“The Boomerang Effect”: The back and forth, relentless debate over how to effectively manage grizzly bears in the Greater Yellowstone Ecosystem (GYE) - A Comprehensive Policy Analysis of the Endangered Species Act and 2016 Conservation Strategy for Grizzly Bear in the Greater Yellowstone Ecosystem

Abstract

The intent and purpose of this document is to summarize and synthesize preceding research and analysis providing a comprehensive policy analysis of Yellowstone grizzly bears, the Endangered Species Act and 2016 Conservation Strategy for Grizzly Bear in the Greater Yellowstone Ecosystem. The goal for this document is: (a) to provide a policymakers with a complete but succinct overview and background on the Yellowstone grizzly bears, the Endangered Species Act (ESA) and the Conservation Strategy of 2016, and (b) provide convincing evidence that our proposed alternative and management recommendations are the best course of action.

Full text

“The Boomerang Effect”: The back and forth, relentless debate over how to effectively manage
grizzly bears in the Greater Yellowstone Ecosystem (GYE)
A Comprehensive Policy Analysis of the Endangered Species Act and 2016 Conservation
Strategy for Grizzly Bear in the Greater Yellowstone Ecosystem
____________________
Presented to
Dr. Shiba Kar
College of Natural Resources
University of Wisconsin - Stevens Point
____________________
In Partial Fulfillment
of the Requirements for the Degree of
Masters of Natural Resources
____________________
by
Tyler J. Brasington
December, 2020

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Table of Contents
1. Executive Summary.....................................................................................................................3
2. Introduction..................................................................................................................................4
2.1 Context...........................................................................................................................5
a. Normative.............................................................................................................5
b. Legal........................................................................................................6
c. Administrative..............................................................................7
3. Alternatives..................................................................................................................................8
4. Policy Recommendations...........................................................................................................12
5. Stakeholders...............................................................................................................................13
a. Stakeholder Elements and Categories................................................................16
5.1 Public Engagement......................................................................................................18
5.2 Power Dynamics..........................................................................................................18
7. References & Works Cited........................................................................................................20
Appendix A: Expert Interview Questions & Summary.................................................................23
Appendix B: Mortality Threshold Calculations.............................................................................28
Appendix C: Greater Yellowstone Ecosystem Maps.....................................................................30
Appendix D: Chapter 68: Wyoming Grizzly Hunting Regulations...............................................32
Appendix E: Hunting Areas per Chapter 68, Wyoming Hunting Regulations..............................35

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Tyler J. Brasington
1195 Meadowlark Lane C054
Jackson, WY. 83001
Tbras709@uwsp.edu
Title: “The Boomerang Effect”: The back and forth, relentless debate over how to effectively
manage grizzly bears in the Greater Yellowstone Ecosystem (GYE). A Comprehensive Policy
Analysis of the Endangered Species Act and 2016 Conservation Strategy for Grizzly Bear in the
Greater Yellowstone Ecosystem
Authors: Tyler J. Brasington1,2
Affiliations:
1 College of Natural Resources, Trainer Natural Resources Building, University of Wisconsin –
Stevens Point, Stevens Point, WI. 54481-3897
2 The Yellowstone Grizzly Project, Jackson, WY. 83001
www.yellowstonegrizzlyproject.org
1. Executive Summary
The Yellowstone grizzly bear population has been listed under threatened and endangered
species protections since 1975. The recovery of grizzly bears in the Greater Yellowstone
Ecosystem (GYE) is arguably one of the greatest conservation successes of our lifetime. The
population has gone from a mere 136 bears back in the 1970s to roughly 800+ individuals in the
ecosystem.
The intent and purpose of this document is to summarize and synthesize preceding research
and analysis providing a comprehensive policy analysis of Yellowstone grizzly bears, the
Endangered Species Act and 2016 Conservation Strategy for Grizzly Bear in the Greater
Yellowstone Ecosystem. The goal for this document is: (a) to provide a policymakers with a
complete but succinct overview and background on the Yellowstone grizzly bears, the
Endangered Species Act (ESA) and the Conservation Strategy of 2016, and (b) provide
convincing evidence that our proposed alternative and management recommendations are the
best course of action.
Irrefutably, grizzly bears will eventually be removed from federal protections. However, in
this analysis we ask, should the current strategy for managing grizzly bears in Grand Teton and
Yellowstone and the Greater Yellowstone Ecosystem (GYE) be adjusted to compensate for legal
harvest post-delisting? Should a discretionary harvest be permitted? Ultimately, we suggest our
proposed Alternative C, which: (a) delists the Yellowstone grizzly bear from federal protections,
(b) allows discretionary harvest, (c) no change in management strategy (d) re-evaluation of
proposed hunting units or zones. We proposed this alternative, knowing that post-delisting state

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wildlife and game agencies will be tasked with the management of Yellowstone grizzlies under
the 2016 Conservation Strategy for Grizzly Bear in the Greater Yellowstone Ecosystem. A shift
in management strategy would most likely not impact the ethics of an open season and legal
harvest. A re-evaluation in hunting units and zones will allow for managers to potentially issue
conflict or management tags on an as needed basis once further investigated.
2. Introduction
The Nixon administration established the Endangered Species Act (ESA) in 1975. Shortly
after that, Yellowstone Grizzly Bears were listed as a "threatened species" under the ESA. Since
1975, grizzlies have made leaps and bounds, going from a mere 136 individuals to well over 800
in 2020. The GYE consists of Yellowstone and Grand Teton National Parks and a handful of
national forest territory. The grizzly bear has been plagued by the "seesaw effect" in policy and
federal protections. The most recent proposal to delist the Yellowstone grizzly bear population
from the endangered species act (ESA) protections occurred during 2017, only to be relisted later
in 2018. However, previous efforts had been made to delist the bears nearly a decade prior
(2007, then relisted again in 2009). The "seesaw" effect, as we call it, will eventually cause the
endangered species act to lose "its teeth." As we lean towards a day where bears are no longer
protected, questions of values, ethics, and policy are contentious topics – set for extremely
volatile debate.
Two important policies that manage the grizzly bear populations include the Greater
Yellowstone Grizzly Bear Recovery Plan and the conservation management strategy. The
recovery plan sets parameters that must be met in order for the species to be delisted. This is how
the population is managed while under federal endangered species protections. The conservation
management strategy guides the future management of grizzly bears in the Greater Yellowstone
Ecosystem (GYE) after they have been removed from federal protections. The strategy allows
for the legal harvest of grizzly bears, which is solely determined by the state wildlife or game
management agencies of the tri-state area (Wyoming, Montana, Idaho).
However, the national parks have a long-standing management strategy and habituated
tolerance with grizzly and black bears. This strategy has allowed bears to access and use habitats
near areas of high human activity (i.e., roadsides), increasing habitat effectiveness levels
(Herrero et al. 2005). Visitors, locals, and some managers cite concerns over the ethics of a
proposed hunt on grizzly bears, especially near and on national park boundaries. An additional
concern is the enormous amount of money spent on grizzly bear conflict and management in
regions of the GYE. The potential to restructure and design a harvest that encompasses particular
conflict areas may help reach a middle ground with those opposed to a grizzly bear hunt.
In the Greater Yellowstone Ecosystem (GYE), the conservation management strategy of
grizzly bears and potential future delisting from endangered species act (ESA) protections
presents a unique opportunity to reevaluate and reassess decades-old management strategies and
practices which were conducive to a grizzly bear population in the Greater Yellowstone
Ecosystem (GYE) with zero acceptable harvests. Should the current strategy for managing
grizzly bears in Grand Teton and Yellowstone and the Greater Yellowstone Ecosystem (GYE) be

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adjusted to compensate for legal harvest post-delisting? Should a discretionary harvest be
permitted? Changing the framework within existing management and conservation plans may be
vital to promoting long term viable populations of grizzly bears while enhancing ethical aspects
of legal harvest, if and when applicable.
2.1 Context
a. Normative context: Recently, scientists (Bruskotter et al. 2018) found that the vast majority
of Americans, regardless of region or political ideology, support the endangered species act
and that the legal back-and-forth on grizzly bear delisting seemed to have no discernible
impact.
"That concern [that not delisting species hurts the Endangered Species Act] has been a
threat that has been leveled for more than a decade, and we have not seen it been proven true,"
Bethany Cotton, wildlife program director for WildEarth Guardians, an environmental group that
sued to keep grizzly bears listed.
Dan Ashe, former director for the U.S. Fish and Wildlife Service under the Obama
Administration, says that the bears have reached carrying capacity for the Greater Yellowstone
Ecosystem. "The question at this point around, about whether they [grizzly bears] should be
delisted, is more of a values-based question. Ashe cites that delisting is more about questioning
the ethics behind trophy hunting, and less about the endangered species act. Ultimately, injecting
the conversation surrounding values into the delisting process fuels the fire for many that the
Endangered Species Act is a broken piece of natural resource policy.
A common political approach and conservative viewpoint of the Endangered Species Act
is that the policy is mostly flawed; animals listed are rarely delisted successfully. The history of
the Endangered Species Act, spanning 45-years, less than two percent of species that have been
listed have been successfully recovered, delisted, and removed. However, it is essential to note
that the process of successful conservation takes an extremely long time. Many professionals and
scientists agree that it is incredibly unreasonable to think a species would recover in a few mere
decades.
Moreover, much of the criticism does not recognize the incredible success of the act's
primary goal: preventing extinction. Close to 99% of species listed under the act are still in
existence today. The longer the bears stay unnecessarily listed under federal protections, the
more animosity and tension will build. For example, during 2010, a budget rider stripped
endangered species protections from grey wolves in their home states, creating a relatively
unpopular and perilous precedent.
Most professionals agree that unnecessarily keeping species [grizzlies] under federal
protections will inherently force people and politicians to search for political answers. The
controversy is not surrounding the endangered species act itself but broadly applies to trophy
hunting and post-delisting management of grizzly bears by the tri-state (Montana, Wyoming,
Idaho).

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b. Legal Context: In 1975 the grizzly bear was listed as a threatened species in the lower
contiguous 48-states under the Endangered Species Act (ESA) with an estimated population
of approximately 136 bears remaining in the wild. In total, the grizzly bears range decreased
to nearly two percent of its historic habitat in the lower 48. According to the ruling under the
Endangered Species Act, grizzlies were listed as "threatened," making it "unlawful to kill,
capture, harm, harass, import, or export a grizzly bear anywhere in the lower 48 states, or to
sell any parts or products of grizzlies in interstate or foreign commerce." (Mott & Burnham
2019). However, notably and unbeknownst to most, one exception allowed sport hunting in
Northwest Montana as long as no more than 25 bears were killed annually through either
management removal or hunting. The ruling states the most critical factor in the grizzly's
decline and recovery as conflicts with humans (Mott & Burnham 2019).
In 1982, the U.S. Fish and Wildlife Service enacted the National Grizzly Bear Recovery
Plan; they revised the plan in 1993. "The grizzly bear is a symbolic and living embodiment of
wild nature uncontrolled by man. Entering into grizzly country represents a unique opportunity –
to be part of an ecosystem in which man is not necessarily the dominant species." (USFWS,
1993). The document modifications include formalizing the six different ecosystems for grizzly
bears, which include: Great Yellowstone Ecosystem, Northern Continental Divide Ecosystem,
Bitterroot Ecosystem, North Cascades Ecosystem, Selkirk Ecosystem, and Cabinet-Yaak
Ecosystem. The Recovery Plan specifies how grizzly bears will be managed when protected
under federal endangered species protections.
In 1983, the Interagency Grizzly Bear Committee was established. This committee was
formed to oversee grizzly bear management. It consisted of state, federal, and tribal stakeholders
directly involved in the management, research, and monitoring of grizzly bears in the Greater
Yellowstone Ecosystem (GYE). (Mott & Burnham 2019; IGBC 2020)
It was not until 2005 that the U.S. Fish and Wildlife Service considered the Yellowstone
grizzlies a distinct population segment. In 2005, the number of grizzly bears in the Greater
Yellowstone was higher than 600. U.S. Fish and Wildlife Service proposed removing
endangered species protections for GYE bears, stating that they are recovered. (Mott & Burnham
2019) Post-2005, the see-saw effect with federal protections began. In 2007, the Yellowstone
grizzlies were removed from the Endangered Species list. Nearly 194,000 public comments
preceded this action.
However, in 2009, the delisting was overturned. In a 46-page decision, a federal judge
ruled that the U.S. Fish and Wildlife Service did not consider the impacts of the potential loss of
whitebark pine due to climate change (whitebark pine is a critical food resource for grizzly bears
which have access within their home ranges; it provides nearly 30% fat, one of the highest
sources of fat bears may obtain naturally in the wild). (Mott & Burnham 2019) The Conservation
Management Strategy (USFWS 2016) specifies how bears will be managed after delisted from
federal endangered species protections.
In 2014, special regulation and policy were enacted, allowing for conflict management of
grizzly bears; 4(D) Rule (50 CFR 17.40).

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Again, in 2017, the Yellowstone grizzlies were delisted from the endangered species list.
Wyoming finalized a hunt for up to 10 grizzly bears to be harvested in the state's core habitat and
12 to be harvested in other areas. Once a female is killed in the core habitat, no other harvest is
allowed in that area. In Missoula, federal hearings placed the bears back under federal
endangered species protections and stopped the planned trophy hunt in Wyoming and Idaho
during 2018.
c. Administrative Context: There are various state, federal, and tribal administrative agencies
involved in grizzly bear recovery. The administrative agencies and organizations involved
include the following:
1. Interagency Grizzly Bear Committee (IGBC) -Established to help facilitate recovery
of viable grizzly bear populations and their habitat in the lower 48 through interagency
coordination, policy, planning, management, and research. IGBC has yielded proficiency
and success in their model for working collaboratively and in cooperation over multiple
jurisdictions coordinating recovery efforts (consists of members listed in 3-9) (IGBC
2020)
2. Interagency Grizzly Bear Study Team (IGBST) – The IGBST is an interdisciplinary
group of scientists and biologists tasked with long-term monitoring and research efforts
for grizzlies in the Greater Yellowstone Ecosystem. The IGBST serves as the technical
and science advisor to the Interagency Grizzly Bear Committee (IGBC) and its
Yellowstone Ecosystem Subcommittee (YES); however, the IGBST is not a voting
member of either committee (consists of members listed in 3-9). (IGBST 2020)
3. U.S. Fish and Wildlife Grizzly Bear Recovery Team National Park Service
4. U.S. Forest Service
5. Wyoming Game & Fish Department – one of three state management agencies that
will oversee the management of grizzly bears once they have been delisted from
endangered species protections; they currently assist in the statewide management of
conflict and research members of both the IGBC and IGBST.
6. Idaho Fish & Game - one of three state management agencies that will oversee the
management of grizzly bears once they have been delisted from endangered species
protections; they currently assist in the statewide management of conflict and research
members of both the IGBC and IGBST.
7. Montana Fish, Wildlife & Parks - one of three state management agencies that will
oversee the management of grizzly bears once they have been delisted from endangered
species protections; they currently assist in the statewide management of conflict and
research as a member of both the IGBC and IGBST.
8. Eastern Shoshone & Northern Arapaho Tribes, Wind River Fish & Game – native
tribes will have full control over how grizzly bears are managed on their lands post-
delisting from federal protections. Native tribes also have representatives and members
for the IGBC and IGBST.

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3. Alternatives
[1] Re-evaluating proposed hunting zones and units for grizzly bear harvest in the Greater
Yellowstone Ecosystem (GYE): During the last attempt to delist grizzlies from endangered
species act (ESA) protections, bears were successfully delisted for nearly 1-year. During this
time, Chapter 68 (WYGF 2018) was developed by Wyoming Game and Fish for Grizzly bear
Hunting Seasons. This provided guidance and instruction to the authority in Wyoming State
Statute to authorize a grizzly bear hunt, provided definitions and outlined grizzly bear licensing
and issuance list specifics, with calculated allowable mortality per hunt area. The state of
Wyoming had the most developed and comprehensive plan for a grizzly bear hunt within the tri-
state area (Wyoming, Montana and Idaho). They designated eight hunting zones (units)
permitted for grizzly bear harvest. Collective female mortality was set at (1) bear and not to
exceed (1); collective male mortality was set at (10) and not to exceed (10) for hunt areas 1-6.
Hunt areas 7, 8 may harvest a total of (12) grizzly bears (any sex) (WYGF 2018) (see Appendix
D).
Regulations for the proposed hunt included that hunters could not take/harvest a grizzly bear
with the use or aid of dogs, snares or traps, and no hunter may take any grizzly bear with
dependent young. There are strict reporting procedures for when a grizzly bear is harvested. No
baiting is permitted in areas 1-6. However, the department may issue authorization permits for
bear baiting in areas 7, 8 if it is determined to meet management objectives and prevent
depredation or present grizzly bear-human conflict.
The regulations set forth by Wyoming Game and Fish (WYGF) establish harvest/allowable
mortality for hunt areas 1-6 (inside the defined demographic monitoring area) and hunt areas 7, 8
(outside the demographic monitoring area). However, in total each year, the budget for grizzly
bear recovery spends nearly $2.2 MIL on conflicts (relocation, removal etc.) out of a budget of
approximately $3.4 MIL (USFWS 2016) annually. The opportunity to increase harvest limits, or
take for high/special conflict areas could be evaluated as a potential alternative to hunting inside
the demographic monitoring area. A re-evaluation of whether tags and permits could be issued
on the grounds of conflicts in given units, accompanied by acceptable harvest, could provide a
useful tool in helping improve public support, and moral, simultaneously reaching the middle
ground (see Appendix D).
A large portion of the general public is outraged and torn over a potential trophy hunt for
Yellowstone grizzly bears. A potential alternative to “management removals” of bears by
wildlife managers, would be allocating harvest tags to local landowners for designated
“management harvest” tags. Specific provisions could be in place for use/waste laws (hunter
would have to use the animals meat, hide) The money generated by the tags could go back into
the state wildlife fund, or it could be placed in the livestock loss fund (compensate livestock
owners who lose cattle, sheep throughout the year). Re-evaluating the current breakdown of
hunting units and zones, wildlife managers would be given the opportunity to distribute conflict
permits/tags to residents and landowners in known high conflict areas which have grizzly bear
issues (property damage, livestock depredation) to harvest grizzly bears. Incorporating

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management harvest tags as a means to remove conflict bears without expending tax dollars for
relocation, removal through wildlife management agencies would save state agencies money.
[2] Management Shift from Habituated Tolerance Strategy in Grand Teton and
Yellowstone National Park: Prior to 1970, bears were food conditioned in Yellowstone, often
begging for food handouts from visitors on the roadsides. In 1970, Yellowstone National Park
developed a new bear management strategy in an attempt to prevent bears from obtaining
anthropogenic foods and garbage (Meagher & Phillips 1983). Nearly a decade later (1979) most
bears that were food conditioned had been removed from the park. However, in the 1980s, park
staff encountered another problem: as populations of grizzly and black bears increased, along
with rising visitation, bears were foraging in nearby roadside meadows, habituated to people, but
not food conditioned (Gunther & Wyman 2008; Haroldson & Gunther 2013). Initially the park
responded with zero tolerance, and these bears were hazed, trapped, or relocated away from the
roadside areas. Their efforts failed, and habituation was not prevented. In 1990 the park
developed their new strategy (Gunther et al. 2015) which focused on habituated tolerance; park
personnel were regularly deployed to manage “bear jams” or vehicles and people at the roadsides
stopping to view the bears. In the national parks, visitors must remain 100 yards or greater away
from bears and wolves. This directly plays into the strategy: remaining consistent with viewing
distances is important with specific regards to maintaining a predictable and frequent exposure to
human presence, and not creating an unpredictable situation which may instigate or enhance the
potential for an innate behavioral flight/fight response.
In the national parks, where development is minimized, food storage is strictly enforced by
park personnel, and there is no hunting, grizzly and black bears may flourish even with the
highest human densities (Gunther et al. 2015). The fact that grizzly bears and black bears can
survive in such high human densities, speaks to their opportunistic lifestyles, behavioral
plasticity, adaptability and intelligence (Gunther et al. 2015). The behavioral component of
adaptability, which is interesting yet concerning surrounding future delisting, is habituation. In
general, habituation refers to the waning or diminished innate flight response to people
(McCullough 1982; Jope 1985). The reduction in the bears innate flight response, makes
habituation an adaptive behavior through a means of conserving energy (McCullough 1982;
Smith et al. 2005). The national parks represent a place where there are hundreds of thousands if
not millions of people that visit annually. The strategy of habituated tolerance works in national
parks because of the frequent, and predictable exposure to humans on a regularly occurring basis.
However, it presents ethical concerns if discretionary harvest is permitted with heavily
habituated bears inhabiting the fringes of the national parks.
With these two factors in mind, we developed four separate alternatives for continued effective
management of grizzly bears in the Greater Yellowstone Ecosystem (GYE):
1. Alternative A: Delist Greater Yellowstone Ecosystem grizzly bears and allow harvest with a
change in management strategy [1] and re-evaluation of hunting zones and units [2].
Under this alternative, Yellowstone grizzly bears would be delisted from federal protections
and management would be turned over to the tri-state area (Wyoming, Montana, Idaho). A shift
in management strategy, away from habituated tolerance in the National Parks would take place

10
accompanied by a re-evaluation of hunting units and zones, so managers may accommodate
management, and high conflict areas for additional permits/tags.
[1] The current management strategy of habituated tolerance may be an ethical and
ecological dilemma with bears residing close to or on our national parks' boundary. However, the
number of bears that are habituated near and around the park boundaries and fringes are limited.
In Yellowstone National Park alone, roads make up less than one percent of the total park area.
The potential to harvest a habituated grizzly bear is possible, however, not widespread.
[2] Re-evaluating the current breakdown of hunting units and zones, wildlife managers
would be given the opportunity to distribute conflict permits/tags to residents and landowners in
known high conflict areas which have grizzly bear issues (property damage, livestock
depredation) to harvest grizzly bears. Incorporating management harvest tags as a means to
remove conflict bears without expending tax dollars for relocation, removal through wildlife
management agencies would save state agencies money.
2. Alternative B: Delist Greater Yellowstone Ecosystem grizzly bears and allow harvest with a
change in management strategy [1] and no re-evaluation of harvest zones or units [2].
Under this alternative, Yellowstone grizzly bears would be delisted from federal protections
and management would be turned over to the tri-state area (Wyoming, Montana, Idaho). A shift
in management strategy, away from habituated tolerance in the National Parks would take place
accompanied by no re-evaluation or changes to hunting units and zones.
[1] The current management strategy of habituated tolerance may be an ethical and
ecological dilemma with bears residing close to or on our national parks' boundary. However, the
number of bears that are habituated near and around the park boundaries and fringes are limited.
In Yellowstone National Park alone, roads make up less than one percent of the total park area.
The potential to harvest a habituated grizzly bear is possible, however, not widespread. A change
may provide enhanced ethical perceptions of legal harvest amongst the general public
[2] Without re-evaluating the current breakdown of hunting units and zones, wildlife
managers would not be given the opportunity to distribute conflict permits/tags to residents and
landowners in known high conflict areas which have grizzly bear issues (property damage,
livestock depredation) to harvest grizzly bears. No management harvest tags as a means to
remove conflict bears would mean state wildlife and game agencies would continue operations
as normal, with relocations and removals performed by state officials.
3. Alternative C (proposed): Delist Greater Yellowstone Ecosystem grizzly bears and allow
harvest with no change in management strategy [1], but changes and re-evaluation of harvest
zones and units [2].
This is the most preferred policy alternative. Under this alternative, Yellowstone grizzly
bears would be delisted from federal protections and management would be turned over to the
tri-state area (Wyoming, Montana, Idaho). No shift in management strategy in the National
Parks would take place (habituated tolerance strategy will continue) accompanied by a re-

11
evaluation of hunting units and zones, so managers may accommodate management, and high
conflict areas for additional permits/tags.
[1] "Visitor surveys indicate that if bears were no longer allowed to stay along with roadside
habitats, spending in the local economy by Park visitors could decrease by about $10.1 million,
resulting in a loss of 155 jobs. Results from a nonmarket valuation survey question indicate that,
on average, visitors to Yellowstone National Park are willing to pay around $41 more in Park
entrance fees to ensure that bears are allowed to remain along roads within the park."
(Richardson et al., 2014). The current management strategy of habituated tolerance may be an
ethical and ecological dilemma with bears residing close to or on our national parks'
boundary. However, the number of bears that are habituated near and around the park boundaries
and fringes are limited. In Yellowstone National Park alone, roads make up less than one percent
of the total park area. The potential to harvest a habituated grizzly bear is possible, however, not
widespread.
Considering the economics, if the management strategy were to change, a significant impact
on local economies would be felt, and decreases and staffing cuts within the National Parks
would follow. This is why it is preferred that no shift away from habituated tolerance.
[2] Re-evaluating the current breakdown of hunting units and zones, wildlife managers
would be given the opportunity to distribute conflict permits/tags to residents and landowners in
known high conflict areas which have grizzly bear issues (property damage, livestock
depredation) to harvest grizzly bears. Incorporating management harvest tags as a means to
remove conflict bears without expending tax dollars for relocation, removal through wildlife
management agencies would save state agencies money.
In this specific alternative, to account for ethical concerns for the potential harvest of a
habituated grizzly bear, managers would enact a safe zone buffer on the boundaries of
Yellowstone and Grand Teton National Park. This would further reduce the chance of a
habituated grizzly bear being harvested during a hunt.
4. Alternative D: Delist Greater Yellowstone Ecosystem grizzly bears and not allow acceptable
harvest [1], no change in management strategy [2], and no necessity to re-evaluate or
consider hunting zones and units [3].
This is the least preferred policy alternative. Under this alternative, Yellowstone grizzly
bears would be delisted from federal protections and management would be turned over to the
tri-state area (Wyoming, Montana, Idaho). No harvest would take place and no shift in
management strategy in the National Parks would take place. In addition, no re-evaluation or
changes to hunting units and zones.
[1] No legal harvest for grizzly bears would be permitted under this alternative. While this is
appealing to anti-delisting stakeholder groups (p. 13) it would further breed resentment and
create a larger divide amongst all stakeholder groups. However, post-delisting, no legal harvest
would be a directive coming from state wildlife and game agencies, not the federal government.
Allowing acceptable mortality at the discretion of the tri-state area is contentious. Acceptable

12
and allowable mortality may increase resentment, and lack of social tolerance towards bears, and
lead to increased cases of poaching, and illegal take (Treves 2009).
[2] "Visitor surveys indicate that if bears were no longer allowed to stay along with roadside
habitats, spending in the local economy by Park visitors could decrease by about $10.1 million,
resulting in a loss of 155 jobs. Results from a nonmarket valuation survey question indicate that,
on average, visitors to Yellowstone National Park are willing to pay around $41 more in Park
entrance fees to ensure that bears are allowed to remain along roads within the park."
(Richardson et al., 2014). The current management strategy of habituated tolerance may be an
ethical and ecological dilemma with bears residing close to or on our national parks'
boundary. However, the number of bears that are habituated near and around the park boundaries
and fringes are limited. In Yellowstone National Park alone, roads make up less than one percent
of the total park area. The potential to harvest a habituated grizzly bear is possible, however, not
widespread.
[3] There are other methods to the management of large carnivores and apex predators which
do not utilize lethal removal as a battering ram to handle conflict. Previous reviews and scientific
literature demonstrate that scientific measures of public support for carnivore-hunting policies
are almost completely lacking. This is particularly true in terms of measuring attitudes among
hunters and sportsman. Importantly, previous data has shown that illegal killing and poaching of
large carnivores does not diminish or become reduced if they are designated as a game species
(Treves 2005, 2009).
Without re-evaluating the current breakdown of hunting units and zones, wildlife managers
would not be given the opportunity to distribute conflict permits/tags to residents and landowners
in known high conflict areas which have grizzly bear issues (property damage, livestock
depredation) to harvest grizzly bears. No management harvest tags as a means to remove conflict
bears would mean state wildlife and game agencies would continue operations as normal, with
relocations and removals performed by state officials.
4. Policy Recommendations
Based on our evaluation, we recommend ‘Alternative C: Delist Greater Yellowstone
Ecosystem grizzly bears and allow harvest with no change in management strategy, but changes
and re-evaluation of harvest zones and units.’
With everything considered, grizzly bears in the Greater Yellowstone Ecosystem have
met all the recovery criteria set forth by the U.S. Fish and Wildlife Service for now over a
decade. Seeing that only two percent of species listed under federal endangered species
protections are delisted, I think it is essential to consider that (a) conservation takes time, but (b)
that if the species is recovered and near or at carrying capacity, we are doing the species and
policy disservice by not taking appropriate action. However, social intolerance of large
carnivores (i.e., grizzlies and wolves) is vital to recognize and address. Some research even
indicates that hunting or imposing harvest limits and seasons may exacerbate social intolerance,
poaching, and illegal take (Treves & Laundre 2020)

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The proposed course of action for Greater Yellowstone Ecosystem grizzlies should entail the
following:
[a] The U.S. Fish and Wildlife Service proposes delisting the species from endangered
species protections. U.S. District Court approves the motion after judicial review
[b] Tri-state area assumes control of grizzly bear management and enacts a plan for legal
harvest of grizzly bears. Harvest totals are based on population monitoring and metrics
gathered via the Interagency Grizzly Bear Study Team (IGBST). Cumulative allowable
mortality at 22 grizzly bears in the entire area (Wyoming). Collective female mortality set
at (1) bear and not to exceed (1); collective male mortality was set at (10) and not to
exceed (10) for hunt areas 1-6. Hunt areas 7, 8 may harvest a total of (12) grizzly bears
(any sex) (WYGF 2018). Additional mortality may be included as a provision [d]
- Refer to Chapter 68 of Wyoming Hunting Regulations (see Appendix D)
[c] The National Park Service continues the current habituated tolerance management
strategy
[d] Tri-state wildlife and game agencies re-evaluate previous hunting zones and units,
looking at high conflict areas, where additional conflict tags or permits may be allocated
or distributed
[e] Tri-state area and the National Park Service design a safety zone buffer around the
National Parks boundaries to account for ethical concerns for the potential harvest of a
habituated grizzly bear (Yellowstone and Grand Teton National Park). This would further
reduce the chance of a habituated grizzly bear being harvested during a hunt.
5. Stakeholders
When the U.S. Fish and Wildlife Service first proposed the formal action to delist the
Yellowstone population of grizzly bears from federal endangered species protections,
stakeholder participation in the entire delisting debate increased. Eliminating federal oversight
for grizzly bear management in the Greater Yellowstone Ecosystem (GYE) was concurrent with
an intensifying worry from some groups & scientists about the direct and indirect consequences
of climate change on species' and species' habitats. Previous research has indicated that climate
change's ecological impacts have been documented (Parmesan & Yohe, 2003; Parmesan, 2006;
Intergovernmental Panel on Climate Change, 2007).
Stakeholder groups would include but are not limited to the following: Public (visitors to
national parks and national forests), Outfitters & Guides (sporting guides/hunting), tourism
guides (wildlife), property owners/residents, agricultural operations (cattle, sheep, etc.), natural
resource managers (National Park Service, Bureau of Land Management, U.S. Forest Service,

14
U.S. Fish, and Wildlife Service, Wyoming Game and Fish, Idaho Fish & Game, Montana Fish,
Wildlife & Parks), political parties & representatives (Senators and Representatives)
Main interests, including values, goals, positions, and preferred policy direction for achieving
goals:
[1.] Public (visitors to National Parks & National Forests): Research has demonstrated that
'protection-use' and 'appreciation' orientations are useful in predicting hunting, fishing, and
wildlife viewing participation (Fulton et al., 1996)
Protection-use orientation is strongly correlated with attitudes and intentions via
wildlife management proposals (Bright, Manfredo & Fulton, 2000; Manfredo & Fulton,
1997; Manfredo et al., 1998, 1999; Manfredo & Zinn, 1996; Whittaker, 2000). Research
implies that utilitarian value orientations are associated with more drastic responses to
wildlife (e.g., destroying nuisance wildlife, hunting for urban wildlife, and wildlife
trapping). Research led by Manfredo & Zinn (1996) suggests that the U.S. public is
moving away from this traditional, utilitarian focus and becoming more protection-
oriented concerning wildlife.
Theory and empirical research suggest that progressing affluence and education
(Inglehart, 1997), urbanization (Bell, 1973; Hays, 1987), and diminishing residential
security (Eriksen, 2001; Smith, 1997) initiative value shift. A shift from materialist
values (focused on physical security and economic well-being) toward post-materialist
values (focused on the quality of life, self-expression, and self-esteem). Prognostication is
that these changes in societal-level conditions have also initiated a gradual shift away
from traditional wildlife value orientations, emphasizing the use and management of
wildlife for human benefit. These results should be viewed as preliminary; only six states
were included in the analysis and did not represent a random sample of all the United
States or all the states in the western region of the U.S.
[2.] Outfitters & guides (Sheep USA, Safari Club International, Ohio Sportsman): pro-delisting
[3.] Tourism guides (Snowmobile Alliance of Western States, The Wild Side LTC., EcoTours,
BrushBuck Wildlife Tours, Jackson Hole Wildlife Safaris, Buffalo Roam Tours, Yellowstone
Tours, WolfWatcher, Grizzly Country Wildlife Adventures): pro & anti-delisting
[4.] Property owners/residents: (Town of Wilson, Jackson, Teton Village, Moose, Moran,
Colter Bay, Flagg Ranch, Blackrock, Hoback, Lander, Pinedale, Cody, Island Park, Powell,
Gardiner, Jardine, West Yellowstone, etc.)
[5.] Natural resource managers (National Park Service, Bureau of Land Management, U.S.
Forest Service, U.S. Fish, and Wildlife Service, Wyoming Game & Fish, Idaho Fish & Game,
Montana Fish, Wildlife and Parks): pro-delisting

15
[6.] Environmental Advocacy Groups (Sierra Club, Earth Justice, Natural Resources Defense
Council (NRDC), Defenders of Wildlife, Humane Society of the United States, Grizzly People,
Alliance for the Wild Rockies, Greater Yellowstone Coalition): anti-delisting
[7.] Political parties (Liz Cheney, John Barrasso, Mike Enzi, Steve Daines, Jon Tester, James
Risch, Mike Crapo, Greg Gianforte, Mike Simpson, Russ Fulcher, etc.): pro-delisting
[8.] Agricultural Operations and Groups (National Cattlemen's Beef Association, Wyoming
Farm Bureau Federation): pro-delisting
[9.] Private environmental/academic research groups, institutions (Craighead Environmental
Research Institute, Teton Institute, Universities (Wyoming, Montana, Idaho, etc.): anti-delisting
Rhetoric amongst stakeholders falls into three main categories: authority, ethics,
and identity (Parker & Feldpausch-Parker, 2013). Most arguments directly relying on this
rhetoric were responsible and contributed to unfavorable communication between stakeholder
groups. These various rhetorical strategies define belief systems within stakeholder groups and
further elucidate exclusionary customs. Overall, rhetorical analyses can further expand preferred
social control frameworks specific to individual stakeholder groups.
Stakeholder comments were categorized into 12 elements within the three main rhetoric
categories:
[A] Authority –
[1] Government or policy reform
[2] Purpose of the Endangered Species Act (ESA)
[3] Authority or distrust of authority
[4] Science or research
[5] Global climate change
[B] Ethics –
[1] Issues with mortality
[2] Stewardship
[3] Environmental ethics
[C] Identity –
[1] Public sentiment
[2] National pride or icon
[3] Schism of environmentalists
[4] Resource use
[A][4] Authority concentrates on the continuum between knowledge providers and decision-
makers; notions of authority are primarily descended from social frames and beliefs about how
society should be managed (Peterson, 2003).
Anti-delisting groups feel that the potential adversarial impacts surrounding
climate change on the grizzly bear population bolster and further advance their argument
to keep bears listed under federal protections. On the contrary, pro-delisting groups do

16
not bring climate change to the table and fail to mention; legitimacy and authority are
afforded to science given its reputation being an objective source for information (Parker
& Feldpausch-Parker, 2013).
[B][1,3] Ethics is agreed upon as the good that leads to a demand in action (Critchley, 2007).
Specifically pertaining to Yellowstone grizzly bears, this means preventing the
unnecessary mortality of female grizzly bears and their cubs or promoting conservation
tenets. Pro-delisting groups, such as cattle ranchers, want to actively engage in species
recovery efforts, as opposed to being forced to change the way they handle their herds
"because of federal mandates." However, anti-delisting groups argue that ESA
protections are critical to grizzlies because of violations of personal, organizational code
of environmental ethics.
[C][1,3] Identity is categorized explicitly by a sense of unity with other "fellow humans"
(Peterson, 1997) and a means to which humans identify themselves within society (Feldpausch-
Parker et al. 2009).
Definitions of how people identify themselves may arise from their occupation,
recreational activities, socioeconomic status, and political affiliation.
Anti-delisting groups view themselves as defenders of the unblemished remnant
wilderness. Pro-delisting groups identified themselves as either wildlife advocates within
the system's realm, which is outlined by the managing authority, or proponents for human
livelihood and well-being over non-human species.
[a] Stakeholder Elements & Categories
Authority: Government/policy reform, the purpose of ESA, authority or distrust,
science/research, global climate change
Anti-delisting groups viewed the ESA as a tool implemented and executed to recover and
protect endangered and threatened species until all threats had been depreciated or even
eliminated (to include future threats, i.e., climate change). Research conducted by Parmesan &
Yohe (2003) indicates that climate change modifies global ecosystem parameters and locations,
directly reshaping wildlife & other species' critical habitat. Anti-delisting groups also declared
that pro-delisting groups ignored the climate change factor in their proposals to delist the
Yellowstone grizzly from federal protections. The decision made by the U.S. Fish and Wildlife
Service failed to consider the changes of climate [natural or anthropogenic]. The criteria for
delisting have been met; however, the argumentative question is how climate change will impact
the long-term recovery for grizzly bears in the GYE.
Pro-delisting groups view or believe that the ESA's purpose was to recover threatened
and endangered species under current present threats. Grizzly bears have met recovery criteria,
so, therefore, they were a candidate for delisting. This does not include any reference to future or
potential threats such as climate change. Anti-delisting groups yielded a preference for control

17
frameworks, which would allow for higher levels of public participation and involvement in
management and policy decision-making (Peterson, 2003). Ironically, anti-delisting groups
supported the hierarchical framework and authority by indicating that USFWS has expertise in
grizzly bear management. However, they rejected the agency's authoritative push for grizzly
delisting; this indicated their egalitarianism beliefs (Parker & Feldpausch-Parker, 2013). Pro-
delisting groups had a hybrid of preferences; some were partial to deregulated, individualistic
strategies for managing natural resources. Others took point in hierarchical control structures,
which exhibit more dependence on the authority of technical expertise.
Ethics: Issues with mortality, stewardship & environmental ethics
Arguments over ethical considerations were also a critical component in the grizzly
delisting debate. There were arguments for preserving ecosystem functions and species diversity
on one side of the aisle and humanity's need for increasing and additional space on the other.
Environmental ethics between stakeholder groups varied to the highest degree. Anti-delisting
groups' ethical foundations were principally formed from the belief that stewardship of grizzly
bears in the ecosystem was predominantly distinguished by preventing grizzly bear mortality and
protecting grizzly habitat. Pro-delisting thinking was the more dominant outlook; active
management was seen as critically important and should allow humans and users to utilize the
land and its resources. However, this was not a universal belief amongst all pro-delisting
stakeholder groups (Parker & Feldpausch-Parker, 2013).
Identity: Public sentiment, national pride/ icon, a schism of environmentalists, resource use
Nature was commonly intertwined and synonymous with stakeholders' identities or
perceptions of themselves. For instance, grizzly bears were not just bears but rather an iconic
depiction of national strengths, individualism characterizing American ideals (Clarke, 1999).
Resource-use advocates, including agriculturists affiliated with pro-delisting groups, most
regularly identified themselves in the "text-based" on their livelihoods or preferred recreation;
they pushed for social control that would give the upper hand to local or state governments over
federal control. Anti-delisting groups and the remaining few pro-delisting groups shared
common identities as either conservation or preservationists, supporting the decision-making
process, yet disagreeing on the end decision (Parker & Feldpausch-Parker, 2013).
To its end, anti-delisting groups saw grizzly bear recovery as inadequate and
fragmentary. Pro-delisting groups argued the contrary, that the bear was fully recovered under
the laws of the U.S. government and that recurrent review of grizzly bear status post-delisting
would prevent a decrease or decline in population. The requisite discrepancies at hand between
stakeholder groups are less about grizzly bears and their management and more about western
U.S. land management policies, which the great bear is only a fraction and part.
The debate of delisting cannot be settled simply by listing or delisting the species alone;
it rests in the hands of policymakers and those with decision making authority to assure that they
manage other essential and associated related conflicts (i.e., oil and gas exploration, timber
extraction, private property rights). Concurrently, these issues should be acknowledged, along

18
with delisting, so that policymakers may maximize stakeholder "buy-in" for grizzly bear
management (Parker & Feldpausch-Parker, 2013).
5.1 Public Engagement
Pro and anti-delisting groups exhibited diverse views of authority, contending social
frames; their beliefs about what constitutes a legitimate decision-making process. Many
stakeholders challenge the USFWS not as a scientific entity or authority but as an authority
figure in the decision-making process. Also, stakeholders dissent on the idea of grizzly delisting,
in succession with the interpretation, understanding, and veracity of the information on
population estimates and the pertinence of climate change. The interpretation and the purpose of
the Endangered Species Act (ESA) were ferociously debated amongst stakeholder groups.
Anti-delisting groups tend to push for higher public participation levels and involvement in
management and policy decision-making (Peterson, 2003). Pro-delisting groups had a blend of
preferences; some were partial to deregulated, individualistic strategies for managing natural
resources. Others took point in hierarchical control structures, which exhibit more dependence on
the authority of technical expertise.
5.2 Power Dynamics & Disputes
The delisting debate surrounding the Yellowstone grizzly is similar to other
environmental issues (O'Connell-Rodwell et al., 2000; Treves et al., 2002; Brook et al., 2003) as
it manifests an apparent and stringent division between environmental conservation groups and
other interest groups and organizations (agriculturists, production-oriented advocates (Clarke,
1999). A preponderance of the differences and dispute exist from varying interpretations and
understanding of available scientific data and the underlying and overarching purpose of the
Endangered Species Act (ESA) (Parker & Feldpausch-Parker, 2013).
The resulting public pressure and ruthless stakeholder rhetoric differentiate belief systems
amongst involved groups and suggest exclusionary practices (Moore, 1993; Clarke, 1999; Clark,
2001). Typically, problems surrounding endangered species conflicts are generally complex,
displaying varieties of tension; freedom, individuality, tradition, and culture form the very
framework for these differences (i.e., view of public v. private property; the role of traditional
land-use ethics; wise-use v. aesthetic valuation of nature) (Moore, 1993; Peterson, 1997;
DeLuca, 1999). Among the most divisive and polemical tensions is individual belief about
legitimate decision-making [social component] (Peterson, 2003).
Often, stakeholders present absolute fidelity and loyalty to their views and beliefs
encompassing social constructs and arrangements, which often limits and serves as an
instantaneous detriment to group cooperation and problem-solving amongst other stakeholders
(Hamilton, 2004). In order to obtain ground and expedite the management of such conflict
situations, a cooperative and conducive environment is required, where stakeholders accept their
opponents as legitimate and their ideas relevant (Mouffe, 2000). Interestingly, endangered

19
species debates sometimes pit the species in question at the center of the debate, when in reality,
it is genuinely human-human conflict at the leading cause of cultural, economic, and
environmental riffs and convergent management objectives (Moore, 1993; Marshall et al., 2007).
Additional conflict may also arise from such a wide-ranging perspective of symbolism. There is
a particular local perception of inequality due to local stakeholders enduring decision-making
and policy implementation ramifications at the national level (i.e., predator conservation and
management strategies) (Dickman et al., 2011).
An ecosystem wildlife management specialist believes there are existing tensions between
involved [stakeholder] groups. Some groups have broken relationships with the federal
government, interacting and getting along better with the state agencies [wildlife management].
“At the same time, other groups ask more for us to be involved. The stemming distrust and
brokenness exist with a lack of open communication with these groups; if we actively listened
and engaged more with these user groups, we may see a difference in perceptions.” They also
believe we can do better about communicating with these various stakeholder groups. When
asked how can resource managers and wildlife management specialists bridge the gap between
science and the public? They replied “more effective means of communication; better outreach
and active listening [actually hearing what is being said] does not just go in one ear and out the
other. Getting on the general public level and establishing sound and meaningful relationships
with stakeholders involved in the management and other decision-making processes.”

20
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Greater Yellowstone Ecosystem. U.S. Government Printing Office.
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Greater Yellowstone Ecosystem. U.S. Government Printing Office.
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in Wyoming Hunting & Fishing Regulations 2018. State of Wyoming.

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Appendix B: Mortality Threshold Calculations

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Appendix C: Greater Yellowstone Ecosystem Maps
Figure 1: Map of the Greater Yellowstone Ecosystem (GYE) outlining the Primary Conservation Area
(PCA), Demographic Monitoring Area (DMA), National Forests, National Parks and National Wildlife
Refuge. In addition, the hashed area on the map represents grizzly bear distribution during the year 2014.

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Figure 2: Map of the Greater Yellowstone Ecosystem (GYE) outlining the Distinct Population
Segment (DPS) boundary, Primary Conservation Area (PCA), food storage order areas, Forest
Service, and National Park Service land.

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Appendix D: Chapter 68: Wyoming Grizzly Hunting Regulations
Section 5. Hunting Regulations.
(a) No person shall take a grizzly bear by the use of or aid of baiting, 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.
(b) No person shall take a grizzly bear by the use of or aid of dogs.
(c) No person shall take a grizzly bear with a trap or snare.
(d) No person shall take a grizzly bear through the use or aid of radio telemetry equipment.
(e) Hunters may take any grizzly bear except dependent young and female grizzly bears with
dependent young
(f) Reporting Grizzly Bear Harvest. Licensees harvesting a grizzly bear in hunt areas 1, 2, 3, 4, 5
and 6 shall report the harvest of a grizzly bear within twenty-four (24) hours of harvest with a
Department provided electronic device unless the licensee properly registers their harvest within
twenty-four (24) hours in accordance with this section. The Department provided electronic
device shall allow the licensee the ability to report their harvest, hunt area, sex of grizzly bear,
licensee’s name and telephone number. A grizzly bear harvest shall not be considered reported
until the licensee receives a Department acknowledgement of their harvest report.
(i) Licensees harvesting a grizzly bear in hunt area 7 or 8 shall report their harvest of a grizzly
bear to the Department by calling 1-800-264-1280 within twenty-four (24) hours of harvest
unless the licensee properly registers their harvest within twenty-four (24) hours in accordance
with this section. The licensee shall provide the date and time of harvest, hunt area, sex of the
grizzly bear, licensee’s name and telephone number.
(g) Registering Grizzly Bear Harvest. Licensees harvesting a grizzly bear shall retain the pelt and
skull from each grizzly bear harvested for registration purposes. Even if the skull is damaged, it
shall accompany the pelt. Visible external evidence of the sex of the grizzly bear shall remain
naturally attached to the pelt. Within five (5) days after harvesting a grizzly bear, the licensee
shall present the pelt and skull to a district game warden, district wildlife biologist or Department
personnel at a Department Regional Office during business hours for registration. The pelt and
skull shall be presented in an unfrozen condition in order to allow collection of up to two (2)
premolar teeth and to allow examination of the pelt to determine the sex and possible lactation
status of the grizzly bear. The Department may also collect biological samples at the time of
registration.
(h) Any person who provides false information when reporting the harvest of a grizzly bear, or
any person who makes a false statement on a grizzly bear registration form shall be in violation

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of this regulation and such violation shall be punishable as provided in Title 23, Wyoming
Statutes for violation of Commission regulations.
(i) Licensed grizzly bear hunters shall take a mandatory orientation and training course on
grizzly bear ecology and management prior to entering the field to hunt grizzly bears. The course
shall be provided by the Department.
(j) Electronic harvest reporting devices shall be returned to the Department at the time a licensee
registers their harvested grizzly bear with the Department or at the close of the grizzly bear
season in accordance with Section 6, whichever comes first.
(k) Licensed grizzly bear hunters shall not take grizzly bears within onequarter (1/4) mile of
Wyoming State Highways 22, 28, 120, 131, 296, 352, 353 and 390 or U.S. Highways 14, 16, 20,
26, 89, 191, 212 and 287 within hunt areas 1, 2, 3, 4, 5 and 6.
(l) Surrender of Electronic Radio Tracking Device. Any person taking a grizzly bear wearing an
electronic tracking device shall surrender the device to the Department in accordance with
registration requirements in Section 5 (g).
Section 6. Open Hunt Areas, Season Dates and Limitations.
(a) Grizzly bear license issuance list hunt areas, season dates and limitations.
(b) Licensees for hunt areas 1, 2, 3, 4, 5 and 6 may hunt any of these hunt areas provided that
individual hunt area is open. Hunt areas 1, 2, 3, 4, 5 and 6 shall have a collective female
mortality limit of up to one (1) female grizzly bear and up to ten (10) male grizzly bears.

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(c) In hunt areas 1, 2, 3, 4, 5 and 6 the total number of licensed hunters in the field shall not
exceed the available collective female mortality limit as specified in Section 6 (a).
(d) In hunt areas 1, 2, 3, 4, 5 and 6 the grizzly bear hunting season shall close in each separate
hunt area when the individual hunt area mortality limit is reached. Hunt areas 1, 2, 3, 4, 5 and 6
shall all close when the collective female mortality limit is reached, the collective male mortality
is reached or on the date specified in Section 6 (a), whichever comes first.
(e) Valid in that portion of Area 2 north of U.S. Highway 26-287 and east of the following:
Where the Turpin Meadow Road (U.S.F.S. Road 30050) meets U.S. Highway 26-287 at
Fourmile Meadow; northerly and westerly along said road to the Box Creek Trailhead; northerly
along the Box Creek Trail (U.S.F.S. Trail 038) to the Enos Lake Cutoff Trail (U.S.F.S. Trail
041); westerly along said trail to the Pacific Creek Trail (U.S.F.S. Trail 036); southwesterly
along said trail to the Gravel Creek Trail (U.S.F.S. Trail 042); northerly along said trail to the
Wolverine Cutoff Trail (U.S.F.S. Trail 029); northerly and westerly along said trail to the Coulter
Creek Trail (U.S.F.S. Trail 029W); northerly along said trail to the Wolverine Creek Trail
(U.S.F.S. Trail 029N); northerly and westerly along said trail to the Yellowstone National Park
boundary. Also valid in that portion of Area 2 west of Grand Teton National Park and the John
D. Rockefeller Jr. Memorial Parkway.
(f) Grizzly bear limited quota hunt areas, season dates and limitations.
(g) Currently, grizzly bears do not occupy hunt area 8. Unused licenses for hunt area 7 may be
available for use in hunt area 8 upon Department notification and written authorization should
grizzly bears occupy this hunt area.

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Appendix E: Hunting Areas per Chapter 68, Wyoming Hunting Regulations
Figure 3: Map of hunting areas in Wyoming as specified by Chapter 68 of Wyoming Hunting
Regulations. Red areas indicate hunting zones 1-6, located within the Demographic Monitoring
Area (DMA). Zones 7-8 are yellow/no-color, hashed, and located outside of the DMA

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Figure 4: Map of hunting areas in Wyoming as specified by Chapter 68 of Wyoming Hunting
Regulations. In addition to specified hunting areas, this map overlays the known 2014
distribution of grizzlies in the Greater Yellowstone Ecosystem (GYE) and identifies the “fringe”
of distribution. Red areas indicate hunting zones 1-6, located within the Demographic
Monitoring Area (DMA). Zones 7-8 are yellow/no-color, hashed, and located outside of the
DMA.