REINTRODUCTION OF A NONESSENTIAL EXPERIMENTAL POPULATION
ALTERNATIVE 1:The goal is to accomplish grizzly bear recovery by reintroducing grizzly bears designated as a nonessential experimental population to central Idaho and by implementing provisions within Section 10(j) of the ESA, conduct grizzly bear management to address local concerns. A Citizen Management Committee (CMC), created under a special rule to be published in the federal register, would be tasked with management of this grizzly bear population. This alternative has been identified as the U.S. Fish and Wildlife Service Preferred Alternative.
Alternatives 1 and 4 received the most comments pertaining to alternatives, and frequently in comparison with each other. The majority of commenters who specifically address Alternative 1, other than through petitions, are critical of it (approximately 70% of alternative one comments). Approximately 18% of the comments specifically addressed to Alternative 1 (outside the petitions) are supportive of it; and about 12% suggest modifications.
Additionally, the USFWS received three large petitions of support for Alternative 1 from the Defenders of Wildlife and National Wildlife Federation totalling 10,364 signatures.
Several aspects of Alternative 1 are controversial, including:
!Citizen's Management Committee - While many herald this Committee as a positive step forward in front-end coalition building, more respondents are concerned that the committee would be made up of individuals who would put political and economic interests ahead of the bear's well being. Several comments reflect a concern on the balance of membership for Idaho and Montana. In addition, respondents fear the committee would lack the scientific expertise needed to make good decisions. Many respondents believe the CMC will be biased toward local interests versus national. Some state they believe a Citizen's Management Committee would be illegal because the Secretary of Interior could not delegate decision-making authority to the group. On the other end of the spectrum, many oppose the concept because they don't feel the Citizen's Management Committee would be given enough decision-making authority.
!Experimental, Nonessential Designation - While some say this designation would provide more flexible management options and addresses local concerns, many express concerns. Most of those who condemn this designation say it is illegal because bears would be taken from populations currently protected as ?threatened@ and offered less protection under the experimental, nonessential status. Some question whether the bears are there already. They also question the legality of dropping consultation requirements between the Forest Service and the Fish and Wildlife Service. They also ask if Alternative 1 meets the mandate of the Endangered Species Act to recover bears.
!Recovery Area - While some respondents believe the recovery area is too large and too close to home, many commenters believe the designated recovery area is too small. They suggest protecting adjacent roadless lands and corridors which would link the reintroduced population with existing grizzly bear populations. They are concerned with habitat fragmentation. Numerous people question whether the habitat and food sources are conducive to a viable bear population. Commenters are concerned with genetic interchange. They say the proposed action conflicts with the purpose and need's description of a metapopulation. Some claim the agencies are trying to justify the experimental, nonessential designation by artificially isolating the Bitterroot Ecosystem.
!Sources for Bears - A number of respondents express concern that bears would be transplanted from populations where they are listed and protected under the Endangered Species Act to an area where they will lose their protection, and this will lead to more grizzly bear mortality.
!Local Interests vs. National Interests - While many support Alternative 1 because it allows those who live closest to the bears more control, opponents maintain the grizzly bear is a national resource and all citizens should have a voice in their management. On the other side are individuals from Idaho and Montana who believe they should have more say because the grizzly bear proposed recovery area is within those states.
COMMENTS FAVORING ALTERNATIVE ONE
Many people who support Alternative 1 say they do so as it is written. Several of those who support it say it represents the first time in the history of the Endangered Species Act that a recovery plan negotiated and written outside the Fish & Wildlife Service has been designated as a preferred course. They say it validates front-end coalition building as a way of bringing conservationists, industry representatives and other?non-traditional@ allies together to achieve balanced solutions to wildlife recovery and management issues. The following comments are representative of the types of comments received in support of the preferred alternative:
!?I want to acknowledge that the plan proposed by the U.S. Fish and Wildlife Service for reintroduction of grizzly bears into the Selway-Bitterroot does involve a different way of doing business under the Endangered Species Act. I also want to recognize that it represents the collaborative efforts of several diverse groups and interests.@
!?Alternative 1 offers the best assurance of both restoring the species and protecting the lives and jobs of the people who live in the Bitterroot Ecosystem.@
!?The approach of placing real authority for wildlife recovery management in the hands of local citizens is both unprecedented and revolutionary.@
!?To begin to build local populations of wildlife that are endangered or threatened is important for the future generations of our country...The legacy you are creating will be much more important to this country in one hundred years than today's detractors realize.@
Draft Environmental Impact Statement
Few comments made by supporters of alternative one relate to the actual Draft EIS. Two sug-gestions may be of note:
!?'Bears moving outside the recovery area would be accommodated through management provisions in the proposed special rule and through management plans and policies developed by the Citizen Management Committee, unless potential conflicts were significant and could not be corrected. ' The meaning of this statement is somewhat vague and ambitious. Perhaps if you strengthened it with examples of what management provisions are being considered, it would allay the fears of local residents...@
!?WMI does not find any discussion of the process employed to rank grizzly bear recovery in the Bitterroot Ecosystem as a fundable priority in the @greater scheme of things.? ...where does the recovery effort (and associated budget) for this additional population of grizzly bears rank versus that of, say, the black-footed ferret?@
Strategies to Control Nuisance Bears
A few individuals support the concept in this alternative that people could continue to kill griz-zlies in self-defense or in defense of others. They also like the authority the Citizen Management Committee would have to designate areas where bear use would actively be discouraged if conflicts are significant and cannot be corrected.
!?Alt 1 specifically states that grizzly bears on private land in the areas such as the Bitterroot Valley will be captured and relocated to the wilderness.@
A few individuals feel the recovery area as outlined in the DEIS is well thought out. They also support that bears would only be released into the Selway-Bitterroot Wilderness. They don't feel that bears should be released into the River of No Return Wilderness at this time.
!?Some have suggested the recovery area should be amended to exclude portions of the south end of the Frank Church River of No Return Wilderness. We oppose such change. The citizen committee is empowered to address and resolve problems if they develop. At this early juncture there is no good reason to assume that conflicts in the wilderness would be unsolvable.@
!?I favor the plan to restore grizzly bears in the Selway-Bitterroot Ecosystem since it is the largest roadless wilderness area in the lower 48...@
!?...if there's anyplace where grizzlies are not, where there ought to be grizzlies, it is in the Selway-Bitterroot.@
A handful of people support the designation of an experimental-nonessential population and implementing provisions within Section 10(j) of the ESA to conduct special management to address local concerns. Of those supporting this designation, most say their reason is because of the management flexibility and the ability to address unique local concerns.
!?A designation as nonessential and experimental will help appease people opposing the pro-posal and might also help limit human/bear conflicts.... The grizzly bears in the Bob Marshall and the Cabinet Mountains seem to avoid people and are rarely a problem... Historically, they have also been less protected and this seems to have fostered a healthy respect of humans.@
!?...the special rules developed under Section 10(j) with respect to the taking of the wolf in Yellowstone should serve as a model for similar rules applicable to the taking or reintroduced grizzly bears... the closer the proposed rules correspond to those that apply to the wolf, the more supportive of them we are.@
!?... experimental populations would provide the necessary flexibility to prevent major disruptions in resource activities and uses as populations of threatened and endangered species are increased.@
Citizen Management Committee
Individuals who favor alternative one primarily cite the Citizen's Management Committee as the basis of their support. Many say they support the CMC because they believe people living in the area should be involved in the decisions that affect their lives. They also like that it broadens public involvement and serves as a model for reducing conflict and bringing diverse interests to-gether. Many say that the CMC is the strength of the proposed action. Several individuals cite a survey of residents that reported 62% support grizzly recovery if the CMC is established. Numerous respondents say they support Alternative 1 because of the various interest groups in-volved in its development. They often name the group as the author of alternative one and then provide their support, i.e.,?we support the National Wildlife Federation's plan@ or ?citizen management as envisioned by ROOTS@. Several respondents support the CMC with full authority to act for the Secretary of Interior. They also support changes recommended by Governor Marc Racicot (Montana) that strengthens protection of the citizen management concept. These comments are further analyzed in the ?Suggested Modifications to Alternative I@ portion of this report.
!?Any successful species recovery plan requires at least tacit approval by those people living in and around recovery areas. The Citizen Management Plan ... gets everybody at the table, and broadens public participation in government ... it can help increase public support for species recovery in general and demonstrate the flexibility and effectiveness of the Endangered Species Act.@
!?What I find refreshing is the inclusion of people most affected by the decision, local residents. I have always felt that the most effective way to complete any species reintroduction is to enlist the help of local people. Quite often, just having someone listen to the concerns of people most affected and working with them to alleviate those concerns as much as pos-sible can make or break any efforts at reintroduction.@
!?This committee will be charged with striking the difficult balance between protecting the grizzly bears and maintaining the needs of the communities surrounding the recovery area. This is a sensible plan, based on the principle that citizens with access to accurate scientific information, can and will make decisions that benefit both people and nature.@
!?... as a retired citizen I view the role of the citizen committee as a positive step in allowing public discourse and comment on this segment of the grizzly bear's future in the rocky Mountains. It provides a...@sounding board?...on how endangered species such as the grizzly can be properly managed in the best interests of the entire public.@
!?Most of the people (in Challis) were not afraid of the bears. They were afraid of the feds and the regulations that come with the feds, and by giving the local people a voice in this... I think you do a very good job of addressing that issue.@
!?(CMC) creates a process that guarantees meaningful involvement in an important decision by people who live near the bears. Not an advisory committee, this is a management committee that will have broad authority.@
!?Most of the people I talked to and represent are not nearly as afraid of the grizzly bear as they are of the legal legislation that it currently packs with it. I believe that the Citizens Management Committee will cut out most of these legal problems, that is a hope which is better than no hope at all.@
Laws, Restrictions, Rights, Authority
Many supporters of alternative one feel the CMC provides a more equitable sharing of authority and responsibility between local citizens, state agencies and the federal government. Some also support it because they believe the Secretary of Interior will delegate authority to this committee. Most supporters of alternative one focus on the empowerment of local citizens and away from excessive government regulation on private lands. Many individuals are concerned about land use restrictions and say this alternative addresses those concerns.
!?Citizen management assumes that current public land management is adequate for grizzly reintroduction, which means no new restrictions will be needed.... most of the concerns I heard (Salmon hearing) are from people who are afraid that the feds are going to come in and lock up their public lands. If we give citizens the management authority over this, it should not be a problem. The citizens committee will decide on any possible land use restrictions.@
Endangered Species Act Proposed Special Rule 10(i)
Only a few individuals who support Alternative I specifically address the special rule. However, the statements in support of a nonessential, experimental designation as described above cover most of those comments. A couple supporters of this alternative believe it represents a positive and significant breakthrough interpretation of the Endangered Species Act.
!?Nothing like this has ever been tried under the Endangered Species Act before. It's a locally-grown solution that the Fish and Wildlife service deserves credit for accepting and advancing as its preferred alternative in the EIS. I think the service deserves credit because its relinquishing its authority (over CMC) saying let's do something differently with grizzly bears.@
Grizzly Bear Recovery Plan
One individual believes the Citizen Management Plan should also make the job of implementing the recovery plan much easier due to its up front broad acceptance by a significant cross-section of the population and industries. Other comments regarding the Recovery Plan can be found in the Issues chapter of this report.
Numerous supporters of alternative one cite the grizzly bear's importance to the ecosystem as a reason they should be reintroduced. Many believe the grizzly bears belong in the Selway-Bitterroot ecosystem, and that bringing the bears back will provide a more balanced ecosystem. Several respondents support alternative I because they believe it will assure long-term survival of the grizzly bear by linking isolated populations.
!?...for millennia grizzlies have contributed to the complexities of life-sustaining processes.... During the past century humans have been conducting a vast, unplanned experiment unraveling these life-sustaining processes.@
!?With the rapid pace of development, it is especially important to work for the preservation of land and species.@
!?We are, every last one of us, a part of this planet, not apart from it. What we do to our
planet has an impact on each of us, and it's time we started acting accordingly.?
!?We the undersigned recommend that you support NWF's plan... with its emphasis on local citizen management. This action is a vital addition to the burgeoning movement to restore the earth and its species, whose existence humankind has so shamelessly imperiled.@
!?Grizzlies in the Bitterroots are a key first step in restoring wildlife corridors between the is-lands of bear habitat now scattered across northern Idaho, western Montana, and Yellowstone. Without those corridors, grizzlies and other species face the genetic isolation that already threatens to destroy our remnant grizzlies in the North Cascades.@
Commenters who support alternative one generally comment on how management activities
the grizzly bears are compatible.
!?The alternative also will eventually demonstrate that many land management activities are compatible and the presence of the grizzly bear and some may indeed enhance habitat.@
Effects of Grizzlies
Supporters of Alternative one frequently mention public health and safety as a major concern. They see alternative one addressing that concern through the Citizen Management Committee and also through more local control. Many of these individuals discount the probability of people being attacked by grizzly bears. They also feel there will be less probability of conflicts with industry interests in this alternative. One hunter states that if this is a success?maybe one day we can hunt them [grizzly bears] too.@
!?As I told my governor, I am an avid hunter businessman , farmer, and outdoorsman. I feel
Proponents of alternative one generally laud its approach to balancing environmental and social needs. They also feel it is timely, cost-effective and does the best job of considering local economies.
!?Alternative one offers the best assurance of both restoring the species and protecting the lives and jobs of the people who live in the Bitterroot Ecosystem. Land use would not be significantly altered and economic activity including timber harvesting in the area could continue.@
!?Please proceed with this action as quickly as possible. Further study is not needed and only wastes time and taxpayer money.@
People in favor of Alternative One comment on the importance of having the Fish & Wildlife Service implement an education program about grizzly bears for the public (especially the communities in and around the recovery area).
!?... sanitation equipment should be installed and education provided before bears have opportunity to become dependent on human food.@
Several proponents of this alternative say it will work if politics and politicians
don't get in the
way. One individual says Alternative one may be the most politically expedient.
!?...if the proposed management... coalition... does not become overwhelmed by outside politics, I see Grizzly Bear Restoration working.@
!?I believe this alternative is the best and probably only politically feasible approach to initiate grizzly bear reintroduction... I recognize this alternative may not appeal to extremists in either the development or conservation camps. However, this... alternative strikes a delicate balance among many difficult interests and deserves a chance to succeed.@
CRITICISMS OF ALTERNATIVE ONE
The majority (approximately 70%) of respondents who specifically referred to Alternative 1 were critical. Numerous individuals state they believe the Citizen's Management Committee proposal is illegal because the Secretary of Interior is not legally able to delegate decision-making authority to this group. Several also are concerned the experimental, nonessential designation is illegal because bears would be taken from populations currently protected as?threatened@ and offered less protection under the experimental, nonessential status. There were several comments pertaining to the size of the recovery area; the criticisms were from both sides on size of the recovery area.
!?Citizen Management Committee...has absolutely no authority under the proposal and this whole section needs to be re-written to give Idaho managers some actual management authority.@
!?The Secretary of Interior has veto power over members of the proposed advisory committee and their decisions. This is not acceptable because the secretary has voiced his support of the proposal and he cannot be objective...@
!?Alternative 1 is little more than a capitulation to those ruled by greed, ignorance, and fear. 'Local control' by governors is merely a (slow) death sentence for the grizzly.@
!?As for the Citizen Management Committee, how is it justified that a few local residents, politically appointed, are given the guiding authority over enacting the reintroduction? I wonder when and where the voices of wildlife professionals, conservation biologists, and scientists who can best understand the dynamic grizzlies are to be heard.@
Draft Environmental Impact Statement
Several critics of alternative one question the data used. Most of those particular comments are outlined in the Issues portion of this report. However, some definitely attached to alternative one by respondents are:
!?... selecting an alternative as preferred in a DEIS does not violate NEPA. Publishing that alternative to the exclusion of others in the Federal Register give it a special favored status. This action gives the distinct impression that a decision in favor of alternative one has already been made.@
!?Under alternative one there is a benefit listed of over $40 million dollars that people would be willing to pay to know that grizzly bears exist in central Idaho. There is no scientific backing for this claim... top grizzly bear scientists such as John Craighead, contend that grizzlies won't survive under alternative I because you are destroying their habitat and removing their endangered species protection. You should not count this as a benefit.@
!?Alternative one @...would ban toxicants lethal to bears within the recovery and experimental population areas. The Forest Service currently uses toxicants to control rodents within newly reforested areas. Would this practice be allowed to continue within the experimental popula-tion area??
!?The Draft EIS contains no comprehensive analysis of the potential long-term impact of implementing alternative one of species such as the lynx, wolverine, fisher, northern goshawk, boreal owl, and a host of other imperiled species. How will the new road network as-sociated with increased logging impact these species?... represents a degree of high biological risk management that is not in the long-term public interest and is contrary to the legal requirements on the Service to recover the grizzly bear and protect biodiversity values.@
Publication of the Proposed Rule in the Federal Register
Several critics of Alternative I question the legality of publishing the proposed rule at the same time as the DEIS. They also believe the?experimental, non-essential@ population designation would not be legal under section 10(j) of the Endangered Species Act. Several also point out that Section 10(j) contains no provisions that authorize delegating ESA responsibilities to a citizen committee.
!?Section 10(j) which specifies that experimental populations must be wholly separate, geographically, from other populations of the same species the Bitterroot area is less than 40 miles from an established grizzly bear population in the Cabinet Mountains.@
!?Under the non-essential designation, activities such as timber sales, roadbuilding plans, and other development would not require consultation with the U.S. Fish and Wildlife Service pursuant to Section 7 of the Endangered Species Act, meaning less habitat protection for bears.@
!?... under a non-essential designation, there can be no designation of critical habitat... agencies would be under no obligation under Section 7(a)(2) to avoid actions likely to jeopardize the species. Also eliminated are Section 9 takings provisions of the ESA, waived away from consideration by the proposed rule.@
!?Section 10(j) contains no provisions whatever which authorize delegating ESA responsibilities to a citizen committee. The U.S. Fish & Wildlife Service has embraced a liberal interpretation of Section 10(j) special rules to mean that they can make up anything they want.@
!?Although selecting an alternative as preferred in a DEIS does not violate NEPA, publishing that alternative to the exclusion of others in the Federal Register give it a special favored status. This action gives the distinct impression that a decision in favor of Alt. 1 has already been made. The DEIS is written with the assumption that the public favors reintroduction, which is not the case.@
Citizen's Management Committee
Most critics of Alternative 1 take exception to the Citizen's Management Committee as defined in the proposed action. Several respondents feel control of a national issue such as grizzly bear reintroduction will be placed into the hands of local politicians. These individuals and groups claim alternative one is a?model based upon attempts to privatize federal public lands belonging to all American citizens, and held in the public trust@.
There is considerable mistrust based on a lack of confidence by many that as soon as bears have been introduced the Secretary of Interior will somehow reassume the authority granted to the CMC in the special rule. Numerous individuals call for more clarity in the delegation of author-ity to the CMC as well as what actions the CMC is likely to take.
Many comments disapprove of the makeup of the CMC membership as outlined in the proposal. Several question why Idaho would have seven members and Montana five. A great number of these comments call for more?science@ as outlined in Alternative Four's Scientific Committee. There is a fear from this last group that the ?anti-grizzly governors of Idaho and Montana could thwart recovery efforts@ and stack the deck with anti-grizzly bear members. Numerous indi-viduals question the legality of the CMC as section 10(j) contains no provisions which authorize delegating ESA responsibilities to a citizen committee.
!?Alternative one is flawed because it delegates the authority of the USF&W to a citizen's
!?...the management of reintroduction by citizen committees, approved by the governors of Idaho and Montana, proposed by Alternative one is abhorrent. The Selway-Bitterroot are public lands owned by the people of the United States and the reintroduction should take its direction from them. Placing the fate or reintroduction in the hands of local politicians de-pendent on the contributions of extractive industries, that have much to gain by a failed or curtailed reintroduction, is foolishness at best.@
!?The Secretary of interior has veto power over members of the proposed advisory committee and their decisions. This is not acceptable because the secretary has voiced his support of the proposal and he cannot be objective...@
!?... we are concerned about the authority of the Citizen Management Committee. On page xv of the summary it says if the Committee makes a decision that the U.S. Fish and Wildlife Service doesn't believe is right, that the USFWS may disband the committee. This rule undermines the Committee's value.
!?Once the Secretary determines that the CMC has run amok, he has to tell them so, recom-mend changes, and wait around for six months to see if they take appropriate action, while bears, habitat and recovery slip away. There is absolutely no fail-safe mechanism to rein in a @rogue? CMC.
!?...the Citizen Management Committee is not the right group to oversee grizzly bear management... no scientific knowledge about grizzly bears is needed to serve on a committee charged with overseeing grizzly bear management.@
!?The Citizen Management alternative is a poor choice... Many of these groups are not concerned with the welfare or protection of the grizzly and therefore should not be included, the diversity of groups represented ensures that there will be constant conflict and political ma-neuvering within the management group.@
!?Idea of a Citizen's Advisory Committee is great, its implementation as written is a @farce? (pardon the expression).@
!Citizen Management Committee ?...representation is not balanced properly because Montana and Idaho have nearly equal number of members. However, over 90% of the area affected lies in Idaho.@
!?The membership of the Citizen Committee is unequal. Idaho has the most land, but Montana has the most people exposed.@
!?Management decisions, such as habitat protection, should be based on science with citizen input. The current plan calls for a committee with people supplied by the governors of Idaho and Montana who do not always have the best interest of the grizzly bears in mind...@
!?This alternative suggests a political process that does not acknowledge the best available science.@
Experimental, Non-essential Designation
Numerous critics of Alternative I denounce the experimental, non-essential designation which they see as downgrading the status of grizzly bears and removal of their protection under the Endangered Species Act. Many fear this designation would mean more bears would be killed. They also express concern this designation would remove habitat protection as there would be no anticipated impacts to land use activities on public or private lands including I timber harvest, mining, and public access/recreational use. A few individuals commented that they were concerned about how the CMC would affect public access and especially off-highway vehicle use.
!?I oppose Alternative 1 which reduces protections for reintroduced bears to non-essential status... Removal of bears from Threatened populations in the lower 48 states constitutes a @taking? under the Endangered Species Act and is therefore illegal.@
!?The designation nonessential experimental population and no impacts on land use activities including timber harvesting, road building and mining influenced our decision not to support this alternative.@
!?By using Yellowstone and Glacier grizzlies, FWS would not only be @downlisting? them, it would be @delisting? them, which seems clearly illegal... FWS refers to areas @where current grizzly populations are healthy enough to sustain removal of a few bears per year... any population that is listed as threatened is, by definition, not ?healthy@ and has no ?limited surplus...@
!?While the @experimental, non-essential? population designation for wolves appears to be a success... it is not valid for grizzlies because it ignores an extremely important biological dif-ference between the two species; that is, their different reproductive potential... The legality of taking bears currently protected as @threatened? under the Endangered Species Act, and downgrading their protection to @experimental, non-essential? for reintroduction, is almost certain to be challenged in the courts and very likely would fail the test.@
!?Grizzlies are a threatened species and should remain so in the Bitterroots. If a person is at-tacked they can kill a bear in self-defense, so why will changing the status to experimental even be necessary?@
!?You might as well just save time and money and go shoot or gas all the grizzlies right now. I can't imagine removing the protections that alternative I proposes to remove and calling ourselves responsible stewards of our wildlife legacy.@
!?Alternative I downgrades grizzlies to an experimental, nonessential population status. There would be no protection of habitat. It also removes female grizzlies from Yellowstone and Glacier Northern Continental Divide ecosystems and downgrades them to experimental status without ESA protection.@
!?The first generation of bear will be appropriately tagged, collared and marked. However, as they reproduce how will their off-spring be identified? Will the next generation of bear be considered part of the nonessential experimental population or be granted full protection un-der the ESA?@
!?On page xv of the Summary, it states @The CMC would be responsible for recommending changes in land-use standards and guidelines as necessary for grizzly bear management.? These changes in land-use patterns, depending on what the CMC recommends, could affect public access/recreational use and trail use, especially off-highway vehicle use. The CMC shouldn't have any more power than any other organized group when it comes to recommending changes in land-use standards and guidelines.@
Consultation with the Fish & Wildlife Service
Along with concerns for habitat protection requirements, numerous individuals are critical that grizzly bear management under this alternative would allow for resource extraction activities to continue without formal Section 7 consultation under Section 7(a)(2) of the ESA.
!?There would be no protection of habitat, and the Forest Service would not be required to enter formal consultation with the U.S. Fish & Wildlife Service on timber sales, mining, road building, grazing or other development.@
!?I oppose Alternative one... It would remove the requirement for formal consultation with FWS on any development within grizzly habitat.@
Recovery Area and Habitat
Many respondents are concerned with the amount and quality of habitat included in the recovery area. Most of these critics feel the designated recovery area is too small. They suggest protecting adjacent roadless lands and corridors which would link the reintroduced population with existing grizzly bear populations.
!?..the grizzly bear is one of the most habitat-dependent species and has incredibly stringent habitat requirements. It follows that the U.S. Fish & Wildlife Service should not be selecting an alternative that fails to ensure, in letter and in spirit, secure grizzly bear habitat.@
!Alternative one ?...will significantly decrease the recovery area set aside for grizzlies... This area is less than one-fourth the size of the GSSB (Greater Salmon Selway Bitterroot) Ecosystem. Grizzlies require vast areas of secure habitat. Alternative one fails to provide adequate wilderness.@
!Alternative one ?...gives the Forest Service way too much control and freedom to destroy thousands of acres of forest, as they would not be obliged to consult with the U.S. Fish and Wildlife Service on timber sales, mining, roadbuilding, domestic grazing and other public issues.@
!?...numerous agency and independent scientists have acknowledged that some of the best grizzly habitat lies north of the Lochsa River around Mallard-Larkins and the Great Bum That region is nowhere to be found in the government proposal flies in the face of biological reality and ignores an area of high quality habitat vital to any successful restoration attempt.@
!?The preferred alternative restricts the grizzly's recovery area to a small portion of the Selway-Bitterroot ecosystem. This area may not provide adequate area and forage base to accommodate a self-sustaining bear population.@
!?Alternative one limits the official recovery area for grizzlies to the Selway-Bitterroot ecosystem, less than one quarter of the Greater Salmon Selway Bitterroot ecosystem. However, the best grizzly habitat is found in the northern end of the ecosystem, outside of the wilderness, in unprotected roadless areas of the upper Clearwater and St. Joe drainages.@
Federal, State, Local and Tribal Authority
Under Alternative 1 the CMC would be authorized management implementation responsibility by the Secretary of Interior (in consultation with the governors of Idaho and Montana). The CMC would be comprised of local citizens and agency representatives from federal and state agencies and the Nez Perce Tribe. Critics of Alternative one attack this cooperative concept from all sides depending on who they distrust, i.e.., the Secretary of Interior, the governors of the States of Montana, the CMC members, etc.Many respondents believe the government is tying to create more roadless and wilderness areas and putting an end to multiple-use and restricting access. Several respondents from Idaho especially ask the U.S. Fish and Wildlife Service to stay out of their State, to not do anything, and?leave us alone@.
!?...Alternative I has the possibility of affecting trail-based recreation, especially off-highway vehicle recreation within the Bitterroot Grizzly Bear Experimental Area. On page xvii of the summary, it states @There would be no anticipated impacts to land use activities on public or private land to include timber harvest, mining, and public access/recreational use;? however, our department does see the potential for some impacts...@
!?We strongly object to road closures hunting and fishing restrictions, restrictions on mining,
!?...have no desire to pay for a program that has been opposed by the Governor, State Legislature, Idaho Department of Fish & Game, many environmental groups, and County Commissioners and City Councils throughout the state.@
!?The CMC would be responsible for recommending changes in land-use standards and guide-lines as necessary for grizzly bear management. These changes... could affect public access/recreational use and trail use, especially off-highway vehicle use. The CMC shouldn't have any more power than any other organized group when it comes to recommending changes in land-use standards and guidelines.@
!?Every road closure should be subject to public input and the NEPA process. Idaho's citizens should have the right to help determine if roads should be closed.@
!?We were doing just fine before the FWS showed up with bears and wolves in tow. I don't need you, my friends don't need you, my family doesn't need you, my community doesn't need you, the critters don't need you, Idaho doesn't need you, and I would respectfully request you and your ideas and your bears stay out and leave us alone.@
!?I have no desire to pay for a program that has been opposed by the Governor, State Legislature, Idaho Department of Fish and Game, many environmental groups, and County Commissioners and City Councils throughout the State.@
Respondents opposed to alternative one most often express concern about the recovery goal population size, the lack of linkage corridors to existing grizzly bear populations, whether grizzly bears are already in the Bitterroot Ecosystem, and the continuation of resource management activities such as road building, timber harvest, mining, etc.
!?Grizzlies will not survive without more bears and corridors connecting the habitat @islands? that already exist... Therefore, a Selway-Bitterroot bear population is essential to the long term survival of grizzlies in the U.S.@
!?...The biggest problem with this alternative is its failure to provide adequate connectivity between the proposed recovery area and existing populations in Yellowstone, Glacier and the Cabinet Mountains.@
!?Alternative I isolates the greater Salmon-Selway Bitter-root ecosystem from other ecosystems by failing to provide habitat corridors between these ecosystems... Its legal and political strategy includes artificially isolating the GSSB population from others in order to maintain the @experimental, nonessential? status.@
!?...we disagree with Alternative One's assertion that grizzly bear recovery would require 'no anticipated impacts to land use activities on public or private land to include timber harvest, mining, and public access/recreational use.@
!?...The idea that grizzly recovery can occur by focusing simply on individual, isolated populations is a mistake the Fish and Wildlife Service continues to make... violates every rule that population viability analysis has taught about the general requirements for long-term viability. It confuses short-term stabilization with long-term recovery and will produce neither.@
!?...resource extraction will continue in the @experimental area? as planned (or amended by the CMC) under the assumption that this is adequate for grizzly bear recovery it is assumed that projected land use in the area surrounding the recovery zone (the experimental area) such as road building and logging will not have a significant negative impact on the odds of success-ful establishment or population growth rate The best available biology indicates that roads and the number of human/bear interactions they facilitate and the resulting bear mortalities are the largest threat to grizzly bear populations.@
!?The recovery zone and recovery goals under alternative 1 are too small. Research (Mattson) has shown that a viable grizzly population in this part of the world needs at least 20,000 square kilometers. The recovery zone under alternative 1 is slightly less than 25,000 square kilometers.@
!?We do not agree with the DEIS claim that there is sufficient habitat in the proposed recovery area to achieve recovery. The high country wilderness area lacks spring range. Thus, transplanted grizzlies will move out of the area to lower elevations where there will inevitably be encounters with humans and livestock.@
Several critics of Alternative I feel it limits long-term recovery effectiveness and may yield in-breeding and genetic problems caused by the isolated population. Others contend the bears will not survive because there won't be enough food. Whether or not alternative one provides for habitat security is also a big concern especially relating to protection of roadless areas and retaining the integrity of the ecosystem.
!?Why take grizzly bears from a healthy habitat and place them in the Bitterroot Ecosystem where there may not be enough food.@
!?We find no biological evidence that the identified recovery area provides sufficient habitat to achieve grizzly bear population recovery objectives.@
!?Alternative I fails to consider critical habitat and simply introduces grizzly to a habitat that will not sustain them. It also allows for the continued degradation of the ecosystem by continued logging and roadbuilding in roadless areas.@
!?Road building and inevitable use by the public means bear mortality... Subsequent timber harvest will further degrade potential bear habitat. One sees that the best bear habitat we have today is in roadless, undisturbed ecosystems that have ample habitat for home range and dispersal needs with minimal industrial or public intrusions.@
!?The @Nonessential/Experimental Population Area? may barely support a sustainable popula-tion of grizzlies. Present timber management plans were developed prior to grizzly reintroduction consideration. Implementation of these plans will likely render much of Idaho's public lands... unsuitable for grizzlies in the future. Because the preferred alternative allows for further degradation of habitat... this alternative is largely a waste of time and money.@
!?Alternative one will also disrupt and isolate natural ecosystems which will cause future
!?...totally opposed to the ROOTS @Citizen management? alternative; I would prefer the no action alternative to this one, because it sets a disturbing precedent whereby a @zoo mentality? is applied to our public lands.@
Effects of Grizzlies
Numerous individuals opposed to alternative one are concerned about the negative impacts to the safety of themselves, their family, livestock, and their overall sense of security. They question what the effects of grizzly bears will be on listed fish species. Some are concerned with the effects on the local economy and a loss of tourism income. Several of these individuals call for more analysis in the Draft EIS on these issues. Another faction of commenters state the health and safety concerns are blown out of proportion by those who favor activities such as livestock grazing, timber extraction, and public access into the area.
!?As farmers and ranchers we see economic risks to our animals and to our livelihoods.@
!?If I have to worry about grizzlies out there it sure would not be as much fun... Don't risk lives.@
!?I have stated before and will continue to state that the plan to reintroduce grizzlies, which is opposed by our entire Congressional delegation, Governor Batt, the Idaho legislature as well as the Idaho Fish and Game, will put many Idahoans into life threatening situations while draining millions of taxpayer dollars from the Treasury.@
!?The Secretary of Interior and his agencies are forcing the reintroduction of a dangerous predator into areas of our state that are designated for multiple use -- including both recreation and resource production.@
!?This alternative resolves conflicts between grizzlies and livestock @in favor of the livestock on public lands. Protecting cattle or sheep should be secondary to protecting the grizzly.?
!?We strongly object to the claim that grizzlies pose a minimal risk to humans.@
!?One of the mainstays of a grizzly's diet is fish and their presence will adversely affect the salmon and steelhead recovery.@
!?No reasonable consideration is provided in the DEIS to potential conflicts with salmon and steelhead recovery programs also being conducted within the area affected by the Proposed Action. In light of National Marine Fisheries Service (NMFS) decisions to issue @no incidental take? directives to many land management and land use projects and proposals affecting recovery area and nearby land, it can be presumed that the NMFS 'zero risk' approach to listed salmon and steelhead must be taken seriously... Any consideration of grizzly bear reintroduction should be ended until this apparent conflict is resolved.@
!?The DEIS presumes that road density guidelines for national forests within the Experimental Population Area but outside the Recovery Area are adequate for recovery. The presumption is pending review... Road density guidelines are part of a forest plan. The pending review constitutes an admission that the guidelines may conflict with grizzly guidelines. Pursuant to CEQ regulations, the DEIS must discuss the possible conflict.@
!?...will result in...restriction of uses of public lands...@
Very few people commented on the social analysis for alternative 1; however, one individual made the following observation:
!?I can't see anywhere in this alternative where there is ... consideration for the growth of the population in the State of Idaho or Montana. They have taken a good share of the state in this area for the reintroduction. But if the human population continues to grow, who is going to be encroached on first, the grizzly bear on the population or the population on the grizzly bear?@
Several respondents voice their concern with the economic analysis in the DEIS and particularly for alternative 1. Several question the rationale behind spending so much money on reintroduc-tion of the grizzly bear considering the global state of the economy. Numerous individuals object to having their tax dollars spent on this project. Some say the economic analysis is not pre-sented in tangible values for laypeople. They question the data used and want new analysis. Some question the $40-60 million grizzly existence value. Some say the analysis is flawed. A recurring reason given is that?the economic analysis puts the needs of the States of Idaho and Montana before the national interest of viable public land and grizzly bear population. @ Several individuals also feel alternative 1 reflects the economic interests of the extraction industry.
!?...the DEIS does not fully develop costs associated with the Proposed Alternative. Net benefits associated with recovery... range from $40.4 to $60.6 million per year. These benefits are composed entirely of highly speculative and statistically dubious passive use values. The net benefits fail to consider probable losses due to reductions in resource extraction activities, costs associated with indirect impacts on the local economy, and a probable reduction in vis-its to the Experimental Population Area which are supported by data collected in anticipation of the DEIS.@
!?Waste of taxpayer dollars. I don't want my tax money going for this experiment. Millions of wasted taxpayers dollars for nothing.@
!?... claims to create jobs, but the future of these jobs is questionable considering the techno-logical advances in timber-cutting, which has consistently reduced the number of workers needed to accomplish the same amount of output.@
!?With the national debt that the government has there is no reason for unnecessary experiments that cost so much needless money when there's so many people starving to death.@
!?The experimental population area...is too large for efficient management and costs for the reintroduction maintenance ($168,000 per year) are excessive for an indefinite period.@
!?We question the economic benefit of reintroduction... Grizzly bears are not a tourist attraction... grizzlies should be considered an economic loss, not a benefit because of the potential loss of public land access.@
!?The DEIS also measures the value of bears in the region by measuring citizen's @willingness to pay? for their reintroduction. This makes the grizzly into a commodity. The amount citi-zens are Swilling to pay@ for grizzly reintroduction is irrelevant because the grizzly is not for sale.?
!?Alternative one... will force taxpayers to spend more than $137 million in road maintenance alone, versus saving $69 million by getting rid of the costly road expenditure. Logging com-panies will continue to be subsidized...@
!?The problem I've found with this proposal is that the amount of tax payer money spent is far greater than the competing alternatives, and the usage of the term @permanent? logging jobs seems misleading.@
!?Alternative one @...maintains the belief system that human activity is more important than the life of nature. Nature needs the wildlife corridors and peace from human enterprise...?
!?As a Montanan, there is a significant component missing in this mission to reestablish the bear in suitable regions of Montana, and that is the preeminent goal of returning the bear to the status of a huntable, trophy animal. Any EIS... that ignores this component clearly misses the mark of the emotional, social significance that the traditional hunting of this animal has for us.@
Critics of alternative 1 condemn the Citizen Management Committee as having undue political influence in favor of residents of Idaho and Montana. They feel the recovery area has been limited for political reasons, and that it is a political strategy to isolate the Selway-Bitterroot population to maintain?experimental/nonessential@ status.
!?The political makeup of the CMC is assured by allowing the governors of ID & MT to ap-point members to this committee, with NO requisites for training, expertise, or knowledge of the grizzly and its biological needs. Also by stating that only people from areas adjacent to the recovery area can sit on the CMC, the majority of the experts in the field of grizzly biology, population genetics, habitat, etc., will be EXCLUDED.@
!?...the government in this state is biased and for the resource extraction industries and to give them the management control of the bears, that's crazy.@
!?...twelve of the fifteen members on this committee are picked by the Governors of Idaho and Montana. Our Idaho Governor is adamantly against grizzly bear reintroduction. Montana's Governor wants to give further power to the predominately biased citizen management committee. In essence, more power to extractive and livestock interests.@
One individual comments on the public information and education outreach program in Alternative one.
!?The public information and education outreach program should extend beyond the one year @phase-in?. Provisions should be made to continue education programs and to adjust special sanitation equipment needs. An ongoing education program should be incorporated into state hunter safety programs, schools, wildlife clubs and other community groups.
SUGGESTED MODIFICATIONS TO ALTERNATIVE ONE
Some respondents who specifically address Alternative 1 provide suggestions for change. Many commenters favor Montana Governor Marc Racicot's plan. Others want modification or abolishment of the Citizen's Management Committee. Still others suggest expanding the recovery area and protecting adjacent roadless lands.
!?...have identified several challenges that would have to be fully addressed before we could support the plan. These include: 1.) written assurance that grizzly bears that would come from the Yellowstone or North Continental Divide (NCD) would not count against the mortality quota and thus impede delisting of bears in those areas of Montana where there are recovered populations; 2.) written assurance from the Secretary of the Interior that adequate funding is available for both this project and for all aspects needed to delist bears in Yellowstone and the NCD; 3.) that the authority of the citizen management committee is preserved unless there is solid, scientific evidence that its decisions are not leading to recovery of the grizzly bear; and 4.) the other equally important issues as outlined on the attached comments...@ (Montana Governor, Marc Racicot)
!?Local Union #3803 supports the Citizen Management Alternative as improved by the changes suggested by Governor Racicot.@
!?FSEEE recommends amending the special rule to provide for a Scientific Advisory Committee that would include both agency biologists and independent scientists. @
!''The Secretary of Interior must remain ultimately responsible for all final actions of this experimental program.?
!?Clearly define the role of the Citizen Advisory Group. This role must require all actions by this group meet the intent of the Endangered Species Act to move the grizzly bear toward recovery and off the ESA.@
!?The grizzly bear recovery area should be expanded to include all suitable habitat surrounding or adjoining the designated Frank Church - River of No Return and Selway-Bitterroot Wilderness areas. Roadless areas within this area should be fully protected, as they are essential for grizzly bear seclusion.@
!?The linkage zone proposed in alternative four between the Bitterroot Ecosystem and the Cabinet-Yaak Ecosystem should be included as part of the proposed action.@
!?I would like to see greater protection for the bears than a @nonessential? classification allows.@
Draft Environmental Impact Statement
Along with criticisms of the DEIS most respondents provided fairly detailed modifications/corrections they would like to see made in the Draft EIS. These comments are being provided to the F&WS interdisciplinary team in separate data base printouts. The following comments reflect some of the more popular themes that people raise about the DEIS as it pertains to Alternative 1.
!?... the public should have assurances that once begun, grizzly bear recovery will be adequately funded for the entire process to delisting.@
!?There should be more of a compromise between alternative I and 4.
!?To succeed, a thorough evaluation of the population size and dynamics of the donor population will be needed and should go beyond simple assessment of recovery plan mortality thresholds.@
!?A target introduction population of 25 bears in the Selway-Bitterroot over five years does not insure that the internal dynamics and behavior attributes for population growth will be in place... we suggest that a positive and reliable indication of long-term population growth will not be realized for at least 20 years, after which growth rates will likely be less than 4%... Analyses of population growth models, and scientific review of these outcomes, should be clearly explained as part of the EIS.@
!?Biological consideration for translocation sites should be clearly evaluated in a biological plan prior to release of bears.@
!?...there is no basis to believe that an isolated population of 280 is legitimate size to be considered @recovered... More analysis is needed to demonstrate where, how and why the recovery goal target will result in a self-sustaining population. Milestones should be developed to assess progress on population establishment, provide feedback for development of adaptive management strategies, and to provide a basis for decisions about continuing the effort... The DEIS should clearly state in several locations that the population goal of 280 should not be confused with either a viable population, or an actual recovery goal. A range of recovery goals for analysis may be more appropriate until more information becomes available following bear use of the area and potential viability modelling using parameters developed through actual BE data.?
!?To the extent that linkages are not developed, the DEIS should make extremely clear that an isolated population is not part of a metapopulation, and does not incur the advantages of a metapopulation described on p. 1-5. Additionally, expanded clarification of ongoing research on linkages such as described on p. 2-24, should be included in the proposed alternative.@
!?At least one alternative should include an agreement whereby the grizzly bear will be reintroduced into the Selway Bitterroot as a fully protected threatened species if the objectives of the @Roots? proposal fail within three years or within a reasonable period of time.@
!?... we recommend that the USFWS clarify that they adopt the recovery goals and guidelines established in the Bitterroot Chapter of the Grizzly Bear Recovery Plan... At a minimum, initial recovery goals and guidelines established and clearly defined by the Final Rule should: define a recovered population goal of 280 bears well distributed within the Experimental Population Area; maintain 14 females with cubs over a running 6-year average; manage a zero human caused mortality until more than 90 bears become established; manage for 4% overall human caused mortality, including less than 30% females within this overall mortality limit, when greater than 90 are established.@
!?Short and long term evaluation criteria should be established in the final rule. Short term (within first five years) criteria should consider: initial bear survival/mortality; the distribution of bears in the recovery area; evidence of reproduction; habitat suitable within distribu-tion of bears; and the level of bear/human conflicts. Long term evaluation criteria should be based on monitoring key spatial and demographic parameters which may at the minimal include: monitoring the distribution of females with cubs; monitoring the number of females seen with cubs annually; monitoring the annual number of known human-caused mortalities; and maintaining an increasing and sustainable number of bears well distributed within the BE as determine by recruitment and mortality estimates. Recovery evaluation ' criteria should include protocol for determining when reintroduction has failed. Reintroduction efforts should only be determined to be @unsuccessful? based on biological grounds ... should include the in-tent of developing an alternative re social/political reasons or a flawed recovery strategy.@
Most individuals with suggestions regarding the general management strategies deal with the Citizen's Management Committee, the size and quality of the recovery area, sources of the bears to be transplanted and the experimental, non essential designation.
Citizen's Management Committee
!?Our second major recommendation... is for the inclusion of full Section 7 consultation procedures. Baning this, we feel the proposed Citizen management Committee needs fundamental restructuring to bring management of this project under scientific oversight...@
!?... management should occur through traditional mechanisms with the addition of a citizen advisory committee or perhaps better... simply a forum where the managers of grizzly recovery could take public input.@
!?We believe the link between resource professionals and the Citizen Management Committee proposed in Alternative one needs to be strengthened...@
!?... we recommend clarifying the regulations to permit the Secretary (1) to request additional recommendations from one or both Governors if the initial lists recommended to him are such that he cannot meet the requirement with respect to a cross-section of interests and a balance of viewpoints and (2) to refrain from constituting the Committee until he receives such additional recommendations.@
!?IOGA wonders why Idaho would receive only 7 of the 15 slots on the CMA when nearly 80 percent of the 28.4 million acre recovery area lie within Idaho? IOGA recommends that the ratio of make-up of the CMA be changed substantially between Idaho and Montana residents to reflect the affected recovery area... reconnnends that the make-up of the CN4A be tilted heavily towards current users of the wilderness areas. We recommend at least two outfitters for the CMA - one water and one land-based.@
!?... we suggest that the CMC be recast as a Co-Management Committee that includes not only citizens and agency personnel, but also scientists recommended by the National Academy of Sciences. The mission of the Co-Managetnent Committee would explicitly be that of establishing a viable population of grizzly bears in the BE. This Co-management committee would function as outlined in the proposed alternative.@
!?Regarding the Citizen's Management Committee, @Require the governors of Montana and Idaho to consider nominations from minority leaders of natural resource committees in their state legislatures as well as from county commissioners. Such nominations should be ac-companied by written material that documents the nominees' ?diversity of knowledge and experience in natural resource issues@ as well as their ?commitment to collaborative decision-making.@ Written nominations will better allow the public to judge whether nominees meet the standard of being ?a cross section of interests reflecting a balance of viewpoints.@
!?Designate a Bitterroot Grizzly Bear Recovery Committee (GBRC) that insures a true partnership between citizens, tribes, state and federal agencies, and independent scientists to manage released grizzly bears. ...Broaden committee representation to reflect a true partnership of citizens, tribes, state and federal agencies, and independent scientists to jointly manage grizzly bears in the Bitterroot Ecosystem. Modify the committee's role in addressing recovery goals and guidelines, recovery evaluation criteria, and bear management strategies ... Ensure that the purpose and functions of the GBRC are clearly stated in the final rule .... USFWS should authorize a 14 member Bitterroot Grizzly Recovery Committee composed of four citizens from Idaho; three citizens from Montana; one representative each from USFWS, USFS, NPT, and MDFWP; and two independent wildlife scientists...@ (letter from the Nez Perce Tribe).
Sources of Bears
!?To the extent that bears to be relocated into the 10(j) area come from such listed populations, their removal... should be treated as the functional equivalent of a mortality, with all the management ramifications that flow from that.@
!?I suggest to you that all the bears be acquired from interior British Columbia, or if they are not available there, from somewhere else in B.C., the Yukon, Northwest Territories or Alaska.@
Experimental Non-essential Population
!?...there is concern that a nonessential experimental designation could, on technical grounds, preclude efforts to restore linkage zones The concern is that this requirement under the ESA could preclude needed habitat restoration efforts that are undertaken for the purpose of attempting to provide interchange between the Bitterroot and other neighboring grizzly bear populations The landscape, and bear habitats, could change substantially in the several decades it will take to recover grizzly bears it is impossible to predict the nature of these changes over time. Because of this, the Tribe feels it is important to ensure mechanisms for addressing grizzly bear habitat needs, now and into the future.@
!?Final rules which clearly limit bears to the Selway-Bitterroot Wilderness and the Frank Church Wilderness east and north of the Salmon River, along with the concept of the Citizen's Management Committee would constitute a major improvement in the preferred altemative.@
!?...the grizzly bear should be managed for the ENTIRE Greater Salmon-Selway-Bitterroot Ecosystem.@
!?Expansion of the recovery area will permit more full exploitation of the management flexibility permitted under the experimental population approach of Alternative one... We recommend including the important habitats on public lands north of the Lochsa River in the Clearwater drainage as part of the delineated recovery area.@
!?... suggest releasing bears in the most productive habitats first and matching as much as possible the habitats from which the donor bears originate.@
!?Revise the delineation of the Recovery Area to include, in addition to the existing recovery area, that portion of the BE from the northern boundary of the Selway-Bitterroot Wilderness north to and including the St. Joe River drainage.
!?A procedure for compensation of damages caused to individuals (including loss of life and personal injury) should be established under supervision of the CMC. Private funding should be solicited. @
Laws, Restrictions, Rights, Authority
Again, the major focus of these comments relate to the Citizen's Advisory Committee.
!?The CMC would be responsible for recommending changes in land-use standards and guidelines as necessary for grizzly bear management. Will the public have any input into these recommendations...@
!?The Secretary MUST retain final authority.@
!?Taken together, the designation of the population as non-essential and the lack of the Section 7 consultation process could possibly doom the success of the reintroduction effort. It will certainly prolong the chances for success.@
Commenters wanting modifications to alternative one generally focus on the size and quality of the recovery area.
!?The linkage zone proposed in Alternative four between the Bitterroot Ecosystem and the Cabinet-Yaak Ecosystem should be included as part of the proposed action.@
!?...include the protection of adjoining roadless areas by prohibiting road construction in future.@
!?We recommend that Alternative one include a long-term goal of enhancing natural dispersal into and out of the BE... through a planned reduction in the number of roads and the establishment of protected corridors of movement between habitats currently occupied by grizzly bears and the proposed area of recovery.@
!?I am not comfortable with the biologists' conclusion that the Recovery Area can ultimately support 280 bears.@
!?There is a significant portion of the primary area that is bare rock, cliff, or alpine areas not supporting adequate food staples for the bear to include the areas in the calculation of suitable habitat.@
!?I believe the grizzly bear should be managed for in the entire Greater Salmon-Selway-Bitterroot Ecosystem, with full legal protection under the ESA in existing wilderness and roadless areas and experimental population status outside of such areas except for the identified habitat linkage corridor. I favor actively managing this corridor as outlined under Alternative four to secure pathways for bear dispersal.@
Effects of Grizzlies
Most of the modifications suggested for this category deal with hunting.
!?Hunting with hounds and bait (for black bears) should be prohibited in the recovery area...@
!?Black bear hunters should not be allowed in any part of the recovery area... too many instances of misidentification by hunters.@
!?We suggest that all sheep and cattle allotments be immediately ended on any 'Situation One' grizzly habitat that is on Federal land within the reintroduction area as a way of preventing conflicts.@