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MESSENGERMESSENGERSPRING 2024SPRING 2024Photo: A female gray wolf with her pup / Getty via Cava Vol. XXXIIVol. XXXII

STAFFErik Molvar...............................................Executive DirectorGreta Anderson..........................................Deputy DirectorMegan Backsen...............................................Staff AttorneyAdam Bronstein..........................................Oregon DirectorLaura Cunningham.................................California DirectorPatrick Kelly...............Washington and Montana DirectorGrace Kuhn....................................................Digital DirectorGreg LeDonne................................................Idaho DirectorNancy Linscott.....................................Operations DirectorJosh Osher........................................Public Policy DirectorJaimie Park......................................................Staff AttorneyBranden Rishel................................................GIS SpecialistDelaney Rudy..........................................Colorado DirectorPaul Ruprecht ............................................Nevada DirectorDagny Signorelli....................Utah and Wyoming DirectorDave Stricklan ....................................Sagebrush SpecialistCyndi Tuell ...................Arizona and New Mexico DirectorLaura Welp........................................Ecosystems SpecialistBOARD OF DIRECTORSKelley Weston.........................................................PresidentAllison Jones..................................................Vice PresidentDr. John Carter .........................................................DirectorRose Chilcoat.............................................................DirectorDr. Bruce Hayse .......................................................DirectorArtemis Eyster...........................................................DirectorLouise Wagenknecht................................................DirectorADVISORY BOARDDebra Donahue • Louise Lasley • Jon MarvelDr. Elizabeth Painter • Dr. Tom Pringle • Todd ShumanSTATE AND REGIONAL OFFICESIdaho Headquarters: P.O. Box 1770 • Hailey, ID 83333(208) 788-2290 • wwp@westernwatersheds.orgNew Mexico: 738 N. 5th Ave., 206 • Tucson, AZ 85705(520) 623-1878 • cyndi@westernwatersheds.orgCalifornia: P.O. Box 70 • Beatty, NV 89003(775) 513-1280 • lcunningham@westernwatersheds.orgColorado: P.O. Box 621 • Paonia, CO 81428(970) 648-4241 • delaney@westernwatersheds.orgWyoming: (970) 312-1828 • dagny@westernwatersheds.orgMontana/Washington: P.O. Box 8837 • Missoula, MT 59807 • (208) 576-4314 •patrick@westernwatersheds.orgOregon: P.O. Box 1855 • Sisters, OR 97759(541) 595-8034 • adam@westernwatersheds.orgNevada: (208) 421-4637 • paul@westernwatersheds.orgPhoto: Sagebrush landscape / Getty via Canva

Wolf recovery expands despite federal apathy, rancher and trophyhunter hate campaigns...............................................................................3-6Erik MolvarBetter late than never: New regulations would prohibit agriculture onNational Wildlife Refuges...............................................................................7Paul RuprechtSage grouse planning: Plan to plan to plan to extinction........................8Greta AndersonWolverines in Colorado............................................................................9-10Delaney RudyScience progresses – but managem ent still regresses...................11-12Dave StricklanNew faces at Western Watersheds Project............................................. 13Environmental Law Conference is a WWP favorite................................14Adam BronsteinWhere the buffalo (and grizzly bears) roa m......................................15-16Patrick KellyBears Ears National Monument draft Resource Management Planreleased......................................................................................................17-18Laura WelpTABLE OF CONTENTSWESTERN WATERSHEDS PROJECT’S2024 SPRING MEETINGAugust 2024 - Date and Location TBD To obtain more information, please emailwwp@westernwatersheds.org

WOLF RECOVERY EXPANDSWOLF RECOVERY EXPANDSDepending on where in the West, 2023 was either a great yearto be a wolf or was either a great year to be a wolf or a life-or-death struggle to elude humans. Wolf populations expandedand formed new packs in the West Coast states and areintroduction effort in Colorado got off to a promising start. At the same time, wolves in Idaho, Montana, and Wyomingfaced murderous state policies, while an apathetic federalgovernment stood by and did nothing to fulfill itsresponsibilities to protect the species under the EndangeredSpecies Act (ESA) and the California Endangered Species Act.And in the Southwest, Mexican wolves got a long-overduereprieve when a new livestock depredation method – basedon science rather than maximizing rancher payola andparanoia – replaced years of corrupt mischaracterization ofnearly all dead livestock as wolf kills. Through it all, WesternWatersheds Project was a voice for the wolves, contributingimportant gains while setting the table for legal action to getnorthern Rockies the well-deserved protections they havebeen denied for so long.California leads West Coast efforts, with new wolfpacks establishedThe best place to be a wolf is California, where dual listingunder the federal ESA California Endangered Species Act notonly blocks hunting but also prohibits the killings of wolveseven when they prey on cattle and sheep. Livestockproducers are compensated when cattle or sheep are takenby wolves, but they don’t get to call in a state or federal deathsquad and engage in revenge killings. Thanks to California’s enlightened approach, a number of newwolf packs have been established in the state. Thesouthernmost pack is the five-wolf Yowlumni pack thatestablished itself in the Sequoia National Forest near KingsCanyon National Park and had its first litter of pups in 2023.Two new packs were established in the eastern Sierra Nevadanorthwest of Reno, the Beyem Seyo Pack (with six pups andtwo adults) and an unnamed pair. Overall, it has been a solidyear of wolf recovery in California, as wolves reclaimedhabitats long silenced of their howls.Photo: A gray wolf / Getty via Canva 3By Erik Molvar, Executive Director

Just across the border in Oregon, wolves continuedto expand in the western part of the state, wherethey are still federally protected under the ESA. Butwolves have been killed at an accelerating pace eastof the Cascades, and their population is stagnatingstatewide. Oregon remains plagued by a state wolfplan that allows trigger-happy ranchers to kill wolves“in the act” of depredating cattle and sheep. There have also been reports of multiple wolvesbeing poisoned, but as yet there have been nocriminal consequences. Washington has a similarsituation, but has had fewer wolves lost to the cattleindustry. The Washington wolf population grew 5%according to the last census, with a new packestablished in the North Cascades.Wolves return to ColoradoIn December, ten wolves were translocated fromnortheastern Oregon to the mountains of Colorado,fulfilling a legal commitment born of a citizen-ledballot initiative (backed by WWP and our allies) thatwon a narrow but decisive victory in 2020. State lawnow requires Colorado to manage wolves based onthe best available science. But it has nonetheless been a rocky road for wolves,with the state Cattlemen’s Association and fringesportsmen groups like Rocky Mountain ElkFoundation seeking to thwart the reintroduction atevery turn. The state unwisely appointed acollaborative committee stacked with wolfopponents to advise the wolf management plan,which was then drafted for the benefit of ranchersrather than wolves. WWP and our allies fought hardto remove the most egregious provisions, testifyingbefore the Parks and Wildlife Commission andinjecting science into the process. We managed to get trophy hunting struck from thewolf management plan, but it still has provisions forkilling wolves in retribution for livestock losses, andexcessive payments for ranchers whose beef ends upon the “wrong” dinner plate. We’ll keep fighting untilthe lethal management of wolves is stricken from theplan.At the same time, WWP has been working to getMexican gray wolves into the Colorado wolfreintroduction mix. There are hundreds of Mexicangray wolves languishing in captivity, while Coloradostruggles to find gray wolves to import to the state. Establishing Mexican wolves in southwesternColorado could provide a genetic buffer to preventunmanaged intermixing before the Mexican grays arefully recovered, and could recapitulate anintermediate form of wolf that once inhabited thisregion but was driven extinct.Mexican wolves get reforms but still struggleSeveral years ago, WWP spearheaded aninvestigation of corrupt rancher depredation claims,claims that paid out livestock producers for manylost livestock lacking any definitive connection towolf predation. These “killer wolf” claims led to anumber of deadly removals by state and federalagencies, including the killing of an entire pack. Butonce our investigation hit the press, congressionalconcerns cropped up, and a whistleblower steppedforward from within USDA Wildlife Services tounderscore the conclusions of the WWPinvestigation. In response, new federal standardswere put in place requiring definitive proof of wolfinvolvement in the killing or injury of livestock beforea dead cow could be eligible for full compensation.This is already cutting down on retribution againstwolves.As WWP and allies continue to battle in court againsta bizarre Mexican gray wolf management rule thatmakes Interstate 40 the limit on northward wolfexpansion, Asha the wandering wolf made her secondnorthward foray in 2023, proving once again thatnorthern New Mexico is biologically appropriateMexican wolf habitat. WWP drew publicity to Asha’s journeys, putting thearbitrariness of the boundary rule in the spotlightand perhaps buying Asha more weeks in the wildbefore she was captured in December. When she gotto Valles Caldera National Preserve, the parksuperintendent celebrated her return. WWPcontinues to advocate for her expedient re-releaseinto the wild. Photo: Asha in captivity / USFWS4

Feds ignore wolf carnage in the Northern RockiesIn Montana, Wyoming, and Idaho (and parts of Washington andOregon), ESA protections were removed for wolves via abudget rider led by Senators Tester and Simpson in 2011.Placed under state management, the Northern RockyMountain states opened up trophy hunts for wolves andprovided extremely loose regulations (if any) for other types ofwolf killing such as trapping and aerial gunning. In 2022,Western Watersheds Project filed a petition, joined by 70 othergroups, to restore ESA protections for wolves in these states,but the U.S. Fish and Wildlife Service ignored an overwhelmingbody of scientific evidence—showing that wolves deservefederal protection, and revealing state regulatory mechanismsas grossly inadequate and state population estimates asunreliable—and denied federal protections in February 2024.We are now suing them to reverse this decision.Wyoming was the original worst offender, designating wolvesas ‘predatory animals’ under state game regulations across85% of the state, which means there is completely unregulatedkilling of just about all types – shooting, trapping, even runninganimals over with snowmobiles. This is the opposite of wildlifemanagement and has resulted in the extirpation of wolvesthroughout suitable habitats in the vast majority of the state.In Wyoming, wolf hunters using recorded distress calls fromgame species lured ESA-protected wolves from Coloradoacross the state line into Wyoming before killing them. Idaho soon began to emulate Wyoming’s bloodthirsty wolfpolicies, legalizing aerial gunning and night-vision goggles forhunting, approving millions in taxpayer funds to be spent onwolf bounties (following the lunatic fringe of the hunting lobby– Rocky Mountain Elk Foundation and the cynically-misnamedFoundation for Wildlife Management), and opening up ayearlong unregulated trapping season on private lands.It got so extreme that the legislature even stepped in andwrested the wildlife management authority from Idaho Fishand Game so the politicians could ramp up the wolf killingeven faster. WWP and allies won a major legal victory againstyear-round wolf trapping in March, blocking trapping on publicand private lands for nine months of the year to protect grizzlybears during the times of the year they are out of their dens.In the race to the bottom, Montana did its best to keep pace,authorizing almost 300 wolves to be killed over the winter of2023-2024 – perhaps more than half the statewide population.Wolves were lured across the border from YellowstoneNational Park (where hunting is prohibited), and a studypublished in January 2023 showed that enough Yellowstonewolves were killed to break up entire packs in the northernreaches of the Park, interfering with their ability to takedifficult prey like bison.

6In a crowning display of hubris, Governor Gianforte personallykilled a wolf caught in a trap in 2021, in violation of staterequirements that a trapping certification is required in suchcircumstances, and got off scot-free.Through it all, WWP has poured science into the U.S. Fish andWildlife listing process, mobilizing experts who provided keystudies that demonstrate that Montana and Idaho wolfpopulation models grossly overestimate how many wolvesactually live in each state, and showing that even at presentpopulations (well above the legally required minimums that thethree states use as population targets), wolves are far belowminimum viable populations and are showing losses of geneticdiversity as a result, putting them at risk of extinction.The road aheadWe are confident that we have set up the U.S. Fish and WildlifeService for a major drubbing in federal court – it is obvious thatpolitical expediency, not science, drove its recent ‘notwarranted’ finding. We fully expect to be able to win a reversal – the violations inthis case are egregious violations of the “best availablescience” standard. Once the decision heads back to theagency, they will get a second chance to get it right.Meanwhile, we are watchdogging the welfare of wolves allaround the West, supporting their continued resurgence, andspeaking out for these animals who cannot speak forthemselves.The USFWS seems to be pursuing a stakeholder-basedcollaboration as a primary approach to wolf recovery, insteadof re-listing wolves in the states where they are mostvulnerable. WWP has no confidence that mutually acceptablesolutions for ranchers and trophy hunters will ever include anybeneficial outcomes for wolves. We’ll be enforcing the ESA incourt, and holding future policies to its “best available science”requirements instead.

New regulations proposed in February 2024 by theU.S. Fish and Wildlife Service (FWS) for nationalwildlife refuge management would go a long waytoward improving the value of these special areasfor wildlife. In 1997, Congress passed the Refuge ImprovementAct, which required the agency to protect the“biological integrity, diversity, and environmentalhealth” (BIDEH) of the refuge system. However, FWShas never released regulations to implement thisBIDEH mandate, until now. According to FWS, these regulations are needed toaddress the “dual threats of biodiversity loss andclimate change.” The draft provisions state severalbroad policies, including promoting habitatconnectivity, healthy water, soil, and air, andecological restoration. The regulations in most casesprohibit particular activities that are incompatiblewith these values, such as native predator killing andpesticide use. At the same time, the agency wouldprotect its existing water rights within Refuges.Importantly, the regulations would also largelyprohibit agriculture on Refuges. Things like livestockgrazing, haying, and crop production would not beallowed unless they were “necessary” to meet thepurposes of the Refuge, and then only if a desiredhabitat effect could not be reached using naturalprocesses. In other words, FWS could not authorizehaying or livestock grazing to increase duck habitat iffire, flooding, or native herbivores would do the jobinstead (as they have for thousands of years). Useslike growing potatoes seem out of the question underthe new management scheme.If we take FWS’s proposal at face value, managerswould now also use natural means instead oflivestock to fight cheatgrass—perhaps by relying onpassive restoration to promote recovery of nativebunchgrasses and soil crusts, as the best availablescience suggests is the right approach. Sounds like awin!BETTER LATE THAN NEVER:NEW REGULATIONS WOULDPROHIBIT AGRICULTURE ONNATIONAL WILDLIFE REFUGES By Paul Ruprecht, Nevada DirectorUnfortunately, many of our most valuable WildlifeRefuges currently allow livestock grazing and haying,often despite the presence of rare and sensitivespecies. Examples include Malheur and KlamathMarsh in Oregon, Red Rock Lakes and CM Russell inMontana, Ruby Lake and Stillwater in Nevada, ClearLake in California, and Seedskadee in Wyoming. WWPrecently fought livestock grazing at Clear LakeNational Wildlife Refuge in California, where cattlecompete with nesting sage-grouse and tramplerearing habitat for endangered Lost River andshortnose suckers. Sadly, we lost our lawsuit at theNinth Circuit appeals court and cattle continue tostomp the shores of Clear Lake. Happily, the BIDEHregulations may now prescribe a new path forward forClear Lake NWR and these other Refuges.The impact of removing livestock from NationalWildlife Refuges is both dramatic and compelling. Inthe early 1990s, the Hart and Sheldon NationalWildlife Refuges in southeast Oregon and northwestNevada issued new management plans that phasedout domestic livestock grazing on the Refuges.Grazing permittees were offered buy-outs by thirdparties, and the Refuges have been free of cattle eversince. In the intervening 30 years, these landscapeshave sprung back to life. Studies have documentedrecovery of riparian areas and aspen stands, as wellas migratory bird population increases. Fences havebeen removed to benefit pronghorn and sage grouse.The inspiring story is told in a documentary called“Rewilding a Mountain” which you can watch at theQR Code above.Here’s to hoping that we will have many more Refugesuccess stories like these to tell in the comingdecades. Photo: Cattle in a hay field on the Malheur National Wildlife Refuge. Photo: Adam Bronstein / WWP7

SAGE GROUSE PLANNING:PLAN TO PLAN TO PLAN TOEXTINCTIONBy Greta Anderson, Deputy DirectorIn March, the Bureau of Land Managementreleased its third iteration of the ResourceManagement Plan Amendments for GreaterSage Grouse. It’s a huge plan that will amend 77 land use plans inportions of California, Colorado, Idaho, Montana,Nevada, North Dakota, Oregon, Utah, and Wyomingover nearly 69 million acres. This year’s draft planfollows in the footsteps of the 2015 Obama-eraplans and the revised but enjoined 2019 Trump-eraplans, in that the agency doesn’t go far enough togive the bird the meaningful protections that itneeds. I wrote about our hopes for these plans in the Spring2022 Messenger. I shared about the substantivecomments we submitted alongside our allies, as wellas the extensive proposal to designate all sage grousehabitat as an Area of Critical Environmental Concern(ACEC). We had hoped that by reminding the Bureau the 2015plans had too much discretion at the local level,inconsistent and inadequate protections across thelandscape, and too many loopholes for industry, thatPresident Biden would provide an actualcommitment to protect sage grouse and, with it, allthe plants and animals that depend on the SagebrushSea. Suffice it to say, the 2024 draft plan is not as good aswe had hoped. Despite ongoing habitat declines anddiminishing grouse populations across the West, thecurrent proposed management paradigm is evenweaker than previous plans. The preferred alternativeincludes several instances of backsliding, fromdecreasing lek buffers to removing habitat objectivesto manage livestock grazing. The preferred alternative doesn’t even include anacre of the ACEC we proposed, though the agency didanalyze and find that 11 million acres met the criteriafor this additional protection. Comments on the planare due June 13, 2024. More information about theplans can be found at the QR Code at left.Photo: Female sage grouse on Seedskadee National Wildlife Refuge / USFWSSUBMIT YOURCOMMENTS BY JUNE 13Photo: Female sage grouse in flight, Seedskadee National Wildlife Refuge / USFWS8

WOLVERINES IN COLORADODespite opposition from the livestock industry and previouschallenges, recent legislative support and a threatened status underthe ESA have renewed momentum for reintroducing these crucialmesocarnivores to Colorado.Since joining WWP as the Colorado Director inDecember, I’ve had the pleasure of working on anexciting rewilding project: reintroducing NorthAmerican wolverines to Colorado. Wolverines play a crucial role in their ecosystems.As scavengers, they often feed on carcasses leftby larger predators like wolves, grizzly bears, andmountain lions, thereby contributing toecological balance and curtailing the spread ofdisease. Wolverines require large, contiguoushabitats, making their presence a significantmarker of extensive and connected wild areas -essential for wildlife resilience to climate change.Protections for wolverines and their habitatsprovide benefits for the health of the entireecosystem.But, as is often the case with carnivores, (evenmesopredators), the species has foes in thelivestock industry. Despite very few instances ofwolverines killing livestock, Colorado’s livestockindustry has been vocally opposed to thereintroductions. In one of only two recordedinstances of wolverine-livestock conflict in NorthAmerica, a wolverine killed a number of sheep inUtah, before being captured, collared, andrelocated to the Uinta Mountains. This led to anoutcry of protest from a Wyoming rancher whograzes sheep on a Forest Service permit in theUinta range. In Colorado, the bill has beenopposed by the Colorado Cattlemen’sAssociation, the Colorado Livestock Association,and the Colorado Wool Growers Association. Weare engaged to balance and reduce the outsizevoice of the livestock industry in state decisionmaking about native wildlife.Photo: Clara Manolaches via Canva9By Delaney Rudy, Colorado Director

There hasn't been an official population estimatefor the animal in the continental United Statessince 2014, and our ability to assess the populationsize of the elusive critters is limited. When it waslast assessed, the population was estimated to bebetween 250 and 300 individuals. Of these, onlyabout 50 are part of the breeding population. Thisvery small number of breeding individualshighlights the vulnerability of the species andunderscores the importance of expanding theirrange to ensure their survival and bolster theirgenetic diversity.Like most Coloradans, wolverines love snow. Theyare completely dependent on snowpack to storefood and to den. Colorado offers some of the bestwolverine habitat in the lower 48, and our high-elevation habitat is predicted to experience fewerof the catastrophic impacts of climate change thatthreaten wolverines as compared to their habitat inother states. Colorado Parks and Wildlife (CPW) has beenworking on a wolverine reintroduction for decades,but the effort was stymied by the ski industry in the90’s, and had been put on hold by CPW. Then, inNovember 2023, the US Fish and Wildlife Service(FWS) issued a final decision designating thecontinental US population of North Americanwolverines as threatened under the EndangeredSpecies Act (ESA). Because wolverines are nowlisted as threatened under the ESA, CPW needslegislative authorization to begin this effort.On Monday, March 4th, 2024, bi-partisanlegislators introduced a bill (SB24-171) toreintroduce North American Wolverines toColorado, and the bill passed the SenateAgriculture Committee on Thursday, March 21. Thebill is supported by Governor Jared Polis, ColoradoParks and Wildlife, several wildlife conservationorganizations, and other stakeholders, includingthe Ski Industry Association. We participated extensively in the development ofthe bill and have been working on outreach andcoalition building to support its passage. We areconfident that with bipartisan sponsorship and abroad range of stakeholder support, Colorado willsoon be on its way to returning these iconicmesocarnivores to the landscape.There is great reason to be hopeful, but we willremain vigilant to make sure that wolverines areadequately protected from anthropogenic threats.The listing decision was accompanied by an interim4(d) rule, which is a specific tool within theEndangered Species Act used to direct themanagement of ESA-designated threatenedspecies. The rule serves as a road map for theagency to aid in wolverine recovery and grantsspecific protections and exceptions for the species. WWP has concerns about some of the interim 4(d)exceptions, and submitted comments on the 4(d)rule in January raising concerns that it didn’tadequately address threats to the US populationposed by trapping and climate change, and weurged the FWS to more robustly analyze thesethreats when developing the final rule. We arehopeful that the protections provided by the final4(d) rule will be stronger.Also, the Colorado reintroduction bill will authorizeColorado Parks and Wildlife to reintroducewolverines only when a 10(j) experimental, non-essential population rule for the Coloradowolverine population is published by the U.S. Fishand Wildlife Service. 10(j) rules are used to define asubset population of an endangered species toapply specific management direction, which ofteninvolves rolling back protections. The bipartisansponsors and stakeholders in Colorado requiredthe bill to be contingent on the Fish and WildlifeService’s designation of a 10(j) rule. The FWS hascommitted to completing a 10(j) rule for wolverinesin Colorado on an expedited timeline, with supportfrom the state, and we will work with the FWSthrough to shape the 10(j) rule as much as possibleto reflect the needs of the species and theimportance of the Colorado population to speciessurvival in the face of climate change. With this effort on the heels of a successful firstround of wolf reintroductions, it is an exciting timefor rewilding efforts in the state of Colorado.Though I’m highly unlikely to ever see a wolverine,I’m looking forward to sharing our Colorado publiclands with these iconic animals.Photo: Wolverine traveling on a fallen tree / Getty via Canva10

Last month, no fewer than five people with fiveseparate affiliations sent me a link to a newpaper, “Functional traits—not nativeness—shapethe effects of large mammalian herbivores onplant communities,” published in the scientificjournal Science (383: 531-537). The paper was ameta-analysis of 221 grazing studies worldwidethat evaluated the impacts of megaherbivores(plant-eating animals with a body weight over100 lbs.) on native vegetation. The researchersfound that functional traits of megaherbivores –such as the animal’s size and the amount of foodthey consume–controlled their effects onvegetation, not whether a species was “native” toan area. No other factor had close to the sameimpact. This is an important paper, but a lot of peoplehave intuitively known this for a long time. Formillennia, Indigenous hunters worldwide(including the people that produced thebreathtaking cave paintings of horses, aurochs,and wooly rhinos from Chauvet, France, shownbelow, Figure 1) followed the herds of their land,mentally logged their movements, and evaluatedtheir impacts to the landscape. They knew thatwhen forage in an area is gone, the herds moveon. Later, circa 1834, Osborne Russell recordedcamping with a Bannock Indian village in themouth of the Birch Creek Valley, Idaho. Russellcounted 332 lodges in the village and estimatedabout 6 people per lodge. He also estimated thatthe entire encampment killed 1,000 bison toprepare meat for the winter. It is likely that therewas not enough forage for that size of a bisonherd to stay in the Birch Creek Valley all year, butthe Bannock knew to be in the right place whenthe bison showed up. They scouted the bison andunderstood their grazing patterns and knewwhere the forage (and thus the herds) was – andwasn’t. While it is true that individual megaherbivorespecies differ – i.e. have different muzzle sizes,plant preferences, physiological digestionmethods, ability to navigate difficult topography,etc. – the primary impact any herbivore has onvegetation is determined by how muchphotosynthetic plant tissue (primarily leaves)herbivores remove and how often. Grasses arebetter than other plants at replacing grazed-offtissue, but grasses also have an herbivorydamage threshold. SCIENCE PROGRESSES –BUT MANAGEMENT STILLREGRESSESA recent study aligns with centuries ofobservation by Indigenous hunters,highlighting the importance of managinggrazing to prevent ecosystem damage, aconcept becoming increasinglyrecognized.By Dave Stricklan, Sagebrush SpecialistPhoto credit: Replica drawing of one of the cave paintings from Chauvet Cave.Creative Commons, Thomas T.11

If you are reading this, you likely know that WWP is the best in the business at “encouraging” the agencies tofollow the law. But there is also another nascent and loosely organized movement to just provide for bettermanagement by private people if the agencies can’t/won’t, sort of an ecosystem self-help movement. Peopleare just taking it upon themselves to make things better on the landscape. This isn’t new, but the notion isexpanding. We are working with a retired couple in New Mexico that is actively restoring a native Cienega. (Irecommend reading about it in Restoring the Pitchfork Ranch: How Healing a Southwest Oasis Holds Promisefor Our Endangered Land by A.T. Cole). I am also working with a group that is buying some private land andnearby public land grazing permits and replacing the domestic livestock with native herbivores at muchlower stocking rates. This allows wild herbivores to thrive and also does away with the practice of callingWildlife Services to kill native predators in the area. Both entities are using their own money and are notaffiliated with any large or established environmental group. They are just doing it. So to recap: 1. Herbivory and herbivores are natural and normal. The energy captured from the digestion ofplant tissue drives energy transport in the middle trophic levels of properly functioning ecosystems; 2. Whenherbivory is concentrated in one place for too long, damage to plants and soils inevitably occurs; 3. Historyover the past eight or nine decades has shown that land management agencies are not able to respond to orprevent routine damage by too much herbivory (usually by domestic herbivores) occurring for too long inone place; 4. Thoughtful people are now employing common sense and creative solutions to this ecologicalproblem and in some places, it is working. A lot more has to be done on a very large scale and it is critical that society continues to remind the landmanagement agencies of their legal responsibility to meet the legally established land protection criteria, butit seems clear to me that in order to protect public lands, new thinking by regular people like you and meneeds to be applied to landscapes everywhere.Too much grazing in one place by any large herbivore, whether they are wild, feral, native, or introduced, meansthat the animal should naturally move elsewhere, either by self-migration, herding, or human transport toavoid permanent damage to plants and soils on the landscape. It seems pretty simple. You might think that thefederal land management agencies would also key into the fact that the impact of herbivores on nativevegetation depends on how much of it is removed, and set policy and management actions accordingly. However, look at these two images of Trout Creek in New Mexico in the Quemado District of the ApacheNational Forest, which is administered by the Gila National Forest. I took them in the summer of 2018 when Iwas teaching a Field Range Management class at New Mexico State University. The first image is of Trout Creek(Fig. 1), upstream of the second image (Fig. 2). The first image is of a stream reach where cattle are excluded.The photos were taken on the same day. As soon as you get out of the area where cattle are excluded, thewater and vegetation disappear again. This happens twice more along the stream. The effects of themegaherbivores on the grazed portions of the creek show how devastating unchecked utilization can be. Figure 2. Trout Creek on the Quemado Ranger District, grazed. Photo: Dave StricklanFigure 1. Trout Creek on the Quemado Ranger District, ungrazed. Photo: Dave Stricklan12

Digital Director: Grace KuhnIf you follow WWP on social media or get our online newsletters, you may have already noticedwe’ve upped our game considerably. Grace Kuhn joined WWP in January as the Digital Director,sharing with us her expertise and years of experience fundraising and leading communicationsfor a variety of national non-profits. She has inspired us all to be more effective in sharingWWP’s work with the world, and we are grateful to have her working with us.Colorado Director: Delaney RudyColorado-born Delaney Rudy comes to WWP after working for the U.S. Forest Service onwilderness trail and fire crews and as a biological science technician where she gained animportant perspective on WWP’s critical role in reforming agency management! She has gottento dive right in on issues like the Colorado wolf reintroduction and Gunnison sage grouse, andwe’re thrilled to have her on board. Wyoming Director: Dagny SignorelliDagny Signorelli is a public land enthusiast with an educational and professional background inecology. She conducted utilization monitoring on Bureau of Land Management grazingallotments and worked alongside the agency as a wildlife technician, focusing on lynx habitatdetermination. Her research extends to the study of fire ecology in wilderness areas, and sheactively volunteers in the field of environmental justice. She’s a super addition to our team.Ninth-Circuit Attorney: Jaimie ParkFilling the shoes left by Talasi Brooks (more on that below), has been no easy task, but JaimiePark is up to the challenge. She’s got an extensive background in Indigenous law, environmentaljustice, and water and natural resource issues in the southwest. Jaimie’s insight and areas ofexpertise will bring a new angle to our work and she’s been quickly learning the arcana of publiclands law as it pertains to grazing, wolves, conservation plans, and trespass cows. NEW FACES AT WESTERN WATERSHEDS PROJECTBut goodbye to Talasi Brooks! Talasi moved back to New England to be closer to her family. Talasi carried animpressive caseload for WWP and we’ll miss her keen analyses and noble outrage about the injustices beingwrought on our planet. Good luck Talasi! Our 2023 petition to list pygmy rabbits under the Endangered Species Act was found to containsufficient information to warrant full consideration by the U.S. Fish and Wildlife Service. Thisputs pygmy rabbits – another sagebrush-dependent species – on track for protection(hopefully) within the next year. GOOD NEWS SPOTLIGHTPhoto: A pygmy rabbit / Morgan Heim13In addition to all the hard work our staff have been up to, we’ve had four new hiressince the last newsletter!

Colorado’s Wolf Reintroduction | Colorado Wolf ManagementPlan | Delaney RudyDelaney’s panel covered the wolf reintroduction in Colorado. Shepresented on the development and implementation of the ColoradoParks and Wildlife Wolf Management Plan. She discussed the goals andassumptions of the plan, state delisting criteria, and the final 10(j) rulefor the wolf population in Colorado; designating it a nonessential,experimental population. She highlighted that the development of theplan disproportionately represented the special interests of sportsmenand ranchers. She was joined by panelists from Defenders of Wildlife,the Center for Biological Diversity, and Colorado Mountain College. Saving Sage Grouse | A Brief History of Sage GrouseConservation | Erik MolvarErik’s panel covered sage grouse conservation. His presentation was onthe history of protecting the bird; from abundance prior to colonizationthrough the present. He discussed the species’ steady decline, theindustries most responsible for that decline (livestock and oil), efforts toget the grouse ESA protections (successful for the Gunnison SG),congressional interference into adequate protections, and the West-wide sage grouse plans. Erik was joined by panelists from American BirdConservancy and Advocates for the West. ENVIRONMENTAL LAWCONFERENCE IS A WESTERNWATERSHEDS FAVORITE By Adam Bronstein, Oregon DirectorThe annual Public Interest Environmental Law Conference (PIELC) heldin Eugene, Oregon has become the largest gathering for environmentalactivists, attorneys, law students, and academics in the country. Hostedby law student volunteers at the University of Oregon School of Law,PIELC has been held since the early 1980s, growing in popularity andscale over the years. Attending the conference has become a traditionfor WWP staff. The conference typically spans several days and features a wide array ofactivities, including keynote speeches, panel discussions, workshops,and film screenings. These sessions cover a broad spectrum ofenvironmental issues, such as climate change, biodiversity loss,environmental justice, and environmental law. Conference panels andkeynotes impart a lot of useful information informative to our work atWWP, but what makes the event particularly special is the opportunityto connect with fellow WWP staff and colleagues from partnerorganizations. WWP staffers frequently present at PIELC allowing us tohighlight our work and the issues that we care about such as livestockgrazing and species protection on public lands. This year, WWPorganized and presented on three panels30x30 in Oregon: What Will itTake? | Conserving in Good Faith- Aligning 30 x 30 ConservationGoals with EcologicallyAppropriate Land Protection |Adam Bronstein Adam’s panel addressed the 30x30campaign, a global initiative aimed atconserving and protecting at least30% of the planet's land and oceansby the year 2030. This ambitiousconservation effort seeks to halt theloss of biodiversity. To meet landconservation targets under a specificOregon 30x30 initiative, theconservation community will need toaccelerate its efforts and advocatefor the conservation of millions ofacres of public and private land eachyear. Congressional lawmaking isinsufficient to attain 30x30 in Oregon,underscoring the urgent need forsweeping executive action. Adam’spresentation covered whatconstitutes "conserved" so that landswill indeed be primarily managed forbiological diversity, and not extractiveuses like livestock grazing and timberharvest. Adam was joined by AndyKerr of the Larch Company, and LindaPerrine, an independentenvironmental advocate. Photo: WWP staff gathered at PIELC. Front row from left: Delaney Rudy,Jaimie Park, Greg LeDonne, Patrick Kelly and Cyndi Tuell. Back row fromleft: Paul Ruprecht, Erik Molvar, Adam Bronstein, Branden Rishel. 14

WHERE THE BUFFALO (AND GRIZZLY BEARS?!)ROAM A visit to Montana's American Prarie Reserve showcases thesignificant ecological benefits of bison restoration and thecontroversy it sparks among local ranchers and stateofficials. It was a chilly fall morning when I arrived at theAmerican Prairie (“AP”) National DiscoveryCenter in Lewistown, Montana. I was scheduledto meet with Scott Heidebrink, AP’s Director ofBison Restoration, for a daylong tour of theirsprawling preserve lands and adjacent federalbison grazing allotments. Scott greeted me atthe door and, as he walked me back to the officearea, I could sense excitement in his voice. Theother staff members were also abuzz. It turns outthat wildlife cameras set up on AP property had,that very morning, turned up their very firstgrizzly bear. This was likely some of the first evidence ofgrizzly bears in the Missouri Breaks country inover 100 years. This intrepid bear had wanderedover 200 miles eastward from the RockyMountain Front and out onto the plains,somehow managing to safely navigate a tangledmess of roads, barbed wire, grazing cattle, andhostile ranchers. This was a wonderfully wildomen to mark my first visit to Montana’sshortgrass prairie.As we cruised backroads on the way to AmericanPrairie’s Sun Prairie property, Scott and I talkedbison. Scott told me how nutrients fromdecomposing bison carcasses create miniatureecosystems made up of unique plantcommunities, how bison fur provides nestingmaterial for a host of prairie species, and howrecent studies have shown that bison grazingincreases biodiversity in riparian zones whencompared to cattle (which often degrade theseareas).I thought about how, much like salmon carcassesonce fertilized entire forests on the Pacific coast,millions of dead bison must have provided a similarlyincredible infusion of nutrients into these prairiegrasslands. This thought was interrupted when Scott drew myattention to what would be one of many signs postedalong the road urging us to “Save The Cowboy: StopAmerican Prairie.” American Prairie’s mission to connect and rewild 3.2million acres of private and federal prairie grassland,through strategic property acquisition and bisonreintroduction, rubs a particular contingent ofpeople the wrong way. This contingent has recently included not onlylivestock operators and ranchers but also Montana’sgovernor and various state agencies, all of whomappealed a BLM decision granting American Prairie’srequest to convert several federal grazing allotmentsfrom cattle to bison.Photo credit: A bison at sunset on the American Prairie / Patrick Kelly, WWP15

WWP filed a motion to intervene on behalf ofAmerican Prairie but was unfortunately denied.Luckily, it appears unlikely that the appellants willprevail. This is due simply to the fact that bothAmerican Prairie and the BLM followed the grazingpermit process exactly as required. It is difficult to ignore the hypocrisy of stateagencies and the various stockgrowers who haveappealed this decision. Regarding the aggrievedstockgrowers, their sense of entitlement hasblinded them to the fact that just like them, APworked through the very same federal permitsystem to acquire their leases. They met the baseproperty requirements and jumped throughvarious other required hoops, including completionof a full environmental assessment – which isnotably something the agency has yet to do forthousands of cattle permits across the West. Tooppose AP based solely on an irrational fear ofbison is not a good look for these ranchers. Regarding the state of Montana, it is ratherremarkable to see the attorney general argue in hisappeal that bison are “not livestock” and thereforenot eligible for federal grazing permits. Elsewherein Montana, most notably around YellowstoneNational Park, the state has no problem treatingbison as livestock and allows them to be managedas such by the Montana Department of Livestock.Seizing upon the unfounded hysteria overbrucellosis transmission from bison to cattle –something that has never once been documented –the department hazes and harasses bison, oftenemploying lethal measures to keep them bottled upinside the Park. It is quite clear that when it comesto bison, Montana’s government will affix whateverlabel suits their narrow agenda, consistency andscience be damned.Upon reaching AP Sun Prairie property, we slowedthe truck to a crawl and, after cresting a tiny bumpof a hill, there they were. A small herd of around 30bison were off to my right, grazing in thigh-highgrass. The place was so quiet you could hear themchewing. In all directions, clear to the horizon,there were no fences, no buildings, nor any othervisible human-made structures. Where possible,one of the first things American Prairie does whenit acquires a parcel of private property or a federalgrazing lease is to remove the tangled mess ofpasture fencing that impedes the movement ofwildlife.The effects of this fence removal were madeabundantly clear when, later that day, I witnessedthe single largest herd of pronghorn antelope I’veever seen spill out across the prairie in front of me.Scott and I would spend nearly 8 hours slowlymaking our way across just a tiny fraction of theregion that American Prairie is restoring andrewilding. The abundance of wildlife, even on achilly November day, was incredible. I lost track ofhow many different raptor species I saw.Throughout the afternoon I saw sage grouse,porcupines, mule deer, prairie dogs, and a widevariety of grassland birds.As dusk approached, we stopped the truck. A herdof around 80 bison was on the move about 100yards in front of us. With the truck engine silenced,I was astonished that I could actually hear thesound of rustling grass against bison fur as thegroup appeared to float like ghosts across theprairie in front of us. Then I heard a sound thatmade the hair stand up on my arms – a series ofdeep, guttural grunts reached us just as the herdbegan disappearing into a small draw. Though Ihave heard my share of buck snorts and elk bugles,and had more than my fill of mooing cattle, I hadnever heard anything like that before. It was wildand it was ancient and I was unexpectedlyovercome with an incredible sense of gratitude forwhat I was witnessing. In that moment I had thegood fortune to glimpse a time and a place that Iassumed had been lost. It was unforgettable.As the remarkable work of American Prairiecontinues to show, the wisdom of restoring bisonto their native range is clear. The fauna and flora ofthe plains evolved alongside bison and theirinfluence on this quickly disappearing, largelyunprotected ecosystem is remarkable. Bison movethrough these landscapes differently than cattledo, and as they move, they create a mosaic ofhabitats that support a vast array of prairie species. As the hysterical reactions to American Prairie byboth ranchers and the state of Montana haveshown, they are simply running out of good,ecologically justifiable reasons to continue grazingcattle on publicly owned prairie lands, especiallywhen the option to graze a native keystone specieslike bison is readily available. This fact should giveus all a bit of hope.16

The highly anticipated Bears Ears NationalMonument Draft Resource Management Plan (RMP)was released to the public in mid-March 2024.Right now, and until a final management plan isadopted, these lands are still being administeredaccording to the old, industry-forward field officemanagement plans. Some would be happy to seethat continue for as long as possible. This neweffort is our chance to create a science-based RMPthat will guide the Bears Ears NM management forthe next decade or more. This plan is also an important measure of progressfor the five Tribes that conceived of this monumentdesignation and have worked tirelessly for decadesto see their vision realized. The upcoming RMP isthe first time these Tribes’ voices will be codified ina land use management plan through co-management, and we look forward to seeing howthis cooperation between Tribes and agencies willmanage resources on the ground for long-termecosystem sustainability.There are two sentences in the draft plan thatcould bring significant improvement to grazingmanagement: “In accordance with PresidentialProclamation 10285, if grazing permits or leases arevoluntarily relinquished by the existing holders, thelands covered by such permits or leases would beretired from livestock grazing. BEARS EARS NATIONALMONUMENT DRAFT RESOURCEMANAGEMENT PLAN RELEASEDBy Laura Welp, Ecosystem SpecialistForage would not be reallocated for livestock grazingpurposes unless the Secretaries specifically find thatsuch reallocation would advance the purposes of theMonument designation.” These words sound arcaneand bureaucratic, but they enable managers topermanently retire grazing permits. This is a big,important change, and something for which WWP hasstrongly advocated.Alternative E is identified as the “preferred alternative”in the draft plan. Livestock management in Alternative E is frankly amixed bag. It proposes to close about 163,000 acres tograzing, which is 28,000 acres more than the currentplan. But most of these closures are in areas that arealready closed, so the MMP has little practical effect oncurrent levels of grazing. Right now, over 1.2 millionacres are open to livestock grazing on the Monument,and all alternatives keep a majority of that available.However, Alternative E does emphasize proper grazingmanagement. Along with promising to adhere to grazingregulations, the alternative would incorporate TribalEcological Knowledge. The BLM and US Forest Service would coordinate withthe Bears Ears Coalition to make grazing decisions. TheAlternative would: Photo: Bears Ears National Monument / Bob Wick, Bureau of Land Management17

Prioritize the review and processing of grazingpermits and leases, including compliancemonitoring and resource assessments, to protectMonument objects.Incorporate Traditional Indigenous Knowledge intoall parts of the livestock grazing decision-makingprocesses.Coordinate with the BEC on opportunities for jointdata collection and/or analysis.Identify subareas in allotments necessary forclosure (year-round or seasonal).Reassess stocking levels, seasons of use, andmanagement approach.Identify resource thresholds, monitoring, andautomatic responses related to land health and/orimpacts to cultural and sacred resources.Noncompliance with the terms and condition of alivestock grazing permit or lease would beaddressed immediately, in accordance withapplicable law and policy, and could includewithholding issuance of the permit/lease,suspending the permit/lease, or cancelling thepermit/lease.Draft Bears Ears National Monument ManagementPlan, page 2-125If these measures are consistently upheld, it wouldresult in improved grazing management on Bears Ears. WWP is following this issue closely and will share moreinformation as it becomes available. The public has anopportunity to comment on which alternative, orcombination of alternatives, it would like the managersto choose. The Bears Ears Monument ManagementPlan is at the QR Code at right.Map: Areas open to grazing in the Bears Ears National Monument under the Bureau’s preferredalternative / BLM)SUBMIT YOURCOMMENTS BYJUNE 6WESTERN WATERSHEDSMERCH IS HERE!Show your support for the causes you care about andfuel our efforts to protect western public lands and wildlife.18

Interest, Dividends, and Investments 2%2023 Income...................................$1,711,4182023 Expenses..............................$1,556,433Net Income.......................................$154,9852023 Budgeted Expenses...................$1,639,4962024 Budgeted Expenses....................$2,030,816*All figures rounded.WWP 2023 ANNUAL FINANCIAL REPORTMemberships and Major Donors 76.6%Grants 19.8%EXPENSESPrograms 93%Admin 5%Fundraising 2%Other Income 0.7%Legal Fee Recovery 0.9%INCOMEDONATE ONLINEAny size donation is greatlyappreciated! And it’s easy to become asustaining member by giving monthlythrough our websiteDONATE STOCKSTalk to your accountantor financial planner about the potentialtax benefits of making a donation ofappreciated stocks or learn more above.LEAVE A LEGACYConsult your financial planner or scanthe QR code for guidance on makingdonations through bequests, trusts,gift annuities, and more.WESTERN WATERSHEDS PROJECTP.O. Box 1770Hailey, ID 83333~Address Service Requested~