Amended GWA's Comments on Custer Gallatin National Forest Draft Revised Forest Plan

August 13, 2019


Forest Plan Revision Team

Gallatin National Forest All Units

P.O. Box 130, Bozeman, MT 59771


The Gallatin Wildlife Association would like to have these additional comments be considered as an addendum to those previously submitted on June 1, 2019. In the matter of the Custer Gallatin National Forest Draft Revision Plan and the associated Draft Environmental Impact Statement, the Gallatin Wildlife Association will continue to be engaged, bringing forth a solution to preserve the wildlands and wildlife of the Custer Gallatin National Forest. We realize the formal comment period closed June 6, 2019, but also realize that the Custer Gallatin National Forest will accept public comments throughout this period of review. Specifically, we would like to readdress our previously submitted comments on the matter of moose being considered as a Species of Conservation Concern. This addendum will provide additional information in that regard highlighting the seriousness of that request and providing new scientific information supporting our claim to place moose on the list as a Species of Conservation Concern.


Recently, two articles based upon the same reporting by the Associated Press have found themselves in the OregonLive version of the Oregonian1 and in the Jackson Hole News and Guide2 paper of Jackson, Wyoming. Their links are located here.


Both papers have the Associated Press version written by Rachel Hager3 of the Idaho Statesman. We urge the CGNF wildlife biologists to be aware and research the work behind this story as this issue is occurring region wide and CGNF lands are not immune from these causes. In the story as published in the Jackson Hole News and Guide, Rachel Hager states this fact:


“In February, Idaho Fish and Game drastically cut the number of moose tags because of population declines across the state. In 2019-2020, there will be 634 moose tags available, a 22% decrease from 2017-18, which also saw an 8% reduction compared to 2015-16. The Panhandle region of Idaho saw the largest cut this year — a 45% reduction in moose tags and the elimination of antlerless tags.”


These and other facts of the story prove the point made in our previous comments (page 85-95) dated June 1, 2019. State wildlife agencies do not know why moose population numbers are declining, but they are in agreement that they are. As a result, state agencies are sharply reducing the number of moose tags in Idaho, much like what was and is being done in Montana. Further on in the piece, she states that Idaho is not the only state where moose populations have declined. Utah has had a 34% drop in moose populations in just 12 years from 2005 to 2017. It is estimated that Oregon has only 100 moose in their state population, a state where hunting of the species has been banned.


In the article, reasons for the drop-in moose population numbers, while uncertain, are surmised by state wildlife agencies to be similar to those stated in GWA’s previous comments. Climate change, predation, and habitat loss being the primary reason, but that is with the acknowledgement that ticks and disease are being exacerbated by climate change itself. All of these are thought to be responsible for declining numbers of moose. Much of the habitat loss is thought to be from the lack of burnt forests as the U.S. Forest Service has had a campaign for fire suppression over decades. It is known that new growth as in new fresh vegetative shoots originating from recent fires is a source of feeding grounds providing great moose habitat.


Changing the topic to that of disease, parasites and carriers of disease are also responsible for declining moose populations. GWA had previously mentioned the potential of Parelaphostrongylus tenuis, also known as Brain Worm disease. We would like to refer CGNF to two additional sources of scientific information concerning the possibility of this disease on the CGNF. Their links are below.






As stated in the science, this disease is genuinely associated with white-tailed deer populations. But the fact that white-tailed deer inhabit Montana, makes all other prone species more susceptible. According to Montana Fish Wildlife and Parks6, they estimate the population of white-tailed deer in 2018 at a little over 215,000. That link is located below.


According to the Pennsylvania government website listed above, this parasite can affect moose, caribou, elk, bighorn sheep and other species of deer, not to mention domestic livestock. Within the website under the Wyoming, Deer Disease News Archive, there is an article by Judy Molland7, dated October 9, 2014 entitled “How a Tiny Brain Worm is Killing Moose Across North America.” The link to that is below.


She makes this claim.


“Moose populations are in steep decline in North America, in their normal habitats from Montana, Wyoming and British Columbia, to Minnesota and New Hampshire.”


In that article she relies on another link in a New York Times article dated October 14, 2013, nearly 6 years ago. In that article entitled “Moose Die-offs Alarm Scientists” by Jim Robbins8, there is a quote from Nicholas DeCesare, a biologist with the Montana Department of Fish, Wildlife and Parks. He makes these quotes.


“Something changed. There’s fewer moose out there and hunters are working harder to find them.”


That link to that article and quotes are listed here.


As you can see, the science and news worthy articles relating to moose are abundant. The science is out there and can be found rather easily online. The CGNF Draft Revision Plan and the Draft Environmental Impact Statement barely acknowledges moose at all, let alone that they are imperil. We strongly urge the CGNF and the Forest Service in general to become familiar with this parasite and how it affects moose and other prone species. For these reasons, if for no other rationale, this should suffice alone to place moose on the CGNF (and other National Forests) as a Species of Conservation Concern. This species and others are facing threats like no other in our time. GWA believes that the CGNF and all other state and federal agencies have a responsibility to faithfully manage and protect our diverse ecological balance and all the biodiversity contained within the Greater Yellowstone Ecosystem.


One more issue concerning the welfare of moose and other ungulates before we close out these comments, and that is of migratory behavior patterns. One of the essentials of species survivability is the ability to migrate. Species such as moose, bighorn sheep, bison, elk and others need to have the ability to migrate across and along large landscapes. According to scientists, migration has several benefits to the species in question. In Science magazine, an article dated September 2018, eleven scientists released an article entitled “Is ungulate migration culturally transmitted? Evidence of social learning from translocated animals.” In the first paragraph of that article, there are these summations (Jesmer, Brett R., et al, 2018)9.


      1.“Migration allows ungulates to maximize energy intake by synchronizing their movements with the emergence of high-quality forage across vast landscapes.


      2.….migration often bolsters fitness and results in migratory individuals’ greatly outnumbering residents


    3.Ungulate migration is a strategy for exploiting altitudinal, longitudinal, and other topographic gradients of plant phenology that determine forage quality”


But there was a question as to how migration patterns are instilled in their young. As stated in the abstract, “Ungulate migrations are assumed to stem from learning and cultural transmission of information regarding seasonal distribution of forage, but this hypothesis has not been tested empirically.”  Later on in the abstract, there is this conclusion.


“Our findings indicate that learning and cultural transmission are the primary mechanisms by which ungulate migrations evolve. Loss of migration will therefore expunge generations of knowledge about the locations of high-quality forage and likely suppress population abundance.”


That last sentence is key here. The loss of individuals who have learned and have knowledge of these migratory routes does not serve the population well. While much of the article concerns itself with bighorn sheep, the scientific article does address moose as well. The article continues.


“Animal migrations arise through a combination of learned behavior and genetically inherited neurological, morphological, physiological, and behavioral traits.”


When that learned behavior is lost, migration patterns are disrupted placing more biological stress upon the population. Reinforcing this thought, one has to only read an article found in the March 2019 edition of Ecology and Evolution by Lowrey, Blake, et al10. In the article entitled “Characterizing population and individual migration patterns among native and restored bighorn sheep (Ovis canadensis)”, there is found this statement on page 2.



“Globally, habitat loss, barriers along migratory routes, overexploitation, and climate change have resulted in steep declines of migratory behavior, and for many species, subsequent population declines (Bolger et al., 2008; Milner‐Gulland et al., 2011; Wilcove & Wikelski, 2008). The loss of migration spans nearly all taxonomic groups and has important implications across multiple biological levels of organization as well as direct relevance to economic and social concerns (Harris, Thirgood, Hopcraft, Cromsigt, & Berger, 2009; Wilcove, 2010). Once lost, restoring migrations has been met with limited success, as the source of the initial extirpation (e.g., habitat loss or fragmentation) can persist on the landscape (Wilcove, 2010). Although a few hopeful examples have shown some capacity to restore migrations after mitigating impediments to animal movement, the gains generally come at high economic costs and represent a diminished resemblance of historic migratory patterns (Bartlam‐ Brooks, Bonyongo, & Harris, 2011; Ellis et al., 2003)


Bighorn sheep (Ovis canadensis) are an iconic mountain ungulate that occur throughout western North America but have struggled to rebound to historic numbers and distributions after overharvest and the introduction of non‐native respiratory pathogens from domestic livestock (Buechner, 1960; Cassirer et al., 2017). While restoration efforts have resulted in modest increases in abundance and distribution, bighorn sheep occupy a small fraction of their former range and occur predominantly in restored populations that number fewer than 100 individuals (Buechner, 1960; Singer, Papouchis, & Symonds, 2000).”


In other words, there is an economic and environmental cost in man’s interference with the natural world and its processes. The loss of migratory patterns in an already changing world of habitat loss, disease, climate change, domestic livestock grazing, and other threats can be just too much for species to maintain population vitality. What man’s arrogance places asunder, may not so easily be replicated or restored. This is man’s arrogance. But it is also why it is so critically important to know and understand the science, to appreciate the science and to appreciate the natural world as it is. Instead of trying to use the natural world in a scheme of exploitation and extraction, we would be better off educating ourselves in how the natural world works. The Forest Service could be a huge contributor in this effort and actually a benefactor. We might find that the natural world, if left alone in most contexts, would and could take care of itself more efficiently than constant management by man.


GWA once again would like to thank the Custer Gallatin National Forest for a willingness to hear our comments and listen to our concerns. Hopefully this addendum will have value in your determination. We would also like to remind the CGNF that this addendum by no means lessens our support or contention that other species such as wolverine, bighorn sheep and bison should also be listed as Species of Conservation Concern. All of these species, and most likely others need to be reanalyzed for consideration as all face their own specific threats from habitat loss, genetic deterioration, disease, climate change and population loss.



Clinton Nagel

Board Member for Gallatin Wildlife Association and on behalf of:

Glenn Hockett, President of Gallatin Wildlife Association




Cited References


  1. Hager, Rachel, Idaho Statesman, Associated Press, OregonLive, The Oregonian, July 21, 2019.


  1. Hager, Rachel, Moose Numbers are dwindling, but why? Idaho Statesman, Associated Press, July 22, 2019.


  1. Hager, Rachel, Idaho Statesman, Associated Press,


  1. Pennsylvania government website,


  1. University of Minnesota website and Natural Resources Research Institute website,


  1. Montana Fish Wildlife and Parks,


  1. Molland, Judy, “How a Tiny Brain Worm is Killing Moose Across North America,”, Wyoming, Deer Disease News Archive,


  1. Robbins, Jim, “Moose Die-offs Alarm Scientists”, New York Times, October 14, 2013.


  1. Jesmer, Brett R., et al, “Is ungulate migration culturally transmitted? Evidence of social learning from translocated animals,” Science Magazine, September 2018.


  1. Blake, Lowrey, et al, “Characterizing population and individual migration patterns among native and restored bighorn sheep (Ovis canadensis)”, Ecology and Evolution, March of 2019 – revised in May 2019. Page 2
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