2018 CPANP Letterhead Logo


April 24, 2018

Wyoming Game and Fish Department, Wildlife Division

Attn:  Regulations
3030 Energy Lane
Casper WY 82604

Dear Wyoming Game and Fish Department:

I am writing to you on behalf of over 1,500 members of the Coalition to Protect America’s National Parks (Coalition), a non-profit organization composed entirely of retired, former, or current employees of the National Park Service (NPS). The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System (System). As a group, we collectively represent more than 35,000 years of experience managing and protecting America’s most precious and important natural and historic places.

We count among our members many former employees of Yellowstone or Grand Teton National Parks, who are quite familiar with the conservation history of the Greater Yellowstone Ecosystem distinct population segment of grizzly bears (GYE grizzly bears). As a national park advocacy group, the Coalition is most concerned about the adverse impacts that increased human-caused mortality from Wyoming’s proposed hunt will have on the grizzly population within and in the immediate vicinity of Yellowstone and Grand Teton National Parks. We are writing now to express our opposition to the Wyoming Game and Fish Department (WFGD) proposal to allow killing of up to 24 GYE grizzly bears this coming fall, including in areas along the boundaries of the two national parks.


The increase in the GYE grizzly bear population achieved over the past 35 years has truly been a wildlife conservation success story. However, the premature removal of GYE grizzlies from protected species status, without providing adequate institutional controls to ensure the population remains recovered, has been a grievous mistake. During the process to delist the GYE grizzly bear, the Coalition expressed our concerns that the U.S Fish and Wildlife Service (FWS) proposal to remove this population from protections of the Endangered Species Act did not do enough to ensure the long-term conservation of this population. Our primary concern was and continues to be that the Final Delisting Rule would allow significant increases in human-caused mortalities of GYE grizzly bears, including those caused by hunting.


1) The proposed hunt should be delayed indefinitely until ALL issues pertaining to the FWS delisting decision, including appeals to the courts, have been resolved – As WGFD surely knows, the FWS delisting decision and related Conservation Strategy are the subject of multiple lawsuits in the Federal court system[1], [2]. These suits raise legitimate concerns about the adequacy of FWS delisting decision and the associated Conservation Strategy.

A prudent approach would be to hold off on proposing a grizzly bear hunt in 2018. And that is exactly the approach taken by Montana Fish Wildlife and Parks (FWP), which announced on February 8, 2018, that it would NOT be proposing a grizzly bear hunt in southwest Montana this year. In a statement issued by FWP[3] Director Martha Williams said, in part: “Our focus, now they are delisted, is managing these iconic species for long term recovery… Holding off on hunting for now, I believe, will help demonstrate our commitment to long term recovery and at the same time allow us the science-based management flexibility we need.” The FWP statement added, “[W]ith challenges to the grizzly bear delisting rule already working their way through the courts, a hunting season seems likely to complicate those proceedings.” On February 15, 2018, the Montana Fish and Wildlife Commission accepted FWP’s proposal NOT to propose a grizzly bear hunt this year in the Greater Yellowstone Ecosystem.[4]

Clearly, Wyoming is not bound by Montana’s decision. However, in stark contrast to Montana’s cautious approach, Wyoming is proposing an aggressive grizzly hunting program in 2018 that would allow recreational killing of up to 24 GYE bears – including some through baiting. The WGFD proposal targets grizzly bears along the eastern and southern border of Yellowstone and the western and southern boundary of Grand Teton National Parks, including areas within the Primary Conservation Area (PCA) as defined in the 2016 Conservation Strategy for the Grizzly Bear in the Greater Yellowstone Ecosystem. See comment # 3 below.

There are numerous concerns about the FWS delisting decision and Conservation Strategy that should be resolved in court before WGFD can reasonably plan and implement a grizzly bear hunt. Because of this, the Coalition adamantly opposes Wyoming’s proposed 2018 hunt.

2) The proposed hunt will exacerbate the levels of human-caused mortality already occurring prior to the delisting – Questions about the effective management of human-caused grizzly bear mortality are a primary concern with the delisting decision. It is well documented that:

  • Humans are the primary agent of death in grizzly bears. Indeed, rates of human-caused mortality determine the trajectories of most grizzly bear populations (Eberhardt et al. 1994, McLellan et al. 1999, Harris et al. 2006).
  • During autumn, most areas outside national parks are open to ungulate hunting. Haroldson et al. (2004) presented evidence that the distribution of some radio-marked bears changed from use inside YNP to outside YNP with the opening of elk hunting. This movement to outside YNP was attributed to the availability of gut piles left by hunters, which brought hunters and bears into close proximity. About 51% (57 of 112) of the known and probable deaths after August of independent bears in our mortality database were associated with hunters defending a camp, carcass, or themselves when charged by a grizzly (Schwatrz et al, 2010).
  • As described in the FWS 2016 Final DRAFT Conservation Strategy for the Grizzly Bear in the Greater Yellowstone Ecosystem[5] (p. 84): “The number of elk hunters in Wyoming, Idaho, and Montana who recreate in the PCA were estimated and compared with known and probable grizzly bear mortalities from 2005 to 2014 to determine if bear mortality is correlated with hunter numbers. Although total hunter numbers have declined over this time period (van Manen 2015, in litt.)…The greatest source of grizzly bear (≥2 years old) mortality during 2004–2014 in the GYE has been due to interactions with hunters… Although the number of hunters using the PCA have decreased, the number of grizzly bear known and probable mortalities due to interactions with hunters increased in the last decade, primarily outside the PCA. Potential explanations for why this occurred include bears learning to seek hunter-killed game, an increase in population size and concurrent expansion of occupied range, and greater use of ungulate resources (Haroldson et al. 2004, Schwartz et al. 2010, IGBST 2013).

In other words, interactions with hunters have been an ongoing leading cause of GYE grizzly bear mortality even when the bears were protected under the Endangered Species Act. The WGFD proposed hunt will obviously and significantly increase the amount of human caused mortality and threaten the health of the GYE grizzly population.

We adamantly OPPOSE the grizzly hunt and believe it should be deferred until ALL legal challenges related to the FWS delisting decision and Conservation Strategy are resolved in court. However, if WGFD insists upon proceeding with a grizzly bear hunt in 2018, we are particularly concerned with the Mortality Limits and Quotas described in the proposed regulation’s Section 6 “Open Hunt Areas, Season Dates and Limitations.” The target number of killing up to 24 grizzly bears is too high and does not reflect reasonable and prudent caution in the first hunt after a highly disputed delisting; nor does it reflect a sincere commitment to the long-term conservation of the GYE population. In addition, the rule does NOT provide adequate management controls to ensure that no more than 2 female bears will be killed in the Greater Yellowstone Ecosystem during any one season.

Under the agreed upon quotas derived under the Conservation Strategy, Wyoming’s allotment for the number of female GYE grizzly bears that could be killed by hunters in a year is currently two (2). Despite this, the proposed hunting rule would/could allow the target number to be significantly exceeded. As written, 10 male and 2 female grizzlies (i.e., 12 bears total) could be killed in Hunt Areas 1-6; AND the rule would allow hunters to kill an additional 12 bears of any sex (as worded, “any grizzly bear”) in Hunt Area 7. Because of this, the State is very likely to exceed the overall limit of 2 female bears killed by hunters.

A much more prudent approach to an initial grizzly bear hunt, if and when the delisting litigation is resolved, would be for WGFD to establish an overall state-wide quota of no more than 12 bears killed (not 24), including no more than 2 female bears killed in TOTAL. There should be no loopholes, such as the gender indiscriminate hunting of “any bear” in Hunt Area 7, which would allow the state-wide gender quotas to be exceeded.

3) WGFD’s proposed hunt will undermine the management objectives for the Primary Conservation Area (PCA) described in the 2016 Conservation Strategy for the Grizzly Bear in the Greater Yellowstone Ecosystem[6] – The Conservation Strategy states, in part (emphasis added to underlined sections below):

  • (p. 15) Within the GYE, the grizzly bear population and its habitat will be managed utilizing a management approach that identifies a Primary Conservation Area (PCA) and adjacent areas where occupancy by grizzly bears is anticipated and acceptable. The PCA is the existing Yellowstone Recovery Zone as identified in the 1993 Grizzly Bear Recovery Plan (Recovery 16 Plan) (USFWS 1993).
  • 19-20) The vision of the Conservation Strategy can be summarized as follows: Secure habitat and population standards…will be maintained in the PCA to limit access-related disturbances and reduce human-caused mortality…Outside of the PCA, the objective is to maintain existing resource management and recreational uses and to allow agencies to respond to demonstrated problems with appropriate management actions.
  • (p. 30) Significant reductions in the human-caused bear mortality rate have been the primary reason the bear population is now meeting the demographic sub-goals established in the Recovery Plan.
  • (p. 56) The overall objective for habitat management inside the PCA is to reduce access-related disturbances and human-caused mortalities by maintaining or improving habitat with respect to 1998 conditions while maintaining options for resource management activities at approximately the same level as existed in 1998…The PCA accounts for approximately 41% of the GYE grizzly bear’s occupied range as estimated from methods of Bjornlie et al. 2014
  • (p. 60) Human activity is the primary factor negatively impacting availability and security of grizzly bear habitat in the GYE…unfettered human activity is known to result in displacement and mortality of grizzly bears and was a significant contributing factor leading to listing the grizzly bear in the conterminous U.S. as a Threatened species in 1975.

In other words, WGFD’s proposal to allow grizzly hunting within the PCA will, in fact, INCREASE (rather than decrease) “access-related disturbances” and “human-caused mortalities” within the PCA, in direct contradiction of the stated and agreed upon purposes of the PCA. As stated previously, we believe Wyoming should NOT initiate a grizzly bear hunt in 2018; however, if you decide to authorize grizzly hunting, then ALL such hunting should occur only OUTSIDE the PCA.

4) WGFD’s proposed grizzly bear hunt will undermine the management objectives for Secure Habitat described in the Conservation Strategy – The Conservation Strategy states, in part (emphasis added to underlined sections below):

  • (p. 28) History has demonstrated that grizzly bear populations survived where frequencies of contact with humans were very low. “Habitat security” REQUIRES minimizing mortality risk and displacement from human activities in a sufficient amount of habitat to allow the population to benefit from this secure habitat and respond with increasing numbers and distribution.
  • (p. 30) Mortality Reduction Efforts Related to Habitat: Significant reductions in the human-caused bear mortality rate have been the primary reason the bear population is now meeting the demographic sub-goals established in the Recovery Plan.
  • (p. 61) The Secure Habitat Standard REQUIRES that inside the PCA the percentage of secure habitat within each bear management subunit must be maintained at or above levels that existed in 1998. Secure habitat is defined as any contiguous area ≥ 10 acres in size and more than 500 m from an open or gated motorized access route (road or trail) or recurring low level helicopter line during the non-denning period (March 1 – November 30). Specific activities allowed in secure habitat that do not violate standards or count as motorized access route are listed below.
  • (p. 64) Activities Allowed in Secure Habitat – Comment: This section identifies activities that are allowed in secure habitat inside the PCA without violating the standard. It is noteworthy that grizzly bear hunting is NOT listed as an activity that is allowed inside the PCA.

In brief, WGFD’s proposal to allow grizzly hunting within the PCA will, in fact, INCREASE (rather than decrease) “mortality risk” and “displacement from human activities” in what is intended to be Secure Habitat. As a result, the hunt would inevitably degrade habitat security in direct contradiction of the stated and agreed upon Conservation Strategy objectives for Secure Habitat.

5) The WGFD proposed hunt will adversely impact grizzly bears within or near the boundaries of Yellowstone and Grand Teton National Parks – It is generally recognized that the habitat provided within the two national parks is more secure than the habitat on public lands adjacent to the parks, which is why, in part, Yellowstone NP is the core of the PCA. Despite this, WGFD’s proposed hunt targets grizzly bears along the eastern and southern border of Yellowstone and the western and southern boundary of Grand Teton National Parks. As we all know, grizzlies don’t read boundary signs and move across large distances on a regular basis; therefore, national park bears face mortal threat should hunting be allowed along park boundaries as proposed.

A 2004 study published in the Journal of Wildlife Management 68(1):129-137,Haroldson, M.A., C.C. Schwartz, S. Cherry, and D.S. Moody, on “Possible effects of elk harvest on fall distribution of grizzly bears in the Greater Yellowstone Ecosystem” stated, in part (emphasis added to underlines sections):

During the 1990s, hunting-related mortalities were the single largest source of known human-caused grizzly bear deaths in the GYE (A. Dood, Montana Department of Fish, Wildlife and Parks, unpublished data). Shifts in the distribution of our radiomarked bears were undoubtedly resource related. August through October coincides with hyperphagia (Nelson et al. 1983) in grizzly bears. During this period, bears focus on fattening in preparation for winter hibernation. Given the season, timing of shifts in bear distribution, and area of use, we believe that our analyses supports the hypothesis that grizzly bears spend more time outside YNP during the early hunting seasons and that this increased use is due to the availability of ungulate remains left by hunters. Our results clearly demonstrate that bears were at least 2 times as likely to be outside YNP during the hunt than prior to the hunt. This movement occurred independent of whitebark pine seed production…Assuming that the observed shift in the distribution of radio-marked bears reflects the distribution of unmarked bears, one could anticipate a seasonally high concentration (dispersed ecocenter) of grizzly bears associated with the early elk hunt. This shift creates a situation in which large numbers of grizzly bears are in close association with large numbers of armed humans during a season when bears are driven to forage. The management implications of our findings are clear…during the fall when bears are actively foraging and preparing for hibernation…[b]ears leave the protection of YNP and move into close proximity to hunters, which results in dead bears. Keeping human-caused grizzly bear mortality at or below sustainable limits of population size is a critical component of grizzly bear conservation.

Further complicating this concern, our members who have worked at Yellowstone or Grand Teton National Parks know there is a long history of hunting violations committed by Wyoming-licensed elk hunters along the respective park boundaries. Such violations include illegal hunting (i.e., poaching) within Yellowstone and illegal retrieval of wounded game that have been shot on or just outside the park boundary then run into the park where they ultimately die of their gunshot wounds. While hunters, not the State, are responsible for knowing where they are relative to the park boundary, these kinds of violations continue to occur.

No doubt WGFD is aware of the history of elk hunting violations along the park boundaries and, therefore, should have factored it into your grizzly hunt proposal; however, you clearly did NOT. If WGFD decides to authorize grizzly hunting along the respective park boundaries, as proposed, it is INEVITABLE that similar boundary encroachments will occur involving grizzly bear hunting violations. The impact of the proposed hunt will be that grizzly habitat will be less secure both outside and inside the park boundaries, with increased mortality risk and displacement from human activities (i.e., grizzly bear hunting) – ALL knowingly introduced onto the periphery of the parks by WGFD.

As stated previously, we are strongly opposed to a 2018 grizzly hint in Wyoming. However, if and when WGFD proceeds with a grizzly bear hunt, a prudent approach that avoids the above concerns would include some sort of “set back” from the respective park boundaries. The most appropriate and effective way to do this would be to prohibit hunting within the PCA boundaries.

6) WGFD’s proposed hunt will adversely impact wildlife viewing opportunities within Grand Teton and Yellowstone National Parks –Yellowstone and Grand Teton National Parks are world renowned wildlife viewing areas. The parks protect some of the best and last remaining habitats that shelter iconic North American wildlife species like bison, grizzly bears, and wolves. GYE grizzly bears and other “charismatic mega-fauna” are tremendously popular with the millions of park visitors who are drawn to the area every year. In 2016 alone, Yellowstone and Grand Teton combined attracted over 7.6 million visitors, who spent over $1.1 billion in the region. And that spending generated over $1.4 billion in total economic output.

Sadly, the WGFD grizzly hunt proposal gives no apparent consideration to the intrinsic, as well as economic, value of conserving this iconic species in its natural setting. Instead, it seems a capitulation to the yearning of a few to shoot a grizzly bear. Is killing grizzly bears for sport really the image of Wyoming that you want to portray to the rest of the Nation?


For all the reasons described above, the Coalition STRONGLY OPPOSES Wyoming’s proposed GYE grizzly bear hunt and believes that WGFD should hold off on issuing grizzly bear hunting regulations in 2018. If WGFD completes the Chapter 68 Regulations and insists upon implementing a grizzly hunt this year, it seems very likely the decision will be challenged through litigation. In the unlikely event that WGFD does, in fact, hold a grizzly hunt in the fall of 2018, we offer the following comments regarding the proposed regulations:

Draft Hunting Area Map[7]: The Draft Hunting Area Map and narrative descriptions in Section 9 of the proposed regulations should be revised to prohibit hunting within ALL areas of the PCA, as shown on the map (p. 17) in the 2016 Conservation Strategy. The Coalition does not have GIS mapping capability and cannot accurately overlay the PCA boundaries onto WGFD’s hunting area map. As a result, we cannot offer specific suggestions for revised descriptions of the hunting areas; however, these should be remapped, renumbered, and redescribed to indicate no hunting within the PCA. In addition, if certain portions of Grand Teton National Park are, in fact, outside the PCA, then grizzly bear hunting should be prohibited anywhere within the park including on private inholdings located within the park boundary.

Section 2. Definitions:(as written)

(e) “Grizzly Bear License Issuance List” means separate randomly generated lists of resident and nonresident applicants for a license to hunt grizzly bears during the current year in hunt areas 1, 2, 3, 4, 5 and 6, (Add>) as described in Section 9. Comment: The reference to Section 9 is necessary to ensure the reader understands where and how the hunt areas are described.

(g) (Add new definition) “Primary Conservation Area” (PCA) means the area depicted in the map on page 17 of the final approved 2016 Conservation Strategy for the Grizzly Bear in the Greater Yellowstone Ecosystem.

Then renumber subsequent definitions as follows: (h) “Processed bait” …; (i) “Prohibited bait”…; (j) “Unprocessed bait”…

Section 5. Hunting Regulations.

(a) No person shall take a grizzly bear by the use of or aid of baiting. (Strike remainder of sentence >) including any legally placed black bear bait in hunt areas 1, 2, 3, 4, 5 or 6. Baiting may be permissible in limited circumstances in hunt areas 7 and 8 and shall require a Department baiting authorization permit in accordance with Section 7 of this regulation.

Comment: Baiting grizzly bears (i.e., taking grizzly bears over bait) should NOT be allowed in ANY of the proposed grizzly bear hunting areas. Furthermore, baiting black bears should be prohibited anywhere within the Demographic Monitoring Area (DMA), as described in the Conservation Strategy, in order to avoid attracting grizzly bears to black bear bait stations. As you know, baiting black bears in grizzly bear habitat attracts grizzly bears to bait, which contributes to them becoming habituated to anthropogenic food sources and increases the chances of grizzly bear/human conflicts.

Section 6. Open Hunt Areas, Season Dates and Limitations. Comment: The two tables should be revised to reflect no more than 12 bears TOTAL to be killed in the Wyoming portion of the GYE, with no more than 10 males and 2 females to be killed. For example, this could be a limit of 1 bear to be killed in each of Hunt Areas 1-6 and up to 6 bears to be killed in Hunt Area 7, or some variation of this based on WGFD’s best professional judgment of how to apportion a 12 bear (10 male, 2 female) limit. Hunting in any area should be closed once the quota for that area is reached or once the area-wide quota of 2 females is reached.

Section 7. Baiting Authorization Permits. See comment about Section 5 above. While we understand that WGFD intends to allow recreational hunting of grizzly bears in hunt areas 7 and 8, hunters baiting bears should NOT be part of the process. If the Department determines it is necessary to remove grizzly bears in areas 7 or 8 due to depredation or grizzly bear/human conflicts, then baiting bears in the open (as opposed to inside culvert traps) should NOT be part of that process either.

Section 9. Hunt Area Descriptions. Comment: The descriptions should be revised to exclude grizzly bear hunting anywhere in the PCA and in any/all portions of Grand Teton National Park, including privately owned inholdings, which are outside the PCA.


In closing, we have numerous concerns about the WGFD grizzly bear hunting proposal. First and foremost is the concern that it is premature to proceed with a grizzly bear hunt until all issues, including appeals to the courts, pertaining to the delisting are resolved. The iconic Yellowstone grizzly bear and the American public who have long supported its conservation deserve better.

Thank you for the opportunity to comment on this important issue.


Phil Francis Signature




Philip A. Francis, Jr., Chair
Coalition to Protect America’s National Parks