Comment from McBee, Karen

Literature cited in this comment has been added to the administrative record by WildEarth Guardians. I strongly oppose the U.S. Fish and Wildlife Service's proposed revisions to the grizzly bear 4(d) rule. Rather than strengthening recovery for a species that remains listed as threatened under the Endangered Species Act, the proposal would weaken federal protections, expand opportunities for grizzly bear "take," and shift greater management authority to states before recovery has been achieved. The proposed expansion of allowable take is particularly concerning. The USFWS should not permit take that occurs as a result of trapping for other species, which is already a documented threat to grizzly bear conservation (Lamb et al. 2022; McKim 2017). The proposal would also expand state authority over take associated with grizzly bear "management," including conflicts with livestock. Conflict with livestock is already one of the leading causes of grizzly bear mortality, and granting states broader discretion to authorize take in these situations is likely to increase deaths rather than reduce conflict (USGS 2024). In the Greater Yellowstone Ecosystem, the past several years have already set records for grizzly bear mortality related to livestock (USGS 2025). Increasing allowable take under these circumstances is inconsistent with the goal of recovering the species. This proposal also comes at a time when grizzly bears face mounting threats to their habitat. The administration's intent to rescind the Roadless Rule and its rescission of the Endangered Species Act's habitat-based "harm" protections both threaten to increase habitat degradation and fragmentation (Mattson 2024-1). Reducing protections for individual bears while simultaneously weakening protections for the habitat they depend upon moves recovery in the wrong direction. The proposal would further undermine recovery by shifting greater management authority to states that have repeatedly demonstrated hostility toward grizzly bear conservation. Connectivity between isolated grizzly populations is essential for long-term recovery, yet Montana's own grizzly bear management plan states that the state would "not actively manage for grizzly bear presence between core areas." Those landscapes between core populations are precisely where management is most needed to restore a connected metapopulation. Transferring greater authority to states without requiring them to facilitate connectivity will undermine recovery (Mattson 2021). The proposal is also too vague to allow meaningful public participation. It leaves critical decisions about what forms of grizzly bear take will ultimately be authorized to future agreements between the USFWS and individual states. Without knowing what those agreements will contain, the public cannot meaningfully evaluate or comment on the proposal's likely impacts. Finally, there is little evidence that allowing more grizzly bears to be killed will improve public acceptance of the species. Research instead suggests that increasing legal killing does not increase social tolerance and may actually reduce it (Mattson 2020). Studies of other large carnivores have also found that expanding legal killing can be associated with increased poaching rather than reduced illegal mortality (Chapron and Treves 2016). For all of these reasons, I urge the U.S. Fish and Wildlife Service to withdraw this proposal and retain strong federal protections for grizzly bears until the species has achieved true recovery across a connected landscape.