in Montana, plus tens of thousands of supporters. We are a proponent of the North American Model of Wildlife Conservation and the Public Trust Doctrine that define fish and wildlife as a public resource held in trust for all people and managed on our behalf by the state agencies entrusted with their stewardship. This proven conservation model is the foundation of science-based fish and wildlife management, and we rely on state agencies to ensure that decisions are being guided by the best available science and knowledge.
The Endangered Species Act has been an important conservation tool for recovering threatened and endangered wildlife species in the United States. The grizzly bear is a remarkable ESA success story with strong population growth and expansion across the Northern Continental Divide Ecosystem and the Greater Yellowstone Ecosystem. But there is still recovery work to be done.
In early 2022, BHA signaled our support for the U.S. Fish and Wildlife Service (FWS) taking steps to initiate a five-factor threat assessment that acknowledges population recovery, but also the need to partner with the state of Montana, sovereign tribal nations, and other stakeholders to ensure that adequate regulatory mechanisms are in place for grizzly bears’ continued recovery.
While challenges certainly exist, any delisting efforts should prescriptively address the need to work with FWS to develop robust state and tribal management plans that are guided by science and remain dedicated to our shared obligation to establishing greater habitat connectivity, continued monitoring, and accountability in management policies.
Montana Fish Wildlife and Parks (FWP) Grizzly Bear Management Plan released on December 6th, 2022, and the corresponding Environmental Impact Statement, represents a pro-active management plan and is modeled around the previously mentioned standards that seek to ensure the continued recovery of grizzly bears by allowing for expansion of their range, considering public safety needs, and preventing grizzles from becoming re-listed under the ESA.
Upon review, we support FWP's management plan Alternative B - FWP's Preferred Alternative - that would continue to use the best available science to guide management decisions, including "the possibility of tightly managed grizzly bear hunting if not federally listed," while giving the authority on whether to hunt or not, how, and when, to the Fish and Wildlife Commission following an independent public process. Correspondingly in the EIS, we support Alternative 2, the Proposed Action.
We recognize FWP for their proactive efforts to develop a thoughtful plan with public input and have it in place for when grizzly bears return to state management. Montana BHA looks forward to engaging in future opportunities to collaborate with FWS and FWP and provide comments to inform future management decisions.
John B. Sullivan III, Board Chair
Montana Chapter of Backcountry Hunters & Anglers