Another Attempt To List Montana Grayling Under The Endangered Species Act

On August 30, 2024, the Montana Department of Fish, Wildlife, and Parks (MDFWP) closed the Big Hole River to fishing due to high water temperatures. When water temperatures rise, cold-water fish like trout are stressed and more susceptible to disease and even being caught due to low water concentrating fish in the remaining holes.

One of the other reasons for the closure of the Big Hole River is to protect one of the last  Arctic, or what is locally known as the Montana grayling. The grayling has been a candidate for listing under the Endangered Species Act (ESA).

 I petitioned the Fish and Wildlife Service to list the Montana grayling under the ESA in 1991. Since then, the grayling population in Montana has continued its decline toward extinction. Repeated delay tactics, congressional interference, and opposition from the livestock industry have hindered listing efforts. I am convinced the opponents of listing hope the fish will go extinct.

The grayling is a member of the family Salmonidae (salmon, trout, char, whitefishes), subfamily  Thymallinae (graylings), and is represented by a single genus, Thymallus.

The grayling is an Ice Age relict.  Although widespread across northern Canada and Alaska, the grayling in Montana was isolated in the Missouri River’s headwaters at the Pleistocene’s close. A second disjunct population once existed in Michigan which is now extinct.

At one time, the Missouri River drained to the Arctic Ocean. When the Continental glaciers moved southward out of Canada, they blocked the northward-flowing Missouri River, which detoured eastward to drain into the Mississippi and eventually the Gulf of Mexico.

Grayling survived Missouri headwater rivers above Great Falls, including the Sun, Smith, Madison, Gallatin, Red Rock, and Big Hole rivers. Although grayling has been introduced to lakes and streams outside their original range, the fish is now extirpated from many of its native waters. The last strongholds for native grayling populations are the Big Hole drainage, Red Rock Lakes Wildlife Refuge, and relict populations in Ennis Lake on the Madison River.

Grayling require clear, cold water, which is limited by irrigation and livestock grazing that damages riparian areas on tributary streams the fish require for spawning.

Irrigation withdrawals affect grayling in several ways. Low flows mean grayling are confined to a smaller amount of habitat and must compete with other fish for food and space. Less water in the river results in higher temperatures, which are lethal to the fish.

Finally, some young fish wind up in irrigation canals, where they perish. Climate change exacerbates all of these water issues. All of these factors are responsible for the grayling decline.

Another factor is that fluvial grayling (river-dwelling) are migratory. They sometimes move as much as 90 miles between their overwintering habitat (deep pools) and spawning areas.

I once witnessed such a migration on the Kobuk River in Alaska. It was late fall; ice was forming on the river. Along the shoreline as far out as I could see, thousands of grayling were all moving downstream to wintering areas with springs and deep holes that would not freeze in the Arctic winters. It was a fabulous sight, reminding me of what the bison migrations may have looked like in the 1800s.

One of the reasons I decided to attend the University of Montana years ago was the opportunity to see and perhaps catch a grayling. Shortly after arriving in Missoula, I went to the Big Hole River where I saw and caught grayling.

None of the fish I caught were large—maybe up to a foot long. I later caught much larger grayling in Alaska. But none of those northern fish hold a candle to the thrill of seeing a rare fish swimming in clear Montana waters. Due to their rarity in the state, I would not even attempt to catch a Montana grayling. The fish is so rare, it is gone from 96% of the waters that it once swan in.

Ironically, I got involved in the grayling’s plight due to my public lands grazing activism. Back in the 1990s, I was well known in Montana for criticizing public lands livestock grazing. The Montana Livestock Association called me the Ralph Nader of Montana, and it was not meant to be a compliment.

One day, out of the blue I got a manila package in the mail with no return address. When I opened it I found an unsigned letter to me by several Montana Fish and Wildlife biologists who wished to remain anonymous for fear of losing their jobs. They asked me to save the grayling.

The U.S. Fish and Wildlife Service conducted a status review in 1982 to consider protecting the grayling under the ESA but declined, citing insufficient evidence for listing. The MDFWP fish biologist feared that without federal listing, the grayling was doomed. The envelope contained recent fish surveys, data on population trends, and notes on grayling distribution and biology in Montana. It was everything I needed to create a petition to list the fish.

In their letter, they said that their department would not do anything to upset the ranching community and that grayling would become extinct unless something was done to protect them.

I contacted Jasper Carlton, who at the time ran the Biodiversity Legal Foundation, to help me put together a petition, which we submitted to the FWS in 1991.

Legal efforts to get the fish listed continue with Earth Justice representing Western Watershed Projects, Center for Biodiversity, and Pat Munday, a Butte resident. For decades I was a plaintiff in these suits, but I was removed as a plaintiff from the most recent legal suit due to political considerations. Nevertheless, I still support the listing of the fish.

Listing of the fish could influence federal grazing management on tributary streams where livestock damage riparian habitat, increasing sedimentation, and water temperatures. It could also force the irrigators to maintain more water in the Big Hole River during low-water periods. In the end it may be the last hope for saving this fish from extinction in its native waters.

 In 2018 the FWS once again denied listing of the grayling. This decision was challenged in court and about a month ago, a federal court ordered the Fish and Wildlife Service to reconsider its decision not to list the grayling under the Endangered Species Act. So, we are once again waiting to see if the federal government will honor its duty to protect the nation’s natural heritage and preclude extinction of its wildlife.