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

The single largest fact about this docket: 4,299 of 5,000 comments (86%) share one exact-duplicate block of boilerplate text opposing the 4(d) revision, almost certainly distributed as a mail/action-alert template by a conservation advocacy organization. Treated here as one organized voice, not 4,299 independent ones - the raw 'oppose' percentage is a function of this single campaign's reach, not 4,299 separately-considered positions.

• Shared campaign text: “After two centuries of decline due to persecution and habitat loss, grizzly bears are just now beginning to rebound in the United States. I am very concerned about proposed changes to the 4(d) protections...”

A separate, smaller templated letter - a numbered list arguing recovery is incomplete, populations remain genetically isolated, and management should stay federal - was submitted by 20 different commenters with exact or near-exact matching text, distinct from the primary 4,299-comment campaign.

• Shared campaign text: “1. Recovery is incomplete. Grizzly bears still occupy only a small fraction of their historical range in the contiguous United States... 2. Populations remain genetically isolated.”

Six comments explicitly state that supporting literature was added to the administrative record by WildEarth Guardians, a conservation advocacy group, before making the same substantive opposition argument - a visible, self-identified organizing effort distinct from the two anonymous templated campaigns above.

• FWS-R6-ES-2024-0186-76723: “Literature cited in this comment has been added to the administrative record by WildEarth Guardians. Grizzly bears are important to the environment, and they need protection.”

The largest bloc of independently-written comments: brief statements from residents of Montana, Idaho, and Wyoming supporting the rule change, most citing personal encounters with a recovered or overabundant grizzly population and arguing management belongs with the states that live alongside it.

• FWS-R6-ES-2024-0186-76192: “I support the delisting of the grizzly bear. I live in Montana and see them while hunting... hunt them, not all of them but some, so we can install a natural fear of humans into them.”

Longer letters making the same case with more evidence - rising human-bear conflict statistics, population figures exceeding recovery targets, and in at least one case a formal letter from a hunting/trapping advocacy organization endorsing the revision outright.

• Foundation for Wildlife Management: “The Foundation for Wildlife Management (F4WM) submits this comment in support of the proposed revision to the grizzly bear 4(d) rule.”

Brief, individually-worded comments opposing the change, generally on the grounds that recovery remains incomplete or that state management would open the door to unrestricted trophy hunting.

• FWS-R6-ES-2024-0186-76199: “It's bad enough that we are allowing the destruction of wild Mustangs and now the Grizzly is going to be destroyed by blood thirsty hunters? Leave our wildlife alone.”

Substantive individual letters opposing the revision - citing habitat connectivity gaps between grizzly ecosystems, slow reproduction rates, legal/procedural objections, and distrust that state agencies will resist political pressure from hunting interests.

• FWS-R6-ES-2024-0186-77223: “I am writing to express my strong opposition to the proposed revisions to the Section 4(d) rule under the Endangered Species Act (ESA).”

A smaller group didn't take a clean side - supporting some provisions while opposing others, backing conflict-management tools while rejecting trophy hunting specifically, or endorsing the rule's direction while asking for additional safeguards.

A handful of comments didn't take a clear position on the rule itself - process questions, media interview requests, comment-period extension requests, and a few off-topic or garbled submissions.