Public Comment on 5-Year Status Review of the Grizzly Bear

PERC weighs in on the listing status of the grizzly bear

NPS/Eric Johnston

The Fish and Wildlife Service has initiated a 5-year status review of the grizzly bear, which is currently listed as a threatened species under the Endangered Species Act. Today, PERC is submitting the following comment on the status of the bear, focusing on the Greater Yellowstone Ecosystem population of grizzlies in particular.

PERC respectfully submits this comment for the Fish and Wildlife Service regarding the initiation of a 5-year status review of the Grizzly bear (Ursus arctos horribilis) in the conterminous United States, currently listed as a threatened species under the Endangered Species Act. … This comment draws on recent PERC research on grizzly bear recovery and management, including testimony before the House Natural Resources Committee and a brief filed with the U.S. Court of Appeals for the Ninth Circuit.

This comment focuses on the Greater Yellowstone Ecosystem grizzly population and addresses the five factors considered during a Fish and Wildlife Service listing evaluation. The agency determined in a 2017 final rule and reaffirmed in a 2018 regulatory review that “the GYE grizzly bear population has recovered to the point at which protection under the [Endangered Species Act] is no longer required. The best scientific and commercial data available indicate that the GYE grizzly bear [distinct population segment] is not endangered or threatened throughout all or a significant portion of its range.” Delisting the GYE population would recognize the significant efforts by federal biologists, states, tribes, conservation groups, and private citizens to recover the population and allow for continued conservation efforts without the potential deterrent of federal regulation.

Even if the grizzly were considered on a species-wide basis, rather than as several distinct population segments (the approach that the Fish and Wildlife Service has taken in previous delisting efforts and that this comment assumes the agency will take again), the Greater Yellowstone Ecosystem and Northern Continental Divide Ecosystem grizzlies would merit a change in status. A tailored 4(d) regulation could provide incentives for states, landowners, and others to continue recovery efforts for these populations. With such a rule, the Fish and Wildlife Service could provide nearly the same level of regulatory relief for landowners that would come from delisting but with significantly less litigation risk. A tailored 4(d) rule, therefore, could maintain protections for vulnerable populations while also providing stakeholders with incentives to continue recovery efforts for the GYE and NCDE populations.

Read PERC’s full public comment on the grizzly status review.

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