INTRODUCTION

This report summarizes public responses on the following two draft documents issued by the U.S. Department of Interior, Fish and Wildlife Service (FWS):

A. Draft Environmental Impact Statement (DEIS) on Grizzly Bear Recovery in the
Bitterroot Ecosystem;

and

B. Endangered Species Act, Proposed Special Rule 10(j), Establishment of a Nonessential
Experimental Population of Grizzly Bears in the Bitterroot Area of Idaho and Montana
(published in the Federal Register July 1, 1997, and included as Appendix 13 in the DEIS.)

The Draft EIS and Proposed Special Rule 10(j) were released for public review and comment on July 1, 1997. Comments were to be received through September 30. The comment period was extended to November 1 based on numerous requests for more time to prepare responses. The comment period was extended a second time to December 1, 1997 following a request from a member of the Idaho Congressional delegation.

Comments on the two draft documents were received from over 24,000 individuals, organizations, and government agencies. These comments arrived in over 2,660 letters, DEIS summary forms, resolutions, and hearing testimonies. Ten petitions were received with over 21,000 signatures. Fifteen form letters were identified (see Demographic Summary for specific figures). This degree of interest from the public indicates the strong feelings people have in the possibility of grizzly bear recovery into the Bitterroot Ecosystem (BE).

This analysis of the public's responses describes what people have said as completely and directly as possible without assigning weights or serving as a vote-count. The system used to analyze comments was objective, reliable and traceable. All responses to the two draft documents have been considered in the production of the summary, including petitions, hearing testimonies, resolutions, and DEIS summary forms along with letters and form letters.

It is important to note that this analysis is not based on vote-counting. The public involvement efforts of the National Environmental Policy Act (NEPA) are intended to gather information and ideas from the public on proposed actions and alternatives to the proposed action to provide a clear basis for choice among options by the decisionmaker and the public. An analysis of this public comment will help the decisionmaker make better decisions, not to simply count pro-s and con's. It is tempting for a proponent or opponent of a particular alternative to ?stuff the ballot box@ in support of a particular view. But while quantitative informtion is gathered and is important in assessing attitudes and concerns relating to particular issues, that is only part of the information analyzed. The reasons for people's concerns, preferences and criticisms are sought in this process. Therefore one will find little mention of total numbers outside of those provided in this Introduction, but rather more qualitative information indicating trends of public opinion.

The chapters on Alternatives and Issues fully describe and analyze public response. An analysis of form letters and petitions is provided at the end of this chapter.

 

 

PUBLIC INVOLVEMENT

Solicitation of Public Comment on the DEIS and Proposed Rule

The public comment process for an Environmental Impact Statement began in January 1995 and took the following path to the present:

!January 1995 - A Notice of Intent to prepare an EIS was published in the Federal Register. An Interagency team representing the U.S. Fish & Wildlife Service, the U.S. Forest Service, the Montana Department of Fish, Wildlife & Parks, the Idaho Fish & Game Department, and the Nez Perce Tribe was formed to prepare the Draft EIS.

!May 1995 - A Scoping of Issues and Alternatives information brochure was mailed to 1,100 people.

!June 1995 - Formal scoping for issues and alternatives began with Federal Register Notice for a 45-day comment period.

!July 1995 - The public comment period was extended by 30 days until August 21.

!August 1995 - The comment period ended, analysis of public comment began. Over 3,300 written comments were received and analyzed.

!September 1995 - The scoping results were summarized in the document, ?Summary of public comments on the scoping of issues and alternatives for grizzly bear recovery in the Bitterroot Ecosystem@ and document was distributed.

!August 1996 - April 1997 - Draft EIS written and reviewed by Interagency team (Idaho Fish and Game declined opportunity to review and comment on January 14, 1997).

!June 1997 - Congressional members and staffs, administration and agency personnel, states, counties, tribes, advisory committees/councils, and key individuals and organizations briefed on the Proposed Special Rule and DEIS preferred alternative before Federal Register publication and DEIS release to the public.

!July 1997 - DEIS released to public. Public comment period begins July 11 and ran through December 1, 1997 (following two extensions).

!July 1997 - Endangered Species Act, Proposed Rule 10(j) for Establishment of a Nonessential Experimental Population of Grizzly Bears in the Bitterroot Area of Idaho and Montana published in the Federal Register on July 2. Comment period begins July 11 and runs through December 1.

!October 1997 - Public hearings/open houses to gather public comments on the DEIS and Proposed Special Rule held in seven communities on the perimeter of the Bitterroot area. Approximately 1400 people attended these hearings and 293 individuals testified. The Salmon and Hamilton hearings both had more people signed up to speak than time allowed to testify. The dates and locations for the public hearings were as follows:

Wednesday, October 1, 1997: Challis, Idaho and Hamilton, Montana

Thursday, October 2, 1997:Missoula, Montana and Lewiston, Idaho

Friday, October 3, 1997: Boise, Idaho and Helena, Montana

Wednesday, October 8, 1997: Salmon, Idaho

!December 1 - Public Comment period ended.

In addition, the USFWS held meetings with local community, state leaders, and interest groups in communities around the perimeter of the proposed recovery area.

The Draft EIS, the Summary, and the Special Rule were all published on the USFWS web site at: http:://www.r6.fws.gov/endspp/grizzly.

Alternatives Analyzed in the DEIS:

Four alternatives representing different approaches to grizzly bear recovery and management were developed for evaluation in the DEIS because they encompassed public concerns raised during scoping and to reflect a full range of alternatives. Two alternatives (Alternatives 2 and 3) do not necessarily meet the purpose of and need for action, but were included in the DEIS to be responsive to public comments, to provide a full range of alternatives for consideration, and to meet the requirements of NEPA. All four alternatives reflect public comments and suggestions identified through issue and alternative scoping. Alternative 1 was identified as the U. S. Fish and Wildlife Service preferred alternative. The alternatives considered in the DEIS and analyzed in this report are:

Alternative 1. Reintroduction of a Non-essential Experimental Population Alternative (Proposed Action):

The goal is to accomplish grizzly bear recovery by reintroducing grizzly bears designated as a non-essential 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.

Alternative 2. The No Action Alternative - Natural Recovery:

The goal is to allow grizzly bears to expand from their current range in north Idaho and northwestern Montana southward into central Idaho and western Montana, and to recolonize the BE. The ultimate goal is natural recovery of grizzly bears in the BE.

Alternative 3. The No Grizzly Bear Alternative:

This alternative would prevent grizzly bear recovery in the BE.

Alternative 4. Reintroduction of a Threatened Population with Full Protection of the ESA Alternative:

The goal is to achieve recovery through reintroduction and extensive habitat protection and enhancement to promote natural recovery. The grizzly bear would have full status as a threatened species under the provisions of the ESA.

 

 

THE PUBLIC COMMENT ANALYSIS PROCESS

The analysis method used for this project provides a means of categorizing each person's comments into separate subjects, then grouping like subjects together so that the public's comments can be more thoroughly examined. It accurately displays public concerns and reasoning about particular issues and alternatives since each person's own words and phrases are captured. It provides a traceable, visible system for displaying public comments without injecting interpretation or judgment.

Responses were received in the form of letters or postcards, form letters, petitions, hearing transcripts, DEIS summary forms, and resolutions. Each letter, hearing transcript, petition, etc. was first given a unique identification number. A coding system was developed to assign demographic information to each respondent and to record their opinions on issues and alternatives. Demographic information coded included identifying who the respondent represents, the medium used for responding, the respondent's overall preference for or against grizzly bear recovery, and where the respondent is from.

Respondents were classified into one of the following categories, referred to in the coding system as ?Organization Types@:

Individual Citizens, Individual Landowners (if identified), Schools/Universities, Youth,
Professional Scientific Organizations

Federal Agencies, State Government/Agencies, County Government, City/municipal/local
government, Indian Tribal Government, Congressional/Legislative officials, Coalitions,
Political Groups

Business, Ranching, Environmental, and Recreation Organizations and Interests.

The codes that were used to identify the demographic information, issues and alternatives can be found in Appendix A; a demographic summary of respondents is displayed in this chapter.

Next, substantive comments related to a particular alternative were coded, along with particular reasons (issues) for support of, or opposition to, that alternative. In many instances, a particular alternative was not identified, but issues were identified that generally supported or opposed grizzly bear recovery. Many people asked for modification to an alternative, wanted parts of alternatives combined, or offered a completely different alternative. These were captured as well. Also, if a comment specifically referred to the Proposed Special Rule 10(j), this was coded as such. All substantive comments, accompanied by the appropriate coding for alternatives and issues, as well as demographic information, were then entered into a computer database for easier sorting and retrieval.

At all times, objectivity and fairness were stressed in this public comment analysis. All respondents' values, perceptions and opinions were captured, including those based on misinformation. The exact words of each respondent were used rather than summaries of the person's words to insure accuracy and objectivity. All letters were read at least three times by more than one member of the ?coding team@. A coder first read the entire response to gain an overall understanding of the respondent's viewpoint, then re-read the response, highlighting and coding substantive comments. To maintain accuracy and consistency, a coding supervisor or another coder would then check the coded response. If questions arose, they would discuss the response and come to agreement on the appropriate coding.

Form letters were grouped to insure that identical coding was used on each letter. Form letters and petition comments were entered into the database only once; however, the total number of signatures associated with the form or petition was recorded to reflect the number of respondents either submitting the form letter or signing the petition.

Although comments in technical or complex letters were coded and included in the database, they were also ?red-flagged@ because of their length and detail. Copies of these letters have been provided separately to the FWS interdisciplinary team for in-depth review. Letters from all government entities have also been provided to the interdisciplinary team for incorporation into the final Environmental Impact Statement.

Many chose to inform the FWS of their opinion more than once. Some spoke at one of the hearings, then sent a letter or signed a petition as well. Through alphabetical sorting of names, identical letters were identifed, then combined under one letter number and entered into the database only once. If multiple letters received from one individual or organization were different, the letters were treated separately.

DEMOGRAPHIC SUMMARY OF RESPONDENTS

This section presents demographic information of the responses received. Information displayed includes who responded (individuals, organizations, agencies, etc.), how they responded (letter, petition, resolution, etc.), and where they generally responded from .

WHO RESPONDED

 

ORGANIZATION TYPE

 

Number of Signatures

 

Business Owners/Interests

25
County Government/Representative 35
Environmental Interest 14,902
Federal Agencies 7
Individual Citizens 8,998
Congressional/Legislative Representatives 13
City/municipal/local government 10
Industry interest (ranching, timber, etc.) 49
Landowner within recovery area (if identified) 50
Professional scientific organization 7
Recreation Interest 7
State Government/Agencies 29
Tribal Government 3
Schools, universities 29
Coalition 30
Youth 53
Political Groups 4
TOTAL 24,251

 

HOW THEY RESPONDED

 

Response Type

 

Number of Signatures

 

Letter or Post Card

1,856
DEIS Summary Form 520
Hearing Transcript 294
Form Letter 217
Petition 21,362
Resolution 2
TOTAL 24,251

 

 

WHERE RESPONDENTS ARE FROM

 

 

 

Number of Signatures

 

Idaho

978
Montana 806
California 149
Oregon 27
Utah 129
Washington 86
Wyoming 15
Other States combined 505
Outside the United States 2
TOTAL 2,697*

* This figure doesn't account for names on petitions, nor for the many respondents who did not provide an address.

 

FORM LETTERS AND PETITIONS

FORM LETTERS

As letters were received, noticeable trends and similarities among them became apparent. Fifteen different form letters were detected totaling 217 signatures of which 76 percent are in general support of grizzly bear recovery and 24 percent opposed. Eight of the fifteen form letters are generally supportive of reintroduction of grizzly bears; seven are opposed.

Two of the form letters (totaling 9 signatures) do not specifically address any of the DEIS alternatives; however, they are strongly against grizzly bears and include the wording ?Just Say NO! to Grizzlies@ and ?the People of Idaho do not want grizzlies@. This exact wording is also found in several petitions, but because these individuals wrote a letter, the input was analyzed as a form letter.

Only one of the form letters (totaling 14 signatures) is supportive of the Proposed Alternative 1. These individuals are particularly supportive of aspects of a Citizen Management Committee. Another form letter (totaling 9 signatures) is critical of Alternative 1 and does not say which of the other alternatives they prefer, if any. Their criticisms of the Proposed Action are:

! ?Remaining security habitat, especially roadless areas on public lands in grizzly hatitat, should be maintained as roadless.@

! ?On roaded public lands in grizzly bear habitat, road densities should be maintained below one mile per square mile.@

! ?Key food source areas should be protected from human disturbance during bear use and from habitat destruction.@

! ?Isolated island grizzly bear ecosystems in the lower 48 should be reconnected.@

 

Two form letters (totaling 10 signatures) support Natural Recovery and ?No Action@ as outlined in Alternative 2, and also are against grizzlies. These respondents do not believe grizzly bears are ?endangered in vast wilderness areas in the world@; that the grizzly bear would negatively impact the small communities around the Selway-Bitterroot Wilderness?; and that @grizzly bears would decrease the quality of my wilderness experience?.

Three form letters (totaling 32 signatures) support Alternative 3 and are adamant about preventing grizzly bear recovery in the Bitterroot Ecosystem. They make the comment they want to ?leave the grizzlies where they are@.

Six form letters (totaling 143 signatures) support Alternative 4, Reintroduction of a Threatened Population with Full Protection of the ESA. In addition, they compare Alternative 4 with Alternative 1 along the following common themes:

Support Alternative 4 because:

! ?...it maintains full legal protection for all grizzly bears as a threatened species under the Endangered Species Act.@

! ?...it covers the entire Greater Salmon-Selway Bitterroot Ecosystem.@

Oppose Alternative 1 because:

! ?Alternative 1 removes grizzlies' legal protection under the ESA, including protection of habitat. It would remove the requirement for formal consultation with FWS on any development within grizzly habitat.@

! ?Alternative 1 removes female grizzlies currently designated as @threatened? from Yellowstone and Northern Continental Divide ecosystems and downgrades them to @experimental? status which removes their protection under the ESA.@

 

PETITIONS

Ten petitions were received containing 21,362 signatures. Of the total signatures approximately 76.6 percent favored grizzly bear reintroduction and 23.4 percent were strongly opposed.

Six of the ten petitions were adamantly against reintroduction. These were overwhelmingly generated and signed by ?local@ signators from the States of Montana and Idaho totaling 5,002 people. Of those petitions against reintroduction, only one mentions the alternatives. This one generated by Citizens Against Grizzlies, and totaling 2,866 signatures, states they are ?opposed to reintroduction of Grizzly Bears into the Bitterroot Selway Wilderness, therefore; ...(we are)...opposed to the 4 alternatives, as stated, in the draft...EIS submitted to the public for review.@

Three petitions were initiated or obtained from signature campaigns by the Defenders of Wildlife and the National Wildlife Federation in support of Alternative 1, the proposed action. The total for the Defenders of Wildlife petition was 4,430 and the two NWF petitions totaled 10,364.

The Alliance for the Wild Rockies initiated a petition in support of Alternative 4 which garnered 1,566 signatures.

Due to the volume, signatures were counted and recorded in the database, along with the coding and substantive comments, but the individuals' names and addresses were not entered into the mailing list.

Petitions in Support of Grizzly Bear Recovery

All of the petitions in favor of grizzly recovery address specific issues and alternatives. The Defenders of Wildlife and National Wildlife Federation's petitions spoke to the following issues in support of Alternative 1:

! ?I strongly support the @citizens management? alternative plan developed by Defenders of Wildlife and others that will allow local people and scientific experts to share in decisions on how bears will be restored and managed, and I urge you to proceed with final approval for grizzly reintroduction as soon as possible.@

! ?The plan is timely and cost-effective. Because it includes oversight by a Citizen Management Committee, it is acceptable to local residents. This tested approach to threatened species to an area specifically set aside by our government for the protection of wild lands and wild species has the full cooperation of coalitions from the timber industry.@

! ?The NWF proposal has widespread support - from the timber industry, from local citizens who will have input, and from conservationists who eagerly desire to see the grizzly returned to its rightful home...@

The petition generated by the Alliance for Wild Rockies in support of Alternative 4 raised the following points:

! ?...it represents the most scientifically viable way to restore grizzly bears to their rightful home in the Bitterroots.@

! ?I want all grizzly bears to receive full legal protection as a threatened species under the Endangered Species Act....if grizzly bears are to survive, they need protection of roadless areas and they must be connected with other...populations with corridors.@

! ?Alt. 4 is a common-sense, habitat-based approach and is the only alternative that satisfies my concerns. However, I am deeply opposed to taking any bears from threatened populations for reintroduction into Idaho and insist that Alternative 4 be amended to remove that possibility.@

! ?I am strongly opposed to...Alternative 1, which promises to weaken already threatened grizzly populations, fails to ensure the survival of a Bitterroot population, and does nothing to increase the chances of grizzly bears overall. It is also a bad idea, as well as a dangerous precedent, for a group of politically-appointed special interests to manage grizzly bears.@

Petitions in Opposition to Grizzly Bear Recovery

Twenty three percent of the petition signatures oppose grizzly bear recovery in the Bitterroot Ecosystem. Although only one of these six petitions mentions alternatives (as outlined above), the remainder are loud and clear on how they feel about reintroduction specifically and grizzly bears, in general. The issues most often addressed in these petitions include:

! ?The undersigned citizens are opposed....because of the threat to life and property, and restrictive use of this area.@

! ?We urge the Idaho State Governor to exercise the rights of this state according to the 10th amendment of the Constitution...The federal government agencies need to impose their plans and alternatives upon a different people and a different area than the people of this Great State...@

! ?The purpose of this petition is to display...our opposition to said Introduction, and further to request that (the receiver) honor and respect our wishes on this subject, and pray that we don't become prey of the Grizzly Bear or the U.S. Fish & Wildlife Service's plans.@

A petition signed by thirty members of a family in Idaho express the following concerns:

! ? Aside from the threat it would be to the livelihood of Idahoans--mining, lumber, livestock, recreation and tourism, we, as a family would be personally affected. Some members kayak and white water raft in the Salmon River area. Some trailride, horseback in the high country, and have been doing that for about forty years. We love our high country, and do not want our trips there spoiled by threats of grizzly bear attacks. PLEASE DO NOT CONTINUE WITH THIS PROJECT.@

 

HEARING TESTIMONIES

Seven hearings were held in Montana and Idaho attended by approximately 1400 people with 294 people testifying. The Salmon and Hamilton hearings both had more people attend the hearings and register to speak than there was time allowed. The dates and locations for the public hearings were:

Wednesday, October 1, 1997: Challis, Idaho and Hamilton, Montana

Thursday, October 2, 1997:Missoula, Montana and Lewiston, Idaho

Friday, October 3, 1997: Boise, Idaho and Helena, Montana

Wednesday, October 8, 1997: Salmon, Idaho

Strong feelings were voiced by those providing testimony on the proposal to reintroduce grizzly bears as well as vocal support or opposition to grizzly bears in general. A summary of the pro's and con's is provided here to display the general flavor of those testifying at the hearings. Individuals registered to speak who did not get their name drawn could choose to provide written comments for the record. These comments are also analyzed in this report along with others in the Alternatives and Issues chapters.

Hearing Summary

 

Location of Hearing

Attendance

 

Total Testified

 

Number pro/con/ and unknown*

Challis, Idaho 155 29 6/20/3
Hamilton, Montana 200 50 22/23/5
Missoula, Montana 258 56 49/1/6
Lewiston, Idaho 127 45 27/16/2
Boise, Idaho 148 47 28/15/4
Helena, Montana 37 18 14/3/1
Salmon, Idaho 442 49 11/25/13
TOTAL 1,367 294 157/103/34

*Unknown is for those people who did not express support or opposition to reintroduction of grizzly bears in general, or to any of the four alternatives.