In 1970, I came to Montana to attend the University of Montana. I was going to be a fish biologist, and loving to fly fish more than just about anything else in life, I could not think of a better place to go to school than Montana with its fabled trout streams. One of the other attractions of Montana to me was the occurrence of wild populations of Arctic Grayling. Once found throughout the upper Missouri River drainage in the state, by the 1970s the fish were already greatly reduced in numbers and distribution. Wild populations were largely restricted to the Big Hole River, the last major stronghold for the fish. During my college years I used to go down to the Big Hole a couple of times a summer to cast flies for the grayling and often caught a dozen or more of the fish in a typical day. Today you would be lucky to find a single grayling at all, much less catch one in the Big Hole. Indeed last year a survey by the Montana Department of Fish, Wildlife and Parks could only find 40 adult fish in an 80-mile section of the river. The grayling may already be functionally extinct in the Big Hole River. So given the documented decline of the grayling in Montana, it was extremely disappointing to learn that this past week the U.S. Fish and Wildlife Service rejected a petition for emergency listing for the Montana populations of the Arctic grayling from Western Watersheds Project and Center for Biological Diversity. The latest delay in listing the fish is nothing new. Ever since the fish was first documented to be in danger by the FWS in 1982, the agency has done just about everything it could to avoid listing. Unfortunately the sordid tale of the grayling is typical of the response of the agency to any listing petition, particularly during the Bush administration. The history of the fish's legal travails is worth recounting. The grayling is a beautiful trout-like fish with a large sail-like dorsal fin and purple metallic coloration. The fish is found throughout the Arctic regions of the globe, including Alaska, Canada and much of Europe and Asia. But in the lower 48 states, the fish, an Ice Age relict, is now only found in Montana's upper Missouri River drainage. It was once found in Michigan as well, but went extinct there about a hundred years ago due to water quality decline resulting from extensive logging. In Montana the fish has declined significantly, and is now only found in about an 80-mile stretch of the upper Big Hole River, plus a few other locations including Red Rock Lakes, near Ennis Reservoir on the Madison River, and in a small stretch of the Sun River. By 1991, it was apparent to other biologists that if nothing were done to save the grayling, it would likely disappear from Montana. Around this time I was approached by several Montana Department of Fish, Wildlife and Parks fish biologists who were concerned about the future of the fish. Unable to generate support within their agency to do anything about the plight of the fish because the agency feared repercussions from ranchers and the Montana Legislature, they asked me if I would petition to have the fish listed under the Endangered Species Act. So with their quiet assistance, I put together a listing petition, which was submitted that fall to the FWS by Biological Diversity Legal Foundation and me. The FWS took several years to respond, but eventually concluded that the fish was indeed headed for extinction and listing was warranted. However, using a technique that the agency frequently resorts to when it wants to avoid listing a controversial species, it also concluded that while the fish was indeed going extinct, there were other species that were closer to extinction, so it would not list the fish. Such stalling tactics are common with the service. There were many reasons for grayling decline in Montana. One factor appears to be dams, which blocked long distance migrations that appear to be part of the fish's evolutionary strategy. However, the most important factor was the loss in habitat due to livestock production. Trampling of riparian habitat throughout the grayling's range has led to a decline in habitat quality, higher water temperatures, and a decline in deep pools, which are the preferred resting and feeding sites for the fish. In addition, dewatering of streams for irrigation of hay fields has severely impacted the fish. In the heat of the summer, the Big Hole and other rivers becomes too warm to support grayling and the fish retreat to smaller and cooler tributaries. But in drought years, many of these tributaries are completely dewatered, making it impossible for grayling to access the colder headwaters. In drought years, the main stem of the Big Hole River actually goes completely dry in some segments. The other effect of dewatering was to crowd grayling together in the deeper pools of the main river where competition with exotic fish was intensified. In my opinion, the obvious impact of the ranching industry upon the fish was the major factor prompting the FWS to stall listing. If listed, conservationists like myself would be able to legally require minimum flows in rivers, and changes to grazing management on federal allotments throughout the grayling's remaining range. It was also the reason the state of Montana opposed listing – because it did not want to irritate the ranchers who might be affected by such remedies. Though restrictions on sport fishing are rare when fish are listed, the department probably also feared that listing might potentially lead to restrictions on fishing on the Big Hole River. In order to head off listing by the FWS, the Montana Department of Fish, Wildlife and Parks did begin to take the grayling's plight seriously just as the department biologists who contacted had hoped. The department assigned a full time fish biologist to monitor grayling populations. In addition, new research was initiated to review the genetic status of the fish, as well as attempts to reestablish viable populations in a few other rivers like the Ruby and Gallatin where grayling were once native. These stocking efforts all appear to have failed. In addition to the invigorated interest in the grayling's fate by the Montana Department of Fish, Wildlife and Parks, a working group of ranchers, the state of Montana, and others were organized to implement measures to "save" the grayling. Among its strategies was an effort to increase water flows in the Big Hole River. However, like all voluntary efforts, this working group did not garner sufficient buy in from ranchers to significantly improve water levels, particularly during drought years. So to further stall listing of the fish, the FWS has now determined that even though the Montana populations of the grayling are genetically district and isolated from other grayling further north, these fish are not critical to the survival of the species as a whole. In other words the department suggests that since grayling are abundant in Alaska, there is no need to protect the Montana population. Such a ruling from the FWS under the Bush administration is not a surprise since it has an abysmal record of protecting species or any thing else that might affect industry. Nevertheless, if this same logic were applied to all the endangered salmon populations in the Pacific Northwest, the lynx, wolf and grizzly in the northern Rockies would no longer have any ESA protection either since all of these species are abundant in Alaska. Not only is such a position ethically wrong, it is counter to the best conservation science that suggests that isolated and district populations are important to the overall conservation of a species. Of course, the FWS is correct when it asserts that there are plenty of grayling in Alaska, but as renowned conservationist Aldo Leopold noted years ago when discussing the indifference to the disappearance of the grizzly from the West, "relegating grizzlies to Alaska is like relegating happiness to heaven – one may never get there." The same thing could be said of the Montana grayling. It will be a sad day if the grayling disappears from Montana – especially when it future could so easily be secured simply by keeping more water in the Big Hole River.