All this is happening even though there are few bears to hunt: They number around 700 according to U.S. Fish & Wildlife Service estimates—just 100 more than the 600 bears the agency wants to maintain in the Greater Yellowstone Ecosystem. Last year, even without trophy hunting, 61 grizzlies are known to have died in human-bear conflicts. Individual bears who threaten people or their property are regularly killed by professional wildlife managers.

“Why rush [to delist] when you’re as close as you are to your absolute minimum?” asks Mattson, perhaps the most vocal of the scores of scientists opposing the delisting, including prominent biologists Jane Goodall, E.O. Wilson, George Schaller and Michael Soule. Unlike government researchers, Mattson can speak freely because he’s retired from the U.S. Geological Survey and no longer serves on the Interagency Grizzly Bear Study Team. “It’s a precious gift to have grizzly bears here, hanging on.”

With the help of experts such as Mattson, The HSUS and other conservation groups are pushing to keep all grizzly bears listed as threatened. The HSUS does not believe the bear population in the lower 48 has recovered across a significant portion of its historic range and is concerned that the game departments of Wyoming, Montana and Idaho, which would have authority over delisted bears in the Greater Yellowstone Ecosystem, will not responsibly manage the grizzlies.

“These are the same three states that wanted to kill wolves down to the minimum population numbers allowed by the FWS as soon as they were delisted,” says Paquette. “The three states’ intentions are for the bears to be trophy-hunted.”

That means grizzlies will be killed merely for their skins or heads or claws. The HSUS is urging its supporters to speak out against the proposed delisting at the federal level and hunting plans at the state level. Time is short. The U.S. Fish & Wildlife Service and the fish and game departments of Wyoming, Montana and Idaho are taking accelerated steps to approve these measures before President Obama leaves office.

A majority of Americans oppose what the agency and states are trying to do, according to a national poll in April commissioned by The HSUS and Wyoming Wildlife Advocates: 55 percent of those asked opposed delisting (versus 26 percent in favor) and 67 percent opposed hunting (versus 20 percent in favor).

By mid-May, nearly 70,000 opponents had signed an HSUS online action alert and the 60-day U.S. Fish & Wildlife Service comment period had closed. The agency had denied requests from The HSUS and other groups to schedule additional hearings across the country, beyond the ones attended by a couple of hundred people in Cody, Wyoming, and Bozeman, Montana. But the agency had promised to reopen the federal public comment period after more was known about state plans. For its part, the Wyoming Fish and Game Commission had fast-tracked its bear management plan, scheduling eight hearings within a week, closing the public comment period after only a month and then approving the proposal. The Montana Fish and Wildlife Commission had announced it would accept public comments through June 18. And the Idaho Fish and Game Commission was scheduled to meet to discuss how to manage the bears. The HSUS, the Center for Biological Diversity and a Wyoming wildlife filmmaker are suing Wyoming to get its comment period reopened so that more residents can voice their opinions on the proposed management plan.

The proposed delisting is U.S. Fish & Wildlife’s second attempt to remove grizzlies in the Greater Yellowstone Ecosystem from the protection of the Endangered Species Act. The first, in 2007, failed when a judge ruled the agency had not adequately considered declines in the bears’ food sources. Now the agency, under pressure from Western Republicans who dominate Congressional wildlife committees, is back, with a report written by federal scientists that finds the bears have enough food.

If Mattson sees the bears as the miracle worth saving, for agency director Dan Ashe it’s the Endangered Species Act itself that must be protected: “It’s like any tool, we need to not overuse it, or it will break,” he says. But delisting is a move advocates have seen before with wolves and many other animals—one that, in several cases, has quickly led to massive sport hunting and trapping programs and has had little impact on the ESA itself.

“Handing over management to hostile state politicians, without any federal oversight at all, has not been a success story,” says Michael Markarian, chief operating officer for The HSUS. “Our country spends millions of dollars trying to bring species like wolves or grizzly bears back from the brink of extinction, and as soon as they’re delisted, they are subjected to trophy hunting and harmful practices that were responsible for their decline in the first place.”

In March, the U.S. Fish & Wildlife Service declared success: The Greater Yellowstone Ecosystem grizzly bears had recovered. Not so well hidden in the agency’s announcement was more bad news for the bears. In an unusual move, the GYE grizzlies would be singled out from the 1,000 or so other grizzlies in the lower 48, declared a “distinct population segment” and delisted. Under the conditions the U.S. Fish & Wildlife Service is proposing, Wyoming, Montana and Idaho could allow trophy hunting outside Yellowstone and Grand Teton. They could also allow unlimited trophy hunting outside an agency-designated Demographic Monitoring Area (DMA) that covers 19,000 square miles in and around the parks.

During the Bozeman hearing—at which people speaking against delisting outnumbered people speaking in favor 5-to-1—Matt Hogan, director of the agency’s Mountain-Prairie region, played down the possibility of hunting. “There is a potential that the states could choose to have hunting seasons on bears,” he told a reporter for the local NBC affiliate. However, Hogan, who worked for Safari Club International and the Congressional Sportsmen’s Foundation in the 1990s and early 2000s, must know trophy hunting is a near certainty. In late 2015, according to a leaked memo, Wyoming, Montana and Idaho were already planning how to divvy up hunting rights to the bears. Based on the territory they govern in the DMA, Wyoming would get 58 percent of the bears that could be hunted, Montana would get 34 percent and Idaho would get 8 percent. At the time, the states planned to kill 72 bears the first year after delisting (the U.S. Fish & Wildlife rule, issues later, reduced that number to 15 to 20).

It’s unclear where the states would find the money for annual bear counts needed to update population numbers and set hunting quotas. Though federal law requires that the size of the population be monitored for at least five years, there would be no guarantee of enough state and federal funding to supply the several million dollars a year necessary to do this once the federal government turns that responsibility over to Wyoming, Montana and Idaho, says HSUS staff attorney Nicholas Arrivo. Purchases of a limited number of hunting permits would not be enough. In Wyoming, for example, they would cost just $600 apiece for in-state hunters and $6,000 for those out-of-state. In Montana, they would cost just $150 each for residents. If the number of grizzlies were to fall below 500—the number at which the U.S. Fish & Wildlife Service believes its viability would be threatened—the only tool available to the agency would be to relist the bears on an emergency basis, suspending trophy hunting for a maximum of 240 days. But a lot of time might pass before such a decline became apparent, and hunting would continue in the months between when monitors did their counts and the bears were once again protected, meaning the number of grizzlies could drop even further.

Despite the uncertainty, Ashe says at a certain point the federal government has to turn responsibility for the bear conservation over to the states, trusting that they will not allow too many bears to be killed.

“We need to reestablish and reground hunting as part of an ethical tradition,” he said at an HSUS-sponsored conference on carnivores in October. “If we delist, there would be an allowable rate of mortality designed to ensure sustainability.”