Have the grizzly bears of the Greater Yellowstone Ecosystem recovered enough to leave the protection of the Endangered Species Act? The U.S. Fish and Wildlife Service certainly considers that to be the case. Last week the agency declared “the successful recovery of one of the nation’s most iconic animals” and proposed removing the bears from the list of threatened species.

Conservation groups immediately objected. The Center for Biological Diversity called the move a “betrayal” and said it was “premature” to change the bears’ protected status. WildEarth Guardians accused the FWS of “attempting to evade its duty to protect imperiled wildlife on behalf of all Americans.” The Sierra Club said delisting would reverse any gains that the bears have had in recent decades. GOAL Tribal, an association of Native American tribes and groups, was perhaps the most critical, calling the move a giveaway to rich, white hunters.

So where does the truth lie? Well, the grizzlies of Yellowstone are certainly better off today than they were 40 years ago, when the population was estimated at just 136 bears. Today the official count is 717 grizzlies. That’s definitely a success. According to FWS the bears have also dramatically increased their territory and now occupy a range of more than 22,500 square miles.

But those numbers may not tell the whole story. The current population estimate is about 6 percent below that from 2014, when there were 757 grizzlies in the Greater Yellowstone Ecosystem, and birth rates have been stable for the past decade. FWS says the population stability and the increase in territory are both because grizzlies have reached their “carrying capacity” in Yellowstone and the ecosystem will not support any additional bears.

That, however, leaves out some of the threats the bears currently face. As discussed during a panel last week at the Public Interest Environmental Law Conference in Eugene, Ore., grizzlies’ main food sources are all on the decline. That’s most evident when it comes to whitebark pine nuts, a source of high-fat nutrition that is under threat from invasive mountain pine beetles. Bonnie Rice, campaign representative for the Sierra Club, said during the panel that the bears’ dispersal and increasing territory may be because they are seeking additional food such as ungulates, something that puts them in direct conflict with local hunters and ranchers.

Whitebark pine trees have been in trouble in the Yellowstone region for several years. In fact, that’s why grizzles ended up back on the Endangered Species list in 2011 after they were first removed back in 2007. After several rounds of legal courses, the courts ruled that the threat to grizzlies’ food was not considered when they were first delisted.

Healthy pine populations are essential for grizzlies, Rice said during the panel. The more nuts a female bear has to eat, the more cubs she’ll produce. Meanwhile, the presence of this high-elevation food source keeps bears in remote areas away from people, decreasing the likelihood of human-animal conflict.

Rice said the ecological changes currently happening in Yellowstone are occurring too quickly to make a rush judgement that the bears are now recovered. With supplies of other bear food sources—including army cutworm moths and cutthroat trout—also disappearing, Rice said she worries we may be seeing just the tip of the iceberg and that we may need a decade or more to understand the trends that are just starting to emerge today.

Meanwhile, the move to delist the Yellowstone grizzles could face another round of legal challenges. As Kelly Nokes of WildEarth Guardians pointed out during the panel, a 2014 court case found that the FWS only has the legal authority to remove an entire species from the Endangered Species List, not a distinct population segment like the one in the Yellowstone region.

Nokes also said that delisting could hamper any efforts to improve connectivity between the Yellowstone bears and the additional 800-1,000 grizzlies that live in the Northern Continental Divide or the fewer than 50 bears that live in the Cabinet-Yaak region. Neither of those populations would lose their protections under FWS’s proposal.

That might change. Andrea Santarsiere, an attorney with the Center for Biological Diversity, said she expects the Continental Divide bears to face their own delisting challenge in the near future. She also pointed out that the FWS’s own 2011 status review said the agency should be looking for new sites in which to reestablish grizzly populations, something the agency does not appear to be doing at all right now. (FWS said it expects the two populations to connect naturally “in the near future” through dispersals and other movements, and some bears have indeed made the journey, but the panelists pointed out that none of them have been females.)

All of the conservation groups expressed fear that grizzly hunting would quickly follow on the heels of any delisting decision. Declaration of hunting seasons would be up to the states of Idaho, Montana and Wyoming. FWS said “discretionary mortality” of grizzlies would not be allowed if the population dropped below 600.

FWS obviously put a lot of work into its proposal—the document is 223 pages long—but there’s a lot of science missing in all of this. We don’t know how bears’ food will fare in the future or why their population growth has truly stabilized. We also don’t know if 600-700 bears are enough to maintain their genetic diversity, especially if there is no connectivity with the populations to the north.

What do you think? Should grizzlies in Yellowstone keep or lose their protected status? The public now has 60 days to make their case. Comments may be submitted at regulations.gov by searching for Docket Number FWS–R6–ES–2016–0042.


Previously in Extinction Countdown: