Gallatin Wildlife Association


Species of Specific Concern


Similar to the U.S. Forest Service categorization of "Species of Conservation Concern", we are to begin a new page listing species which GWA believes are in dire straits of survival. This listing will be growing over time, most likely not be complete, and as you cmay guess will be somewhat subjective. 


We will most likely use information and science as provided in the Montana Natural Heritage Program.




It is estimated that fewer than 300 wolverines exist in the lower 48 states. The federal government has been petitioned for decades to list the wolverine as an Endangered Species for protection, yet, to no avail. They are not listed as threatened or endangered even though there have been many attempts to do so. GWA feels that wolverines are very much in need of listing and protection. Between trapping, habitat loss and fragmentation, and climate change, there is perhaps no more worthy candidate of listing.


A statement from the U.S. Fish and Wildlife Service's own webpage. A statement dated August 13, 2014.


"while it is clear that the climate is warming, after carefully considering the best available science, the Service has determined that the effects of climate change are not likely to place the wolverine in danger of extinction now or in the forseeable future. As a result, the wolverine does not meet the sttuatory definition of either a "threatened species or an "endangered species" and does not warrant protection under the ESA"


We very much disagree with this conclusion of the USFWS!






(text provided is from GWA's Objections comments)


One of the species that we will justify for consideration as a Species of Conservation Concern on the CGNF landscape is moose and is why we include it here as our own Species of Specific Concern.  That doesn’t mean there shouldn’t be others for consideration, there are. And we believe they all would qualify under the current definition of the 2012 Planning Rule. Moose is just another species that are in decline upon the landscape.


  1. Declining numbers in Population:

Again, there are many reasons for the decline of moose populations. The DEIS suggests that populations are declining due to hunter harvest, increased predation, vegetation changes due to large-scale disturbances and natural succession, disease, parasite loads, and climate change (DeCesare et al. 2014). Page 444 of the DEIS.


Even though actuals numbers of moose maybe hard to confirm, there is evidence to suggest the numbers are declining across the west and one reason comes back to climate change. In GWA’s previous comments of June 2019, we have this statement found in U.S. Forest Service’s publication.


GWA: “Interestingly, in an assessment by the CGNF, Assessment Forest Plan Revision, Final Terrestrial Wildlife Report, (Dixon, Bev, et al. 2017, page 110)17, one can see a consensus beginning to form. One reason for a decline of moose populations is climate change. The question will be, are some state and federal agencies willing to admit that?”


“Montana Department of Fish, Wildlife and Parks, in an interview with the New York Times, noted that there are fewer moose out there, and hunters are working harder to find them (Robbins 2013). The hypothesis for the decline is climate change.”


Additional research.


GWA: The paper, entitled "Status and Trends of Moose Populations and Hunting Opportunity in the Western United States", appeared in a scientific journal specific to moose, a journal called Alces: A Journal Devoted to the Biology and Management of Moose (Nadeau et al. 2017 )18. In the 2017 abstract, there is this statement.


“On average, hunting opportunity has decreased across 56% of the western US, remained stable across 17%, and increased across 27% during 2005–2015. Generally, declines in hunting opportunity for moose are evident across large portions (62–89%) of the “stronghold” states where moose have been hunted for the longest period of time (e.g., Idaho, Montana, Utah, and Wyoming).


One more scientific data point which was presented in June 2019:


GWA: “In a paper dated May 8, 2019, Julie Cunningham100, a wildlife biologist for MFWP, provided these results:”


“Moose declines began to be noticed in the 1980s, and female moose hunting opportunities were closed for some districts. The remainder of these districts closed female moose hunting in the late 1990s. The total number of moose licenses offered decreased over time, from 158 in 1985 to 110 in 1995 to 58 in 2005 to 22 in 2015.”


“Given the decline in moose availability and number of moose licenses, as of 2014 MFWP began issuing licenses valid in multiple districts (Figure 1). To simplify the hunting regulations, MFWP may propose officially combining these districts in the 2020 biennium. Moose are no longer so plentiful that we need to force hunter dispersal across the landscape with many small districts, so allowing fewer larger districts with approximately the same number of licenses will make more sense.”


These numbers and trends should give the Forest Service pause, for they indicate that all is not well with moose populations and habitat. We could provide several more pieces of evidence in scientific research and literature, but we again would hope that the Forest Service read and reviewed our original comments without repetition here.


  1. Susceptible to Climate Change:

There are a couple of ways that climate change is affecting moose. One way is disease from tick loads etc as highlighted here by the Forest Service documentation. There is plenty of research to match and confirm the threats of disease by tick infestations.


GWA: “We are seeing that climate change can affect moose habitat in many indirect ways, but we must not forget about the most direct way possible, temperature. In the same assessment by Dixon19, an interesting biological fact about moose needs to be taken into consideration:”


“Moose are adapted for cold weather, and when the temperature rises above 23 degrees Fahrenheit in winter, as has happened more often in recent years, they expend extra energy to stay cool. In addition, the warmer weather may result in higher tick loads or other parasites or diseases (DeCesare and Newby 2013).”


And then there is this fact again shown in our previous comments of June 2019.


GWA: “That was winter; how about summer? For that we will reference a document by Alyson Courtemanch, a wildlife biologist for the Wyoming Game and Fish Department. In her paper entitled Jackson Moose Herd Unit Population Objective Review (Courtemanch, Alyson, 2015)20, we see the limits of summer temperature for moose:”


“Moose become heat stressed when temperatures exceed 60 degrees Fahrenheit in the summer, which interrupts feeding and causes them to seek shade to cool down.”


  1. Other Diseases:

Besides the infestation of ticks and the parasites that they bring there are other diseases that befall the moose. Here is a list including those found in ticks.


1.“Moose, especially calves, commonly experience hair loss and stress in late winter due to winter ticks (Dermacentor albipictus). Winter ticks seem to be especially prevalent in the southern portion of the herd.

2.“Elaeophora schneideri is a filarioid nematode that lives in the carotid arteries of mule and blacktailed deer (normal definitive hosts) and is transmitted by horse flies.

3.“In addition, several moose in the Jackson Herd have been observed in recent years with

keratoconjunctivitis, which is a bacterial infection of the eye.

4.“Brucella abortus in moose. This infection with B. abortus will kill moose, and progression of the disease is likely rapid under field conditions.

5.“Parelaphostrongylus Tenuis. However, current knowledge of hte nature of moose declines and the biology of meningeal worm (Parelaphostrongylus tenuis) makes this parasite the most credible explanation. 


All of these diseases weaken the status of moose. This is a lot for a moose to overcome in the wild: climate change, predation, disease, vegetation and changes in natural progression of vegetation.


Again, we know the habitat is there, but there are forces outside the control of the Forest Service that should significantly warrant the agencies concern. It should warrant the agencies listing as a Species of Conservation Concern.


Finally, GWA would like to refer the Forest Service to an article that we submitted in November of 2019. It is from a Nov/Dec edition of Bugle Magazine by Heather Fraley21. We will quote what we said at that time.


GWA: “We have previously stated moose populations are facing unprecedented declines throughout the west, reasons not fully understood by scientists. However, this article highlights and confirms previous theories and concerns of GWA that the combination of parasites, disease, climate change and loss of habitat, the latter two bringing about changes in food supply are primary rationales for the declining population. As a result of these facts, Heather states the following in her article.


“State wildlife agencies cut moose hunting opportunity by 60 percent across former strongholds in Idaho, Montana, Wyoming and Utah from 2005 to 2015.”


GWA: “This trend is verified by observations of researchers and agencies across the United States and Canada. These trends and theories were all part of discussions by Canada, the United States as well as European countries who attended an annual North American Moose Conference. Heather again states.


“What they saw was foreboding. Populations of the largest member of the deer family have declined over the last 30 years across much of their southern range in the United States and Canada.”


GWA: “The title of this article is “Death By A Thousand Cuts, The Uncertain Future of Moose in Elk Country”. Toward the end of the article, Heather makes this statement.”


“Nothing in wildlife has a single cause, and moose declines are no exception. Multiple factors interact differently in different habitats, but for all the uncertainty, managers are slowly getting a clearer picture of what’s happening with moose across elk country.”


GWA: “Our question to the CGNF continues to be, what is being done by Forest Service researchers to understand population declines on the CGNF? The Custer Gallatin National Forest Draft Revision Plan and the associated Draft Environmental Impact Statement barely recognizes how stressors affecting moose populations on the CGNF. Knowing what we know and knowing what we don’t know, GWA would like a full accounting as to why these conditions don’t justify status of Species of Conservation Concern?”


As you can see, many species are facing severe threats right here on the Custer Gallatin National Forest, not that this is an indication of something the Forest is doing wrong, but because these are regional and with the regard to climate change, global threats. Not listing these species and others as Species of Conservation Concern is a disservice to the reality on the ground. Hopefully the listing of these and other species will help direct the management of the Forest Service back to their original missions of the agency; to protect the resources at large. By ignoring the reality on the ground, we are turning the other way and basically pretending all is well, when we know it is not.

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