B&C Position Statement - Wolf and Grizzly Bear Management

Effective Date: November 29, 2023

Situational Overview

Gray wolves and grizzly bears have become the most controversial species of wildlife in North America. Once considered animals to be eradicated by any means possible, these two species were “listed” under the Federal Endangered Species Act (ESA) in the 1970s. Since then, they have recolonized remarkably in the lower 48 states of the U.S., advancing under decades of Federal protection and three wolf reintroductions, and supported by abundant prey. Populations of both species are either stable or growing wherever they occur.

The ongoing controversy is fueled by passionate views about the proper size of the populations and their distribution, and how to manage the effects of these powerful, charismatic animals on other elements of their ecosystems (e.g., other wildlife species, livestock, people, and land). The question of how to manage them has been further complicated by disagreements over whether state governments should resume their role as managers or if the Federal government should retain this role. The Federal government has attempted to transfer the role to states for the wolf 8 times and for the grizzly bear twice (a third such decision is pending). All but one of these “de-listing” decisions have been reversed by the courts, with one of these reversals subsequently reinstated by Congress.

The main reason for these judicial reversals concerns the interpretation of a 1996 Federal policy that divided entire populations of wolves and bears into subpopulations for separate analysis of their viability. A secondary issue preventing resumption of state management is whether state management policies and plans are adequate to sustain wolf and grizzly populations.

Today, as a result of the two successful wolf de-listings by the Federal government, management of wolves in Idaho, Montana, Wyoming, and parts of Oregon, Washington, and Utah is the responsibility of the state fish and wildlife agencies and commissions. After first being listed in 1978, decades of efforts by the U.S. Fish and Wildlife Service (FWS) led to the Northern Rockies Distinct Population Segment of gray wolves meeting the requirements for ESA delisting.¹

Following numerous legal challenges to this decision, Congressional action in 2011 finally reinstated the latest decision of the FWS (at that time) to delist in Idaho and Montana. Wyoming wolf delisting followed after a subsequent FWS decision withstood a 2012 court challenge. The rest of the wolves in the lower-48 states, which are expanding in the Northern Rockies and Pacific Northwest, and occur in the Great Lakes states of Minnesota, Wisconsin, and Michigan, are listed and remain governed by the FWS under ESA authority.

Grizzly bears are exclusively managed by the FWS under ESA authority in the lower-48 states, with most of these bears living in the states of Idaho, Montana, and Wyoming. The FWS has attempted twice (and is attempting again now) to remove the bear from the endangered species list based on years of research, management, and recommendations by the federal/state interagency grizzly bear study team that grizzly bears, where they occur, have recovered, and are no longer threatened. As with similar attempts to delist the wolf, these decisions were rejected by courts for lack of consistency between the meaning of “population” in 1973 and the amended meaning in 1996.

This unstable management regime, roiled by litigation, suggests that wolf and grizzly bear management is at a crossroads. Most people agree that neither persecution nor wholesale protection are appropriate as the primary approaches by which we manage them. Still, we have not yet been able to assign stable governance as we have with numerous other wildlife species under state and tribal management. Without stable management, the problems of depredation, threats to human life, property damage, and nuisance cannot be adequately addressed. Frustrations over management have spurred state legislatures to pass species-specific laws and concerned citizens to promote ballot initiatives, both of which supersede the state agencies and commissions that apply scientific analysis and consider public opinion in setting management policy.

For much of its history, the Boone and Crockett Club and its members have been actively involved in wolf and grizzly bear policy, research, and in developing best management practices. The Club understands the biological, sociocultural, economic, and political factors associated with managing these two species, and is well-positioned to help promote results-driven, successful conservation strategies moving forward.

Position

The Boone and Crockett Club supports delisting recovered gray wolf and grizzly bear populations, resuming state management and oversight. The Club finds that keeping species at no risk of extinction listed on the ESA misuses the ESA, wastes the resources of the ESA program needed for other species, impedes conservation, and erodes support for the ESA.

The Boone and Crockett Club maintains that state and tribal wildlife agencies have the expertise and the capacity to successfully manage recovered wolves and grizzlies and refine their management policies to ensure populations remain robust and to mitigate any new challenges that arise. These agencies and their associated commissions are also in the best position to address the effects on wildlife and people from wolf and grizzly conflicts. The Club has been and will continue to work with state and federal leaders to ensure state-level policies sustain wolf and grizzly populations.

State management plans must ensure that objectives are based on science and its means are effective and ethically acceptable to society. Goals of managing population sizes and distributions must define measurable results, and the means of management must achieve those results within ethical bounds. For example, hunting should be bound to the ethic of Fair Chase, and management actions involving wolves should adhere to animal welfare standards to ensure removal is conducted in the most humane manner possible.

State management must outperform the ESA requirement that a state management plan constitutes an “adequate regulatory mechanism,” meaning that a plan gives reasonable assurances that a species will not become threatened or endangered again. The even larger challenge for state wildlife agencies is showing the entire country that a species once almost eliminated, then restored, can now be sustainably managed. State wildlife agencies have demonstrated exceptional success with many other species. Continued coordination between the states and FWS will maintain delisted status and help withstand litigation.

Of course, state management of any species comes with challenges. Managing wolves and grizzlies is expensive, hunting and trapping may not suffice to achieve population goals, and public debate over how many wolves and grizzlies there should be and where they should occur is contentious. The Club believes these debates should not be held in courts of law, but in the administrative venue of state wildlife commissions supported by the professional analysis of wildlife agencies. This is where most wildlife management policies have been made successfully for more than a century. However, decisions will not be made in these venues so long as wolves and grizzlies are listed under the ESA and managed by the FWS.