Revision of the Grizzly Bear 4(d) Rule Under the Endangered Species Act

The single largest bloc in the docket (52.4% of all submissions) is an exact-duplicate form letter opening with the line “After two centuries of decline due to persecution and habitat loss, grizzly bears are just now beginning to rebound,” urging FWS to withdraw the proposal and maintain strong ESA protections until recovery and connectivity are complete. Several hundred additional comments not counted in this exact-match tally are personalized variants of the same template with an added sentence or two, showing the campaign's actual reach extends beyond the strict duplicate count.

The second-largest bloc (36.5%) centers on a specific statistic — roughly 72 known or probable grizzly deaths in the Greater Yellowstone Ecosystem in the past year, about 35% above the 10-year average — cited almost verbatim across thousands of submissions, often with a full academic citation list. The letter argues proven non-lethal tools (guard dogs, noise deterrents, secured attractants) already reduce conflict and should be prioritized over easier killing, capture, or trapping authority. This appears to have been the dominant submission pattern in the final days of July.

• J. Andrew Walsh: “grizzly bear mortality in the Greater Yellowstone Ecosystem recently reached approximately 72 known or probable deaths in a single year, roughly 35% above the recent 10-year average”

A third organized campaign, run through WildEarth Guardians' online action page (several submissions still carry the tool's raw tracking links), cites specific research on incidental trapping injuries, USGS mortality data, and habitat connectivity to argue expanded trapping-related take and state management authority will increase mortality. Many versions explicitly credit WildEarth Guardians for the cited literature.

• Lynne Gaudette: “Livestock has no legitimate place in our public lands!!!”

515 comments are brief, non-templated statements that simply ask FWS to keep grizzly bears protected, without engaging the rule's specific provisions. These are genuinely independent (not exact-duplicate or near-duplicate text) but don't offer a substantive argument beyond a general preference for the status quo.

• John Murray: “Keep existing protections in place. We are not asking for more, just keep it the same.”

155 comments make a substantive scientific case against the rule, arguing that population counts within individual ecosystems overstate true recovery because those subpopulations are not yet demographically connected — grizzlies rarely cross the human-settled valleys and highways between them. Several cite specific per-ecosystem population figures and peer-reviewed connectivity research directly.

• Avrohom Toron: “Long-term recovery depends on restoring and maintaining connectivity between the Greater Yellowstone Ecosystem and the Crown of the Continent Ecosystem in northwestern Montana.”
• Periel Stanfield: “Research has already shown that trapping for other furbearers can seriously injure or kill grizzly bears, including toe amputations and other preventable injuries.”

141 comments, largely from Montana, Idaho, and Wyoming residents (including at least one state legislator who authored grizzly-related state bills), argue the population has recovered enough that day-to-day management decisions should shift to state wildlife agencies, which they describe as more responsive to local conditions than federal bureaucracy.

• State Senator Bruce “Butch” Gillespie (Montana): “The Grizzly have been recovered for many years now and are not in any danger that I can see. Our many small towns and rural communities are exhausted from the continual surveillance necessary not to become a victim.”

131 comments belong to a long tail of smaller organized templates that didn't rise to the scale of the three major campaigns — variants arguing recovery is incomplete via numbered talking-point lists, a “Bear Smart Communities” connectivity template referencing the Tetonia mother-grizzly case, a “science not political pressure” short template, and several single-commenter repeat-submission clusters.

• Cristina Economides: “The Tetonia mother grizzly and her cubs should have been a wake-up call. Instead of strengthening federal oversight after that tragedy, this proposal would give states broader authority to lethally manage federally protected grizzly bears.”

93 comments argue the grizzly population has exceeded its original recovery targets — in some cases citing specific figures — and that continued ESA protection is no longer scientifically justified, independent of the state-management question specifically.

• Anonymous: “Please remove the protection on the grizzly bear as they have far exceeded the mandates set forth by congress, the us fish and wildlife and the endangered species act by double.”

87 comments are directed more at the current presidential administration generally than at the rule's specific provisions — criticizing Interior Secretary Doug Burgum by name, alleging the proposal serves oil-and-gas or ranching donors, or simply venting about the administration's broader environmental record. This is an unusually large and explicit political bloc for a wildlife-management docket.

• Jean Anderson: “This proposal to reduce protections for grizzly bears is not based on any science and is simply another naked attempt by this Trump administration to benefit the few at the expense of the many.”
• Genevieve Jacobi: “I would rather have 100 grizzlies on this planet than the likes of Doug Burgum and his pals.”

76 comments come from ranchers reporting escalating livestock conflict, hunters describing rising grizzly encounters in the field, and trapping/hunting advocacy organizations, all supporting the rule's added flexibility for state agencies and trapping-related incidental take.

• Aimee Hachigian-Gould (rancher, Ulm, MT): “In the past five years, the grizzly bears have moved in and we no longer see the black bears.”
• Foundation for Wildlife Management: “F4WM submits this comment in support of the proposed revision to the grizzly bear 4(d) rule, and specifically its incidental take exception for legal trapping and hunting of other species.”

72 comments oppose the rule specifically because they distrust state wildlife agencies to manage grizzlies as carefully as the federal government — citing state wolf-management records in Montana and Idaho, political pressure from ranching/hunting interests on state commissions, and the argument that migratory wildlife crossing state lines shouldn't be regulated inconsistently state-by-state.

• Katherine Vogel: “I do not have any trust in Montana State government to deal with Grizzly Bears.”
• Eric Henningsen: “The land ultimately belongs to we the people and not the states.”

56 comments cover a diverse tail of niche independent arguments that didn't cluster into a larger theme — proposed compromise positions, federal-vs-state jurisdictional arguments, climate-change framing, and personal anecdotes about specific encounters or family history with grizzlies.

48 comments belong to a smaller organized pro-rule template, mostly from Idaho and Montana trappers and hunters, supporting the rule's incidental-take exception for state-regulated trapping of other species and asking FWS to adopt a “documented harm” standard for take rather than “precautionary, speculative risk of harm,” which they say has led courts to close otherwise-lawful wolf trapping seasons.

• Anonymous: “I/We urge the service to move to a definition of take that is based on documented harm (as opposed to the current allowance of ‘precautionary, speculative risk of harm’).”

40 comments are off-topic (unrelated policy complaints, a journalist's media inquiry, healthcare policy), too short or garbled to classify, or contain no substantive text at all.

32 comments frame their opposition in explicitly religious or philosophical terms — stewardship of God's creation, the inherent right of all species to exist, or broader arguments about humanity's historical persecution of grizzly populations — rather than citing recovery science or management specifics.

• Lisa Ann Kelly and Family: “It is a shameful thing the people of this continent did, when they hunted down and decimated the populations of Grizzly bears.”

30 comments focus specifically on opposing any path toward trophy hunting of grizzlies, distinct from broader rule opposition — arguing that killing bears for sport or as photo trophies serves no conservation purpose and that a small number of well-funded hunters would benefit disproportionately from any future hunting season.

• Cindy Hatcher: “Killing hibernating animals is for cowards!!!”
• Nancy Vann: “The Safari club would love to add additional trophy hunting for grizzly bears they have been trying for years and years and now with Trump in office think they will get a green light.”

16 comments, most from organizations or attachment-bearing submissions, engage the rule's actual text line-by-line — a formal APA arbitrary-and-capricious legal argument, a wildlife nonprofit's critique invoking Montana's post-delisting wolf-management record as precedent, a farm bureau's proposed redraft language expanding defensive-take authority beyond “working dogs,” and detailed Tier 2 incidental-take critiques from conservation scientists.

• Wolves of the Rockies (Marc Cooke, President): “America's grizzly bears deserve management guided by biology, not politics.”

15 comments oppose the rule on economic grounds specific to Yellowstone-gateway communities, citing federal data showing wildlife viewing (with grizzlies as a marquee draw) generates hundreds of millions of dollars annually for local tourism-dependent economies that a hunting season or population reduction could undermine.

• Pat Erikson (Park County, MT): “Studies by the federal government itself show that wildlife viewing in the Yellowstone region drives over $580 million in annual economic activity for businesses, outfitters, guides, restaurants.”