MT FWP Grizzly Bear Management Plan

The deadline to comment on the Montana Fish, Wildlife, and Parks Grizzly Bear Management Plan is quickly approaching. Saturday, Feb. 4, 2023 is the last day to comment on the proposed plan, which provides a guideline for the state of Montana to manage grizzly bears upon their removal from the Endangered Species List.

RMFRG Executive Director Trina Jo Bradley submitted the following comments:

“Having served on the Grizzly Bear Advisory Council, let me first say thank you for taking under consideration all of our recommendations. We worked extremely hard to put together a good set of recommendations, and it makes me very happy that FWP did not take that effort lightly.
Following are the notes and comments that I made while reading the plan. Again, thank you for putting together a well-researched, comprehensive plan that will set Montana up for success in grizzly bear management in the future.

P5 – I appreciate that FWP recognizes in print that grizzlies are “among the most difficult species to have in our midst.” 

Additionally, I appreciate that FWP recognizes that “removal of some animals will be necessary in the implementation of this plan.”

P8 – Role of Private Lands – I appreciate FWP’s recognition of the importance of private lands in the management of grizzly bears, but I would like to see “FWP would have ZERO tolerance for grizzly bears involved in conflicts.” Now that the population is well above recovery status, there is no reason to keep conflict bears on the landscape.

P9 – Destinations of a bear captured in a conflict – I understand the last sentence of the Preferred Alternative to mean that if delisted, FWP could potentially move conflict bears to other sites, potentially transplanting a problem where there previously wasn’t one. Am I correct? If so, I am strongly opposed to moving any conflict bears to any relocation site. Conflict bears need to be euthanized.

P11 – Engagement with Community Groups – The Preferred Alternative language is perfect – thank you.

P21 – First sentence – I would suggest adding “some” in front of “people and cultures.” Not everyone values grizzly bears.

Last sentence of the first paragraph – I would suggest adding “and working lands” after “communities.” We need to reiterate that ag producers are paying the highest price for grizzly bear recovery.

Fundamental Objectives – I suggest adding another bullet point that says, “Maximize agency and public understanding that working private lands are key to grizzly bear recovery and continuity.” 

P41 – Role of Private Lands – FWP needs to acknowledge that private lands provide much more than connectivity between ecosystems – private lands also provide an extensive amount of habitat right now, and will continue to increase as the grizzly population grows.

P46 – Public Information on Conflicts, etc – I don’t think there is a need to share every detail about conflicts, relocations, or mortalities with the public, although such information should be available upon request. However, for people in certain positions (such as myself) it would probably be beneficial to both sides to share information throughout the season.

P51 – Geographic Setting – Why didn’t you include Liberty, Hill, Chouteau, Judith Basin, Fergus, Golden Valley, and Musselshell Counties in your map? There are already confirmed bears in some of them, and I’m almost positive there are bears present in every one of those counties, at least during parts of the summer months. I would strongly suggest you change your map and subsequent information to include those counties.

P55-56 – Land Ownership – I think it would be helpful to say just what percentage of that 37 county area is private land – people need to know just how much private working lands are affected by grizzly bears, and how much they contribute to the survival of the species. (Page 78 Habitat and Range Expansion says, “By 2018, more of the NCDE population’s Occupied range was on private land than was on public land.”)

P65 – Sidebar 5 – What is the point of having this in the plan? It contributes nothing.

P66 – Habitats – Because grizzly bears inhabit so many acres of working private lands, I think it would be beneficial if FWP provided information in this section on what they eat and where they prefer to be on these lands.

P66 – Motorized Access – The first sentence is entirely inaccurate – I’d say the NCDE grizzly population on the east Front has done quite well in close proximity to humans and established settlements.

P82 – Distributional Objectives – Close to the end of the second paragraph, it says, “FWP favors working with partners…(recognizing that this will require efforts from people and entail some suffering for bears)…” I do not like the implication that bears are going to “suffer.” Some bears may have to be removed, maybe lethally, but there will be no suffering involved. This statement opens the door wide for those opposing any management of grizzly bears. I suggest the entire statement is removed.

Questions about Population Management
What is FWP going to do to manage populations once the ecosystem is fully saturated (which is already occurring in NCDE and GYE) and grizzly bears are delisted?

Executive Summary (page 5) says, “FWP’s Preferred Alternative does not identify specific statewide population targets beyond those already referenced…”

ES (page 6) says, “FWP’s Preferred Alternative does not manage for grizzly bear presence outside of core areas…” So am I to understand that if they behave, they’ll be allowed to live wherever they roam, and if they don’t behave, FWP will take steps to remove immediately?

Part Two (page 40) – Numerical Objectives – Again, FWP does not outline how they will CONTROL the growing population, or at what point they will decide the landscape is full. As a producer, this is a huge issue for me. I need to know that we aren’t just going to let bears completely overrun the landscape, or expand into areas they don’t need to be. 

Additional Background (page 82) says, “…FWP view the grizzly bear…for which detailed numerical objectives would not be useful.” Is this to avoid too much push back from either side of the issue? Are there plans in place that are not “written in stone,” so to speak, to control the population?

Hypothetical Hunting (page 107) – Sixth Bullet – Hunts would be sustainable (not intended to reduce population abundance) – WHY? Wouldn’t a hunt be the perfect way to bring in a massive amount of funding for management AND help reduce the population of bears – especially in areas where they don’t provide connectivity? And again, if FWP isn’t using hunting to reduce the population, what are they going to do?

P26 – Survey says 83% of Montanans support hunting;
P99 – “FWP acknowledges that, to MANY Montana citizens…” Clearly, those are opposing statements. I would suggest changing “many” to “a small percentage” or “some.”

As a sportswoman and livestock producer on the Rocky Mountain Front, I find great value in a potential hunt for grizzly bears. The amount of revenue that could be generated by selling tags in a lottery could quite possibly fund all management efforts across the state. I would imagine that all Montana citizens – regardless of their stance on hunting – would purchase tags, either for that once in a lifetime hunt, or to prevent a hunter from getting the chance. 
Montana has shown time and again that using hunting for population control works. Grizzly bears are no different than any other game species, and it is time people stopped putting them on a pedestal.
I think Approaches Two and Four (page 107)to hunting would be the best choices for Montana. Approach Two would generate a great amount of revenue, and would in no way threaten the grizzly population in the state. Approach Four would be a great way to generate more funding, give someone that chance for a hunt, and of course, manage an ever expanding population of grizzly bears.
I do not think Approach Three is the way to go. A “rich man’s hunt” is not something I support, and I would imagine most Montanans feel the same way. 

Thank you for your consideration.”

Please take the time to send in your own comments, or reach out to Trina if you need assistance.

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