Notes on Summer's End, News in Wildlife Managment

3rd of September, 2023

Hello, and welcome to Keystone Wildlife Coalition's first newsletter. My name is Gunnar Nemeth, a co-founder of KWC, and I'm absolutely honored to be writing to you all today. If you are new to Keystone Wildlife Coalition, welcome! We are a wildlife conservation group founded in Montana, focused on protecting Keystone Species in their natural habitats from the threats of poaching, illegal trapping, and harassment.

The objective of these newsletters will be about KWC's recent activities and plans for the future while providing coverage of wildlife management news in the United States and worldwide. I will offer my analysis and opinion on all of these developments. This newsletter is longer than I would like, and future editions will be much shorter than this.

Since KWC's founding earlier this year, our small team has worked tirelessly to curate organization relationships, plan direct-action field operations, and register as a 501(c)(3). Soon, we will be expanding our project capacity to include more frequent and comprehensive media coverage.

Held v. Montana

The biggest news in US environmental management happened here in Montana, where 16 youths won a monumental case against the state to protect their right to a healthy environment. The ruling applies to state operations in which they must consider the impact of fossil fuels and minimize contributions to climate change. This ruling by Judge Kathy Seeley in the First Judicial District Court of Montana should set a statewide precedent and possibly a national one in favor of the environment.

Held v. Montana brought national public awareness to Article IX of the Montana Constitution, in which the Article reserves the right to a clean and healthful environment for all residents. While this ruling directly addresses the state's pro-fossil fuel legislation, we hope conservationists can also use it to protect wildlife.

You can read more about the decision and the possible implications at Our Children's Trust, which helped bring the case to court. You could also read news releases by the Montana Wildlife Federation or the Montana Free Press.

National Park Service Draft EIS and Bison Management Plan

In early August, the National Park Service released a Draft Environmental Impact Statement (EIS) for the Bison Management Plan within Yellowstone National Park. You can find information with Yellowstone NP's release, the NPS Planning, Environment & Public Comment (PEPC) site, or you can read the entire document for yourself here. It is 149 pages long, so I apologize in advance for any misunderstandings I might have while working through it. I know these propositions could change how the Yellowstone Bison herd is managed in Wyoming and Montana for the foreseeable future.

The participating agencies are the Montana Governor's Office, the Department of Livestock (DOL), and Montana Fish, Wildlife and Parks. The federal agencies following the lead of Yellowstone NP are the Animal and Plant Health Inspection Service (APHIS) and the US Forest Service (Custer Gallatin NF). There is an Indigenous perspective involved with this project, as the InterTribal Buffalo Council, Confederated Salish and Kootenai Tribes of the Flathead Nation, Nez Perce Tribe, Confederated Tribes of the Umatilla Indian Reservation, and the Yakama Nation are all named.

We welcome more indigenous insight and co-stewardship practices in ecological management, especially with the bison management program. No animal in the United States is controlled quite like the American Bison, so hopefully, the participating tribes will facilitate beneficial change in the governance practices.

The fact that these organizations created this EIS suggests these groups admit to the mismanagement of buffalo in some way. Otherwise, there would be no need to go through this lengthy process. In one of the introductory paragraphs, it is written:

"The purpose of the plan is to preserve an ecologically sustainable population of wild, migratory bison while continuing to work with partners to address brucellosis transmission, human safety, and property damage and support tribal hunting outside the park."

I think adding "migratory" into the document language is highly significant, as the original management plan, the Interagency Bison Management Plan (IBMP) adopted in 2000, did not address the natural migration of buffalo and did not accommodate their movements. This addition implies respect for the animal's natural behavior, so hopefully, the management plan will allow for it.

Bison Management Alternatives

The EIS proposes alternatives, including the no-action option, which includes no-change and no-project variations, and two alternative plans. The first choice is not really an alternative; it is a continuation of the current management program or a slightly smaller scope of operations. If that option is selected, we will continue to see the devastating mismanagement of buffalo in and outside of the National Park.

I doubt anyone can honestly claim the IBMP is the best choice for management or even relevant to the issues faced 23 years on. This mismanagement is easily exemplified by the brutal removal of nearly a third of the entire Yellowstone herd population in just one season, the winter of 2022-2023.

The other options for bison management aren't necessarily ideal either. As the document states: "Under all alternatives, the NPS would continue to meet the main goals of the IBMP." This means the agencies involved will continue to haze and capture wild bison inside park boundaries for shipment to slaughter. They continue;

"The NPS does not anticipate using vehicles or helicopters to haze bison within the park, but Montana could use a helicopter if it deems it necessary to move bison back to the park."

Hazing by helicopter was previously off-limits. Video footage was released in 2012 of federally-funded helicopters disturbing a Grizzly Bear, which the federal government protected under the Endangered Species Act.

But with Montana delisting the grizzly, the most recent Montana FWP Commission meeting, and US Senator Jim Risch (R-ID) introducing a bill that would fully delist grizzly bears in the lower 48 from ESA protections, it seems grizzlies and buffalo alike have difficult times ahead.

Listed as Alternative 2 for Bison Management, NPS would give more responsibility to the tribes using the Bison Conservation Transfer Program (BCTP) for the "acceptable" reduction of the buffalo herd through hunting, or capture and relocation to tribal lands. If the NPS does not believe animals are being killed or relocated, they could raise or lower the removal quota. It's unclear to me how this will all be determined. The document goes on;

"This alternative would prioritize treating bison more like other ungulates, such as elk in the Greater Yellowstone Area (GYA), which also have been exposed to brucellosis but are not subject to intense disease management like bison. Captures of bison for shipments to slaughter would immediately cease, with natural selection and public and tribal hunter harvests outside the park in Montana being the primary factors limiting bison numbers."

That is from Alternative 3, which is perhaps the best choice offered. This option has some positives, with the prioritization of NPS working closer with the tribes possibly being the most critical aspect. The immediate cease of shipments to slaughter must be a good thing. However, despite that supposed intent, there seems to be a catch;

"If higher bison numbers threaten the efficacy of management efforts to keep them in the existing management areas, even with more hunting opportunities, the NPS would reinstitute shipments to slaughter and the use of other tools as described for Alternatives 1 and 2."

From that excerpt, it appears that special interests are valued higher than others, and I don't think the buffalo or the tribes are included. So, despite the posturing to "allow" the tribes to manage the buffalo population, I believe the NPS and the state of Montana added this clause to reserve the final say in the matter. Hopefully, the state agencies would afford more trust to tribal management than I am giving to them.

This document has plenty more, as the previous paragraphs only briefly highlighted sections of the first fifty-some pages. But I will continue my analysis at a later date. The National Park Service is taking public comments on this. There will be two virtual public meetings soon, and you can find more information on how to attend at the NPS website found here. Make your voice heard!

Montana Fish, Wildlife, and Parks Commission Meeting

Montana FWP Commission held its August meeting on a wide variety of topics. You can watch it in its entirety here. The agenda included the killing regulations of Keystone Species such as Gray Wolves, Grizzly Bears, and Mountain Lions under the guise of management practices. This meeting was an unsurprising assortment of bureaucracy and passion, with important decisions being made and lots of educated wildlife conservationists providing incredible insight. Unfortunately, none of them were the ones making decisions. Two of the seven Commissioners "could not attend" the meeting; FWP gave no reasons for their absence.

Public seating was packed with people who took time out of their busy lives to attend: conservationists, Montana residents, organizations, educators, and even some livestock ranchers. But while the public was overwhelmingly in support of wildlife, the motions passed, and the amendments added by the Commission seem to aim for the near-eradication of multiple Keystone Species, with the support from a select few trappers, ranchers, and hunters.

For some context, Montana has already stripped Gray Wolves of ESA protections.

Here is what Montana FWP proposed for wolf management this time:

• An unchanged quota of 100 wolves in increments of 25, for wolves that may be taken by a landowner at any time without the purchase of a wolf license when the wolf is a potential threat to human safety, livestock, or dogs

• Maintaining the floating start date for wolf trapping in areas with grizzly bears

• Rename "Trapping Districts" to be called "Regions"

• "The statewide wolf population is being reduced as directed by the legislature. To facilitate a measured reduction over time, quotas are recommended at the average harvest levels from the last five years, which is 289 wolves distributed statewide."

As an organization, KWC finds this motion inappropriate for properly managing or conserving wildlife and the environment. As an individual, I find these propositions vile, cruel, and frankly disgusting. Legislation passed by the Montana Senate led the FWP into adopting inhumane and inconsiderate management practices for most species of wildlife, especially wolves.

The laws mostly favor livestock ranchers and small sections of the hunting community, such as poachers or trophy hunters. It appears to me the state of Montana fully endorses the killing of innocent wolves, bears, big cats, and other treasured wildlife despite the overwhelming amount of public outrage to these ends.

Wolf and Grizzly ARMs

The Commission then discussed the Administrative Rules of Montana (ARM) concerning wolf control methods and the grizzly management policy. The wolf discussion was short, as the motion was to slightly change the wording for more administrative flexibility in the future. The Montana legislature is specifically instructing FWP under Senate Bill 295 (SB 295), which begins to remove protections under the Endangered Species Act and calls for the reduction of the population through a quota system and at the discretion of livestock owners.

Public comments were heavily against the motions. With the wolf ARM, public comments pointed out that the Commission should only be moving forward with any changes to wolf management with an advisory committee. This committee would be a diverse group of interested parties: Montana residents, conservation groups, hunting associations, and state agencies.

This kind of advisory structure is afforded to other wildlife species in Montana and certainly afforded to wolves in different states. Asking for an advisory committee was not an extreme request of Montana FWP.

Comments surrounding the grizzly motion called out the litany of issues; the qualification that bears only need to be "threatening" towards a rancher's livestock without defining what "threatening" actually means. These livestock ranchers will be shooting or trapping grizzly bears on public land!

Wildlife belongs to the public. The land technically belongs to the public. However, ranchers can now use their discretion to kill a Keystone Species that the Endangered Species Act previously protected. The motion passed with the slight amendment that these ranchers must demonstrate implementing non-lethal methods before resulting in lethal action. The amendment is better than nothing, but there are rumors that this may be changed or removed entirely.

Wolf Hunting and Trapping Season

Now the highly controversial 'Fall 2023 – Winter 2024 Furbearer and Wolf Trapping and Hunting Seasons and Quotas'. This motion called for the hunting, trapping, and snaring of 289 wolves statewide, distributed as follows;

• Region 1 – 120 wolves

• Region 2 – 91 wolves

• Region 3 – 52 wolves

• Region 4 – 15 wolves

• Regions 5, 6, 7 - 5 wolves

• Wolf Management Unit 313 - 6 wolves

The commissioners amended that to increase the quota to 300 wolves, with 11 more wolves targeted in Region 1. Another amendment passed was that individuals who harass wildlife by aircraft shall be fined not more than $5,000 or imprisoned not more than one year, or both. So, the Commission not only increased the quota for wolves killed, but also reduced the punishment for those that break the law regarding wolf hunting.

The public was passionate about all this, with dozens of individuals and organizations speaking out against Montana's cruel political management of wolves. The counting method for the wolf population in Montana (iPOM or integrated patch occupancy mode) was called out for being unreliable and possibly overestimating the actual wolf population within the state.

Comments also pointed out to the Commission that wolves and wolf-watching bring in an estimated 85 million dollars to the Montana economy, while the small percentage of Montanans that actually participate in this slaughter bring in around $300,000. That small percentage also spoke at this meeting; trappers associations, livestock ranchers, and cruel-hearted individuals all applauded the FWP Commission's plan to murder wolves at an astounding rate.

Despite almost two and a half hours of public comments, with an overwhelming majority calling for increased protections for the gray wolf in Montana, the Commission disregarded practically all public concerns. It approved the killing of hundreds of wolves this upcoming winter.

I could continue about developments in wildlife management in Montana, but I won’t. If you have the time, keep an eye out for these important upcoming dates and check out these articles about other recent developments.

1. Thousands of people and organizations call on the Biden Administration to fully restore the Endangered Species Act. Article by Western Watersheds Project

2. Mountain Lions in Utah will now be able to be hunted and trapped in Utah year-round under a new law. Article by the Mountain Lion Foundation

3. A new pack of Gray Wolves have been spotted in California’s Sierra Nevada. Article by the Nevada Wildlife Alliance

4. Conservationists sound the alarm that only four collared wild Mexican Gray Wolves survive in México. Press Release by Center for Biological Diversity, Western Watersheds Project, and WildEarth Guardians

5. Red Wolves are increasingly under threat in North Carolina, one was shot and killed recently. Article by Kristen Johnson at The News & Observer

KWC's Future Projects

Now to discuss Keystone Wildlife Coalition's plans for the upcoming months. Some of KWC's projects will include the transportation of wildlife between sanctuaries and rehabilitation centers. We have already worked with sanctuaries to place animals across the western US. We will assist in evacuations or emergency rescues on an as-needed basis. KWC also plans to increase its social media presence, with more news media coverage, and expand its educational resources. We will write summaries and analyses of new management plans shorter than this. We will also partner with wildlife photographers and videographers to raise awareness on social media platforms!

KWC will participate in field operations with trained teams on Habitat Supervision and Poaching Discouragement Missions to protect threatened species in target areas with a high density of illegal activity. These operations carry risk, as we will directly oppose hunters implementing illegal methods and straight-up poachers. We will always protect, conserve, and advocate for wildlife. No matter the opposition. As stated in the Keystone Wildlife Coalition Values;

"Courage - We are devoted to the execution of necessary duties, often in the face of adversity, uncertainty, or jeopardy."

Now, these ideas are all well and good, but we can only do this with support from individuals, communities, and other like-minded organizations. Once KWC is registered as a 501(c)(3) non-profit with the state of Montana and the IRS, we will be open for tax-deductible financial donations. We will offer one-time donation and monthly subscription options, with benefits such as early access to newsletters, personal appreciation messages from our staff, and merchandise. Very soon, the inventory will be available online, including t-shirts, hats, stickers, and more!

I don't want to get everyone too excited, but we are developing plans for a KWC benefit festival within the following year. We will have live music performances, great food, sponsor vendors, games, silent auctions, and more!

In the meantime, please share this newsletter with your friends, family, and anyone else who might find it interesting. Follow us on Instagram, Facebook, TikTok, LinkedIn, or any other social media site! Please explore our website and subscribe to our mailing list to hear about KWC updates, wildlife management news, calls to action, and special events.

Thank you all for your support, and until next time, I wish you all the best,

Gunnar Nemeth,

Co-Founder & Director of Communications