Executive Summary of Public Comments Draft EIS for Grizzly Bear Recovery April 1998
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
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 regarding 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 public comments will help the decisionmaker make better decisions, not simply count pros and cons. 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 information 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 Summary of Public Comments and the Executive Summary of Public Comments on the Draft EIS for Grizzly Bear Recovery in the Bitterroot Ecosystem are both available on the internet at: http://www.r6.fws.gov/endspp/grizzly.
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 began 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 began July 11 and ran 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 1,400 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, 1997 - 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 Nonessential Experimental Population Alternative (Proposed Action):
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.
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, where the respondent is from, the medium used for responding, and the respondent's overall preference for or against grizzly bear recovery.
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,
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 on pages 5 and 6 of this document.
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 coments 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 were provided separately to the FWS interdisciplinary team for in-depth review. Letters from all government entities also were 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 identified, 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.
Number of Signatures
|Industry interest (ranching, timber, etc.)||49|
|Landowner within recovery area (if identified)||50|
|Professional scientific organization||7|
HOW THEY RESPONDED
Number of Signatures
|Letter or Post Card||1,856|
|DEIS Summary Form||520|
WHERE RESPONDENTS ARE FROM
Number of Signatures
|Other States combined||505|
|Outside the United States||2|
FORM LETTERS AND PETITIONS
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 Preferred Alternative. 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.
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.
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 petition, 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 (NWF) 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.
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 sections.
|Location of Hearing||
|Number pro/con and unknown*|
COMMENTS ON ALTERNATIVES
Public comments on Alternatives 1 through 4 are presented in this portion of the report. Within the discussion of each alternative, text is broken into three sections: comments favoring the alternative, comments against it, and comments suggesting modifications. The other comments received on issues are found in the second major portion of this report, Comments on Issues. A summary of each alternative is presented at the beginning of each alternative discussion.
No respondents suggested combining aspects of one alternative with another; however, some recommended entirely different alternatives. These suggestions are provided following the discussions of Alternatives 1 through 4.
In the following discussions on alternatives, representative quotes from respondents' letters, testimonies, etc. are used to illustrate what the majority of people said about each alternative. In order to protect the integrity of the individuals' responses, the quotes used are exactly as provided, including syntax mistakes, grammatical errors, and some misinterpretation of the data.
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."
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."
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."
THE NO ACTION ALTERNATIVE
ALTERNATIVE 2: 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 Bitterroot Ecosystem (BE). The ultimate goal is natural recovery of grizzly bears in the BE.
This alternative received little attention when compared to the others. As pointed out by the Bitterroot National Forest Supervisor at the time, "Most of the discussions have centered around how bears will be reintroduced, not if they will be reintroduced. It does not appear that the NO Action Alternative has received the same considerations as the other alternatives."
The majority of the respondents who support Alternative 2 feel the time frame of natural recovery would allow everyone to adjust to the presence of bears; therefore reducing bear-human conflicts. Many state that if left alone in the proper habitat , the existing bear population would recover. A popular reason to support this alternative is its low cost. Full protection under the Endangered Species Act is also a favorite argument from many respondents. This means habitat protection and less liberal "take" provisions.
"Natural recovery has the best chance for long tern success if combined with habitat protection and restoration measures."
"Please save the taxpayers some money and support Alternative 2."
Opponents of Alternative 2 feel natural recovery wouldn't happen because it would rely on bears migrating from other ecosystems, and there are no management practices to encourage migration. Some feel this alternative is an attempt by the federal government to remove the people from public lands or to remove private property rights under the authority of the ESA. Many persons feel the time frame in Alternative 2 is too long. The threat of grizzly bears to human safety is a recurring concern.
"Grizzly bears attach people, unlike the Fish and Wildlife Service, I do not believe there is an acceptable level of injury and death caused by grizzly bears."
"We do not need our forests and other public lands shut down and put people out of jobs to encourage the grizzlies to roam into our back yards and endanger our lives."
Those suggesting modifications to Alternative 2 like the idea of natural recovery, managing corridors between the Cabinet-Yaak and the Bitterroot ecosystem, and oversite of the Citizen Management Committee.
"Alternative 2 might be a reasonable approach, if the USFWS would undertake a project to provide a viable migration corridor which would link the Cabinet-Yaak ecosystem to the Bitterroot ecosystem."
"The proposal should be modified to implement the formation of a CMC to manage grizzly bears..."
ALTERNATIVE 3 - THE NO GRIZZLY BEAR ALTERNATIVE
ALTERNATIVE 3: This alternative would prevent grizzly bear recovery in the Bitterroot Ecosystem.
Alternative 3, the No Grizzly Bear Alternative received the third largest amount of comments (behind Alternatives 1 and 4). People do not want bear recovery in the BE for several reasons: concerns for human safety, the possible negative effects to the local economy and land use restrictions being the most common. Many people feel that the grizzly bear is simply a tool used by the federal government to reduce private property rights and restrict personal freedoms. An additional concern is the cost of the program to the taxpayer. People feel there are more important projects that could be funded with their tax dollars: roads and school improvements. Some feel the grizzly bear is not a Threatened species and their tax dollars should not be spent on this program. Many people denounce returning grizzlies to the BE after all the hard work that their ancestors went through to remove the bear. Many are concerned about the negative impacts grizzly bears will have on other wildlife species: deer, elk, and salmon. People are concerned that their hunting opportunities will decrease while the dangers of hiking and camping in the back country will increase.
"We are opposed to the introduction of grizzly bears into the State of Idaho and are very disappointed in the attitude of our Federal Government's apparent willingness to ignore the opinions of the elected officials of Idaho and our rights as a state. Our views are those of our delegation in Congress, our director of the State Fish and Game Department, and the citizens of Lemhi County."
"I feel that the grizzly bear recovery will have a drastic effect on the cattle industry, and its getting extremely difficult to make a living at anything in these days. This will also have a large impact on the lumber, timber, and paper industries. I feel that the recovery of the grizzly is not as vital as the sustaining of human lives."
In a form letter, 21 people from Idaho comment:
"We were all doing just fine before the Fish and Wildlife Service 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 Selway Bitterroot system doesn't need you , and I would respectfully request you and your ideas and your bears to stay out and leave us alone."
People express opposition to Alternative 3 for several reasons. Some feel it was illegal under the ESA to prevent natural recovery that could occur. Others feel the Fish and Wildlife Service should have an active plan to restore 'an integral part of the ecosystem'. Many oppose this alternative simply because they want the Fish and Wildlife Service to take a more active role in bear recovery.
"...under Alternative 3, the USFWS would not fulfill its legal mandate to protect the species and its habitat..."
Few comments actually suggest modifications to Alternative 3. Most feel this Alternative was incorrectly identified or evaluated.
REINTRODUCTION OF A THREATENED POPULATION
WITH FULL PROTECTION OF THE ESA
ALTERNATIVE 4: 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 majority of commenters who specifically address Alternative 4 are supportive of it (approximately 78% of Alternative 4 comments). Approximately 6% of the comments that specifically address Alternative 4 are critical of it; and about 16% suggest modifications. Supporters of Alternative 4 are also vocal in their opposition to Alternative 1, which influences the percentage of comments that are critical of Alternative 1. Alternative 1 supporters, however, are not as critical of Alternative 4 and this is reflected in the lower percentage of critical comments for Alternative 4 as compared with those critical of Alternative 1.
Additionally, the FWS received a petition with 1,566 signatures in support of Alternative 4 from the Alliance for the Wild Rockies. The petition indicates that Alternative 4 represents, "The most scientifically-viable way to restore grizzly bears to their rightful home in the Bitterroots," and lists numerous reasons for this statement. It also states numerous reasons the supporters of this petition oppose Alternative 1.
COMMENTS FAVORING ALTERNATIVE 4
Supportive comments of Alternative 4 include many reasons why it is the best choice for the grizzly bear and for the Bitterroot Ecosystem. Many people feel the large recovery zone in Alternative 4 is essential for grizzly bear recovery in the BE because it provides adequate space and food resources for a viable population of bears. They also suggest that the recovery boundaries include the entire "Greater Salmon-Selway Bitterroot Ecosystem" which is essential for holistic management of the bear and other ecosystem components.
There is strong support for reintroducing and recovering grizzly bears with full protection as threatened species under the ESA. Many people feel this is the only way to insure the survival of grizzly bears in an area where the public is not totally supportive, and the only way to insure protection of essential habitat through Section 7 consultation with the FWS. Protection for the grizzly is a major concern of supporters of Alternative 4.
Another common response is that the planning, implementation, and management of the recovery project needs to be guided by the best available science, and they strongly support the Scientific Committee. There are also a number of supportive comments about the proposed linkage zone to the Cabinet-Yaak Ecosystem, and the habitat restoration proposal to reduce road densities and increase habitat security in the recovery zone. Respondents feel Alternative 4 will insure genetic diversity of the grizzly bear metapopulation in the Northern Rockies through linkage with other grizzly bear ecosystems. They also support the restrictions on resource extraction activities, and feel ecosystem protection (especially roadless areas) and restoration of the managed landscape are beneficial to all species, including humans.
In general, supporters of Alternative 4 are not concerned with the effects that grizzly bears will have on human safety, hunting opportunities, recreational opportunities, and other wildlife species. They see many benefits, rather than detractions. There are many comments pertaining to the spiritual value of returning the magnificent bear to its native habitat, and of putting the "wild" back into the wilderness. Supporters also comment there will be economic benefits to local communities from the creation of restoration jobs, and increases in tourism.
"The IBA strongly supports reintroduction of grizzly bears into the Selway-Bitterroot Wilderness areas of Idaho and western Montana...Alternative 4, the "conservation biology" alternative, is the strongest alternative from the purely biological perspective."
"In my views this is the only alternative that has a chance for grizzly recovery."
"I fully support reintroduction of grizzly bears in the Bitterroots and Salmon-Selway ecosystem. Please select Alternative 4, the Conservation Biology Alternative, and implement the reintroduction of giving grizzly bears full protection under the Endangered Species Act, as well as beginning habitat restoration work."
"...may well be determined by a scientific committee that no acceptable source population exist, but by protecting habitat and establishing linkage corridors between current populations and the Greater Salmon-Selway Ecosystem what over the long term, a healthy, viable population will establish itself in the next century...only need to give the bears an opportunity."
CRITICISMS OF ALTERNATIVE 4
Relatively few (6%) of the respondents who specifically refer to Alternative 4 are critical of it. Some commented about the stringent protection for the grizzly bear and its habitat under this alternative. They feel local residents will not accept grizzly bears with ESA threatened status. They think this will lead to increased illegal take of reintroduced bears from resentful local residents, and they are also concerned about the perceived lack of legal protection afforded local landowners from grizzly bears protected under ESA threatened status. There is concern that private property rights will be subjugated by the ESA protections under this alternative. Others don't think there are any suitable source populations of bears for the BE. Several commenters fault Alternative 4 because it does not provide for any local control in the management of reintroduced bears. One commenter thinks the Scientific Committee concept is unconstitutional.
The habitat suitability for grizzly bears in the large recovery zone is questioned. The Alternative 4 analysis of effects to human safety is questioned, and commenters don't like the fact that more protection is offered the bear than is assured to humans. Many respondents are concerned that Alternative 4 will negatively impact ranching, motorized recreational opportunities, and access to public lands. There are numerous criticisms of the economic analysis for this alternative. One critic thinks this alternative has the ulterior motive of influencing land management decisions, and is not about grizzly bear recovery. Others don't think the alternative is politically feasible.
SUGGESTED MODIFICATIONS TO ALTERNATIVE 4
Some of the respondents (16%) who specifically refer to Alternative 4 provide suggestions for change. There are a few requests for additional analysis to determine habitat adequacy. An extremely popular requested modification to this alternative is to not use threatened populations of grizzly bears as source populations for the BE, but instead to allow the Scientific Committee to determine if other un-threatened populations could provide bears for reintroduction to the BE. A few oppose using Canadian bears for reintroduction, while others encourage the use of bears from Canada and Alaska. Others are not in favor of reintroduction of bears into the BE, but would support Alternative 4 without reintroduction and increased focus on natural recovery. Some commenters want more specific monitoring measures, and others don't want reintroduced bears radio-collared and monitored. Some comments suggest the incorporation of a Citizen Management Committee into Alternative 4, i.e. combining the strengths of Alternative 1 and 4. One person wants Alternative 4 changed to give reintroduced bears "experimental essential" status under ESA 10(j). A few respondents think the recovery goal should be determined by the Scientific Committee, and not at this early stage. A few people want Alternative 4 to designate other linkages to the YE and NCDE. One person thinks an aggressive habitat restoration program should be implemented and reintroduction delayed, while another person thinks the habitat restoration program in Alternative 4 is too aggressive, and FWS Section 7 consultation would adequately protect grizzly bear habitat. Commenters emphasize the need for an intensive, and proactive public information and education campaign to be initiated well before reintroduction occurs.
"...writing to support reestablishment of ...don't think any of the alternatives are adequate, however, we favor a modified Alternative 4."
"We also suggest adding a change to Alternative 4 to say that no bears may be taken from threatened populations including the Greater Yellowstone and Glacier/Northern Continental Divide ecosystems for reintroduction to Idaho. Instead, let the Scientific Committee determine whether there are unthreatened populations which can provide a source of bears for reintroduction."
ADDITIONAL ALTERNATIVES SUGGESTED
Several respondents suggest alternatives to be considered in addition to the four examined in detail in the DEIS. Although some of these suggestions may only be modifications of Alternatives 1 through 4, or may have already been considered in the DEIS, they are listed here as they are presented by the respondents.
A popular suggestion by many is to include a "true" No-Action Alternative.
"I would like to see you analyze one other alternative and that would be the true no action alternative. That would involve like tomorrow quit doing this analysis, quit trying to reintroduce the bears, and should the bears make it there or if they may already be there, just leave them alone. I know that probably won't fit the purpose and need for the analysis, but then again, I'm not really sure what the need is yet."
A few respondents suggest returning grizzly bear management to the states:
"One you don't mention is to return management to the state of Montana, which was doing a good job. The alternatives you do mention are all self-serving."
"Lets have a bill before the State and a public referendum."
Another favorite option is to include an alternative to "delist" the grizzly bear:
"The U.S. Fish & Wildlife Service can recognize that the grizzly bear population within the study area is extinct and can be delisted, or that an error was made and the population should not have been listed. Delisting removes the responsibility for populating the area under ESA and the controversy is resolved."
"Delisting does not require modification of legislation or regulation...the ESA and associated regulations expressly provide for delisting where a species is no longer threatened. Conversely, the FWS acknowledges the No Grizzly Alternative would require substantial modifications of both federal and state law. Delisting is a reasonable primary alternative, both standing alone and in comparison to the No Grizzly Alternative. This requires the FWS to revise the DEIS to include delisting as an alternative."
A couple people suggest an additional alternative with biologically defined boundaries rather than social:
"...the boundaries of the recovery area are socially defined rather than biologically defined. If grizzly bear habitat does indeed become of higher quality as one goes further north in Idaho, then it would be logical to consider inclusion of portions of the St. Joe River drainage, and perhaps areas further north and closer to the Cabinet-Yaak recovery area. However, this was not even included in the recovery plan. With the socially defined boundaries for the northern portion of the recovery area...then it seems appropriate to consider the southern boundaries as well. I suggest the area east of the Middle Fork of the Salmon River and south of the Big Creek drainage in the Frank Church River of No Return Wilderness be deleted from the recovery area. The Mattson and Merrill appraisal suggests that areas in Custer and Lemhi Counties within the FCRNRW are not especially good grizzly bear habitat. These areas are close to grazing allotments, a mining district, and intensively used recreational areas in the Stanley Basin. There is substantial opposition to grizzly bear recovery in these counties and recognition of this may alleviate some concerns."
"The greater Selway-Bitterroot Ecosystem represents one of our last chances to save an ecosystem of significant size in the planet's temperate zones. Because the GSBE is unique..., it should probably be made a world biological preserve with a future determined strictly by biologists who are absolutely free of industrial and political pressure... The DEIS fails to consider such an alternative..."
A few feel a compensation program needs to be included in an alternative to show support to the ranching community.
"I believe that a compensation program is essential to get the support of the ranching community for the grizzly bear recovery program."
The following three suggestions are also indicative of the broad range of alternative possibilities there are:
"The experimental/non-essential recovery area should be designed more as a "containment zone" to keep the bears contained strictly within the core recovery area inside the Selway-Bitterroot, Frank Church, and Gospel Hump Wilderness Areas. To do this, you need to give the bear "varmint status" whereby any grizzly found outside the wilderness but inside the "containment zone" could be shot and killed on sight by anybody with a valid hunting license, and with no further justification or authorization required by the USFWS. This "varmint status" would habituate most bears to remain only in the wilderness areas."
"Maybe the supporters of the reintroduction experiment could start a fund called Help and Aid to Victims of Aggravated Bear Encounters, Attacks and Run-ins. H.A.V.A.B.E.A.R. could cover legal fees, hospital costs and investigative activities."
"As you can gather from my comments I think all four of the alternatives are garbage, so I propose Alternative 5.... First of all there would be no designation of a boundary around any of the land in Idaho. Second, if a grizzly bear walks under his own power (without being herded, baited, or somehow coerced) into some federal, state, or private land in Idaho, so be it. He or she can live there without being harassed or studied to death.... If the population gets to a sustainable size (to be determined by the Idaho Game Dept.) then we have a hunting season on them. If the...Game Dept. decides any bear is a nuisance or is adversely affecting other animal populations they can be killed (or moved somewhere else)...Any movement of bears must be approved by the local people and industries directly involved in the area where the bear is going to be moved to. This all sounds to me like what we have in place now, well let's leave it alone then and we'll call this Alternative 5, "the cheap, less regulatory, and safer alternative."
COMMENTS ON ISSUES
This section addresses each of the issues identified in the analysis of public comments. The issues are presented by logical groupings rather than by the numerical code number listed beside it. The code numbers were assigned during the analysis process as a tool for the content analysis team to categorize comments.
100 DEIS (DRAFT ENVIRONMENTAL IMPACT STATEMENT)
CORRECTIONS TO FACTS & DATA IN THE DEIS (101)
QUESTION THE DATA USED (102)
Many people question the data used throughout the DEIS. They make the general comment that the data is basis for meeting the objectives of the reintroduction program. Many people question if the habitat in the BE (Bitterroot Ecosystem) can support a recovered grizzly bear population. Some people feel grizzly bears exist in the BE currently at a level the habitat can support. The data presented in the Economic Analysis is disputed by people both for and against bear recovery.
There are many questions asked and comments made about specific items in the document, as well as suggestions for corrections or changes on specific pages. Because there are too many of these to print in this summary and they are too varied to summarize, they are provided to the USFWS in a separate document.
COMMENTS ON THE PROCESS & PUBLIC INVOLVEMENT (103)
(Compliance with NEPA)
Many people feel the DEIS violates NEPA, the National Environmental Policy Act, because it doesn't offer a true range of alternatives including a 'No Action' Alternative. Conversely, some respondents state the 'No Action' Alternative should not be included in the DEIS because that action would be a direct violation of ESA. Respondents frequently call for a new DEIS and analysis. Some people believe more public hearings should have been held and others request a state-wide referendum on the reintroduction. Some people comment that the public hearings were 'rigged' because elected officials were allowed to speak first and were not subject to a random drawing. Several people are particularly critical of the Salmon hearing. They are concerned that the hearing officer did not enforce the ground rules which resulted in some people becoming so intimidated they did not express their views on the issue. Many people question whether their comments will count or make a difference, that the decision has already been made, and the FWS is not going to listen to local concerns. Several people claim the public involvement process was not well publicized. They contend the effected people were not informed about the hearings nor were people coached on how to make official comments.
PURPOSE AND NEED (104)
(Why here? Why now?)
People who question the need to reintroduce grizzly bears into the BE feel the grizzly is not endangered. The fact that there are many bears in Alaska and Canada confuse people on why the bear is listed in the lower 48 states. People comment that there are bears in Yellowstone and in the Northern Continental Divide Ecosystem, so why should we reintroduce them into the BE? If reintroduction of grizzlies into the BE is critical to their survival, why is the preferred alternative an 'experimental non-essential' population? Some people feel there is a population of grizzly bears currently in the BE and the FWS should not play an active role in this population's expansion.
PUBLICATION OF PROPOSED RULE IN FEDERAL REGISTER (105)
EXPERIMENTAL, NON-ESSENTIAL POPULATION (215)
CONSULTATION WITH THE FISH & WILDLIFE SERVICE (216)
ENDANGERED SPECIES ACT (304)
These issues are being addressed together because of their similarities and interrelatedness.
1. Publication of the Proposed Rule in the Federal Register: Most of the comments regarding the publication of the Proposed Rule are critical. Most respondents feel it does not meet the design or intent of the Endangered Species Act and circumvents the present protection given to grizzly bears. They question whether it is legal to publish the preferred alternative and not the other alternatives because it appears the decision is already made. They also claim this violates the intent of NEPA to present all alternatives in an equal fashion. They suggest numerous changes to the wording in the proposed rule.
2. Experimental, Non-essential Population: A few individuals support the experimental, non-essential designation as provided in Alternative 1 and published in the proposed rule. Their primary reason to support this designation is it allows more flexibility in dealing with human/bear conflict that would not exist were the grizzly bears to enjoy the full protection of the Endangered Species Act. On the other hand, critics of this designation claim it would provide no protection of habitat while altering the status of the grizzly bears which would undermine the ESA. Several respondents claim there is evidence grizzly bears are already in the area and designation as experimental, non-essential must be denied. Some claim the agencies are trying to justify the experimental, non-essential designation by artificially isolating the Bitterroot Ecosystem.
3. Consultation with the Fish & Wildlife Service: Most of the comments are critical of Alternative 1's proposal to allow for resource extraction activities to continue without formal Section 7 consultation under Section 7(a)(2) of the Endangered Species Act. Many see this as sacrificing habitat needed to ensure the grizzly bears will survive. A handful of people feel doing away with Section 7 consultation is a good idea. They say it will give management agencies more flexibility and that formal consultation creates a negative impact on recreational use of the forests.
4. Endangered Species Act: A few individuals applaud the Fish & Wildlife Service for their positive and significant breakthrough interpretation of the Endangered Species Act. Most of the comments, however, were extremely critical of what they see as a misinterpretation of the ESA. Many question the legality of altering the protective status of the grizzly bears under the proposed action, and that it would undermine the integrity and intent of the ESA. Several also point out that Section 10(j) contains no provisions that authorize delegating ESA responsibilities to a citizen committee. Supporters of Alternative 3 frequently call for de-listing the grizzly bears as they believe there are plenty of grizzlies now. Critics of Alternative 3 claim it does not meet the legal mandates of the ESA and should not have been included in the DEIS. A great number of individuals who support Alternative 4 say it is because it maintains full protection under the ESA for all grizzly bears.
REVISE CURRENT ANALYSIS (106)
NEED FOR RESEARCH (410)
Comments toward revising current analysis and suggested research topics are wide ranging and diverse. Several themes do appear: the economic analysis does not represent real dollars, the cost of the proposal is underestimated, and the losses to wildlife and livestock are underestimated. Other issues mentioned in lesser degrees are: what is the maximum number of bears that will be in the BE, genetic isolation from other bear populations, habitat suitability of the BE, the effect of a growing human population within the recovery zone, and logging in the Cove Mallard roadless area.
ADDITIONAL ANALYSIS NEEDED (107)
Many individuals suggest additional analysis is needed. Those comments fall into the major categories outlined below. Other concerns raised less frequently include the effects of recovery activity on wilderness and wilderness values from motorized intrusions. Several people question the validity of the survey and economic analysis done by the USFWS stating they do not know of anyone contacted for such studies. People want a better explanation of how expected human injury/mortality and livestock losses were developed. People request more information on how the Citizens Management Committee will operate, whether their actions will be subject to NEPA, and how internal conflicts will be resolved. Several people call for more analysis on the effects of recovery on recreation and hunting opportunities within the recovery area. One person feels the DEIS did not account for inflation and the real cost of goods and services over time with regards to the projected budgets. Another individual claims the Grizzly bear DEIS needs to be integrated with the Upper Columbia River Basin DEIS.
200 - MANAGEMENT STRATEGIES
STRATEGIES TO CONTROL NUISANCE GRIZZLIES (201) (MOVING/KILLING/BEHAVIORAL CONDITIONING)
Comments on this issue are divided between those who want to see grizzly bears shot for harassing livestock and those who do not want to remove such bears. No one suggests any new techniques for handling bear conflicts. Several people are concerned about the additional burdens that nuisance bears will put on their livelihood. It is not clear to the public that the IGBC Nuisance Bear Guidelines exist and how these will effect bear management in the BE. Some people feel nuisance bears wouldn't be an issue if they were not transplanted in the first place. Others comment on the appropriate time for a member of the public to shoot a bear. Some feel it should be allowed to protect one's property while others believe the only time to shoot a bear should be in defense of human life.
ILLEGAL KILLING OF GRIZZLY BEARS (202)
HUMANE TREATMENT OF GRIZZLIES (205)
EFFECTS TO GRIZZLIES (407)
(GENETICS, DISEASE, COLONIZATION, BEAR SAFETY ADEQUATE FOOD)
Few people comment on illegal killing directly. Some feel if grizzly bears were placed in the BE that the local people would shoot these bears advocating a "shoot, shovel and shut up" policy. Others emphasize the need for full protection under the ESA to reduce human mortality. Some people believe a grizzly bear should be able to be shot in defense of personal property. A few comments relate to the treatment of the bears themselves. People feel the capture, handling and relocating of bears is cruel and inhumane.
Many people contend the habitat base is not present in the Bitterroot Ecosystem to support a healthy grizzly bear population. Since there are few berries, white bark pine and no salmon runs exist, people are worried that the bears will have no food. The bears will then move to the valley floors in search of food and running into conflicts with the local residents . Many people are concerned about the genetic isolation of a recovered bear population in the BE. They emphasize the importance of corridors to promote interchange between populations of bears.
REGULATED PUBLIC TAKE OF GRIZZLY BEARS (203)
Comments on this issue range from both ends of the spectrum. Some people feel it is imperative they have the ability to control a depredating bear immediately. People feel they will not be able to protect their life, a family member, friend, or livestock without criminal prosecution. Others feel that with too much freedom, locals that are fearful of the bear will kill them indiscriminately. Several people comment that excessive human induced mortality is part of the reason the grizzly is gone from the Bitterroots. Several people advocate a hunting season on grizzly bears to make them afraid of humans. Some of the questions raised on this issue are already addressed in the IGBC Nuisance Bear Guidelines.
COMPENSATION FOR LIVESTOCK KILLED BY GRIZZLIES (204)
The majority of the few comments on this issue support the idea of compensating private stock owners for their losses caused by bears. One person feels that, "Someone grazing cattle on public land should not be paid for cows taken by a bear." Several people suggest a compensation program similar to the one for the wolf reintroduction, and that the USFWS needs to be fiscally accountable for the program. They raise the question of who will pay if the funds are not donated to the groups who support compensation now, such as the Defenders of Wildlife.
RECOVERY AREAS (Grizzlies Traveling into Experimental Area) (206)
RECOVERY AREAS (what are the actual boundaries of recovery area) (207)
RECOVERY AREAS (where people want grizzlies) (208)
RECOVERY TIME (209)
The above issues have been combined into this summary because of their similar nature. Few commented on bears traveling into an experimental area. Some people feel that the recovery area needs to be increased to protect more habitat and increase the probability of grizzly bear recovery. Several people have questions about bears leaving the experimental area and how these bears will be dealt with when they come into conflict with humans.
A significant number of comments pertain to the size of the Recovery Zone. By far the majority of the people feel that the area needs to be increased and that the, "Boundaries of the recovery area are socially defined rather than biologically defined." Many people feel that the size of the current proposed area will limit the probability of grizzly bear recovery. People do not like the recovery area drawn out in Alternative 1 and support the area suggestions in Alternative 4. Only three comments state that the recovery area is too large and should be reduced.
People are divided about having bears in the Bitterroot Ecosystem. Some are adamantly opposed while others are just as strongly supportive of the reintroduction effort. Some people are concerned that there will be bears in their back yard. Others feel it will return the ecosystem to its natural order.
With respect to the time frame outlined for grizzly bear recovery, a small number of people commented. Most feel the ten year evaluation period for the project is too short. People note that grizzlies have a low reproductive rate and it may take some time for the population to grow. Some people feel that the projected recovery time of 100 years is too long and will be a waste of tax dollars.
BEAR SOURCES (210)
A voluminous number of people commented on where reintroduced grizzly bears will come from. By far the largest concern people have is taking bears from the Northern Continental Divide Ecosystem (NCDE) and Yellowstone Ecosystem (YE) populations that are currently listed as Threatened. People believe relocated bears will no longer be protected as a threatened species. A second concern commenters have is that the removal of these bears from their respective ecosystems will hasten meeting the ecosystem's recovery objectives. Based on these assertions, several people feel that the proposed transplanting is illegal. Many people suggest a "scientific committee" should determine where there are unthreatened populations which can provide a source of bears. Two people suggested "crossfostering" grizzly bear cubs with female black bears in an effort to get bears into the Bitterroot Ecosystem. A small number support taking one or two bears form the YE and the NCDE each year. A Scout Leader is concerned about placing "park" bears in Idaho, he feels that these bears are unafraid of humans, and therefore pose additional risk to him and his troops. Idaho Fish and Game is concerned that the Bitterroot Ecosystem will become, "A depository for problem bears."
GRIZZLY RECOVERY IN OTHER AREAS OF THE COUNTRY (212)
A variety of comments relate to how management of grizzly bears in other areas affects management in the Bitterroot Ecosystem (BE). One theme among these comments is delisting and how it relates to bear management in the BE. People do not want the BE reintroduction effort to divert USFWS time and money from the delisting process in the Yellowstone Ecosystem and the Northern Continental Divide Ecosystem.
Most comments on this issue pertain to people's concerns on how monitoring occurs throughout the reintroduction effort and then how monitoring will help in project evaluation. Several people object to placing radio collars on bears because, "It's a symbol of wilderness." Several also do not believe the DEIS clearly states the criteria to use in determining the "success" or "failure" of the reintroduction. Technical letter 836 from the Nez Perce Tribe suggests specific criteria to evaluate the project. The comments are quite detailed and the FWS is referred to the original letter for the complete suggestions.
CAPTURE AND RELEASE METHODS (214)
The main concern people have about handing bears is its effect on the bears themselves. People question whether the handling operation itself somehow changes the bear and it's outlook on humans. Others would like a more detailed description of which bears will be relocated and where they will be released.
PROTECT GRIZZLIES (217)
HABITAT PROTECTION/SECURITY/RESTORATION (308/408 412)
EFFECTS ON GRIZZLIES FROM HUMAN INCURSIONS (409)
These issues are analyzed together because the comments overlap greatly. The vast majority of people who make comments regarding the habitat and security of grizzly bears are people who favor Alternative 4 because they feel it would provide the best chance of successful reintroduction. A large percentage of these people at the same time speak in opposition to Alternative 1, saying it would not provide the habitat and security grizzlies need. Respondents who feel habitat security is a priority feel road removal and protection of roadless areas within the recovery zone should be a priority. People are concerned that a road density standard is not established for the Bitterroot Ecosystem in this DEIS, some suggest that road densities be maintained at less than .25 miles/sq. mi. Many feel management standards in place for other fish and wildlife will not be adequate for grizzly bear recovery.
CITIZEN MANAGEMENT COMMITTEE - CMC (218)
While many applaud 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 will 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. Also, 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.
Comments pertaining to Alternative One:
Numerous respondents who support Alternative 1 primarily cite the CMC 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 together. Many say that the CMC is the strength of the proposed action. Several 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 involved in its development. 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 CMC concept. These comments are further analyzed in the write-up for Alternative 1 in this report.
There are numerous critics of Alternative One's Citizen Management Committee. Several respondents state the CMC proposal is illegal because the Secretary of Interior is not legally able to delegate decision-making authority to this group. Conversely, many oppose the concept because they don't feel the Citizen's Management Committee would be given enough decision-making authority. There is considerable mistrust by many that as soon as bears have been introduced the Secretary of Interior will reassume the authority granted to the CMC in the special rule. Numerous individuals call for more clarity in the delegation of authority to the CMC as well as what actions the CMC is likely to take.
A few respondents are concerned that this project will promote single-species management that will overlap into land management decisions on the whole recovery area and adjacent lands.
Comments Pertaining to Alternative Two:
Proponents of Alternative 2 suggest grizzly bears should be allowed to recover naturally while being managed by the Citizen Management Committee as outlined in Alternative 1.
Comments Pertaining to Alternative Three:
There were no CMC comments on this Alternative.
Comments Pertaining to Alternative Four:
Supporters of Alternative 4 believe grizzlies in the Bitterroot Ecosystem should be managed by a Scientific Committee and existing management agencies, and not by the CMC as proposed under Alternative 1. They are concerned about political influence in selection of the CMC, management of such an important species by nonprofessionals, and by the unfair delegation of management of a national resource to local citizens and their interests. Some comments suggest the incorporation of a CMC into Alternative 4 which they see as combining the strengths of Alternatives 1 and 4. A number of respondents want a modification of Alternative 4 to include a CMC, or at least include some local citizens on the Scientific Committee to insure local concerns are heard in the decision-making process.
BEAR MORTALITY QUOTAS (219)
Of the few comments received on this issue, the majority apply to the effect of bears removed from NCDE or YE for reintroduction on the donor ecosystem's allowable human-induced mortality quotas. The state of Montana feels that transplanted bears should not be counted against mortality quotas or impede the delisting procedure. Private interests on the other hand feel that bears removed from either the NCDE or YE should count against mortality quotas, and therefore the FWS should not remove bears from either of these two ecosystems.
300 LAWS, RESTRICTIONS, RIGHTS, AUTHORITY
FEDERAL, STATE, LOCAL & TRIBAL AUTHORITY (301)
Most of the comments on this particular issue stem from people who live in the area and are fearful of the government coming in and taking away the rights they have from the states of Idaho and Montana. People feel that the grizzly bear will bring in more regulations on their lives. They feel the FWS has no legal right to reintroduce bears into the Bitterroot Ecosystem since the state government is opposed to the plan. Several claim Idaho has a right to, "Self determination under the constitution of the United States." Some people question the legality of the Secretary of Interior designating authority to a Citizens Management Committee. Many believe the USFWS should retain management responsibilities for reintroducing grizzly bears. Some people feel the federal government is arrogant because it is not listening to local concerns . These people site local and state laws being violated by the reintroduction process. Numerous people ask if the FWS would be the responsible party for any deaths caused by reintroduced grizzly bears. Still others are concerned this is an unfunded mandate and that the states will be stuck with the tab for bear reintroduction costs.
A few comments are actually supportive of the federal government being in charge of reintroduction. They are usually voiced by individuals who believe this is a national issue and should be handled by the Secretary of Interior. Some do not believe the management should be left up to the states and especially to the Citizen Management Committee with local people on it.
RESTRICTIONS ON USE OF PUBLIC LANDS (302)
EFFECTS OF GRIZZLIES ON PUBLIC ACCESS (508)
These two issues are discussed together because they are so closely related. Numerous individuals comment on how grizzly bears will effect their access and use of public lands. Most of these comments are divisive.
Opposed to Land Use Restrictions
Many respondents, particularly residents of Idaho and Montana, indicate they do not want any restrictions placed on the use of public lands. A primary point of contention for many is the threat of road closures that would restrict their access to public lands. Many believe this is an attempt to "lock up" public lands. They question the statements made in Alternative 1 that no trail or road closures are expected solely for grizzly bears. They are concerned about the effects to the local economy, restrictions on multiple-use activities, and the effects on recreation uses on public lands.
Positive or Neutral Responses
A few respondents are positive (or at least not negative) about grizzly bear recovery efforts and believe people and bears can coexist. They view some of those opposed to the recovery effort as self-serving, reacting to perceived threats to their self-interests.
PRIVATE PROPERTY RIGHTS (303)
Many people feel that the grizzly bear is a tool the federal government is using to, "Steal private property rights," and to, "Establish more government control." Comments on this issue show that the public sees this reintroduction as a threat to their private property. Some suggest that the federal government compensate landowners for the land value losses once grizzly bears are present. Commenters feel there will be land use restrictions imposed by grizzly bear management even though the DEIS says there will not be. Some people accuse the government of lying when it says no land use is expected to be altered; they state that the Final EIS should be more truthful about this issue. Several respondents emphasize the FWS must cooperate with private landowners to recover listed species such as the grizzly bear since private lands do provide habitat for wildlife species. And a few respondents voice their concern with how this effort will affect their access to irrigation dams in the reintroduction area.
LAW ENFORCEMENT (306)
The four comments received on this issue are included below:
"The USFWS is going to assist (DEIS Appendix 14-B2113, page 6-151) means each Grizzly kill will be taken to the max to prosecute." (See Letter 753, Concerned About Grizzlies, for additional information.)
"Can a rancher who defends his property from a Grizzly expect search warrants and possible prosecution?"
" Be advised, that this office (Custer County Prosecutor) will prosecute anyone and every one who introduces or conspires to introduce any wildlife into Custer County without a permit as provided by law."
"I don't want to have to kill a grizzly bear, nor do I want to have to defend myself in court if I kill a grizzly bear."
IGBC GUIDELINES (INTERAGENCY GRIZZLY BEAR COMMITTEE (309)
The three comments made on this topic are listed below:
"...support the role of agency personnel in dealing with bears whose interactions with humans are problematic...such actions emphasize bear protection within the experimental, non-essential designation...Recommendation: Agencies should be allowed to follow current guidelines, as allowed in other ecosystems under full threatened status, until new guidelines are proposed and accepted by the management committee."
"This Alternative (3) is in opposition to the stated goals of Interagency Grizzly Bear Committee."
"The development and implementation of standards and guidelines for grizzly bear recovery in our areas never was generated with citizens involvement."
COMPLIANCE WITH FOREST PLANS (311)
People addressing this issue feel the DEIS fails to consider possible conflicts with forest plans. Concerns from both sides of the issue are expressed, some question the need to manage lands for, "A population of grizzly bears that does not exist." Others feel the existing forest plans do not provide sufficient standards and guidelines for grizzly bear recovery.
WILDERNESS ACT (312)
The four comments received on the Wilderness Act are included below:
"Not only is reintroduction good for the species, but it is consistent with the intent of the Wilderness Act."
"The recovery area in the Plan needs to be expanded. A quarter of the Selway-Bitterroot is not Sufficient Habitat."
(Wilderness Act states) "These lands 'shall be administered for the use and enjoyment of the American people is such a manner as will leave them unimpaired for future use and enjoyment.' I feel that this proposed reintroduction has a potential to impair the enjoyment of many of the users."
"Bears are going to be reintroduced by helicopters. I believe that is prohibited by the Wilderness Act. This document does not seem to analyze the impacts of that activity."
LOCAL CONTROL (313)
Within this issue, many feel grizzly bear management in the BE should rest upon the local citizens not people from other states or people who will not be directly impacted by grizzly recovery. Since the people of western Montana and central Idaho will be most affected by reintroduction, they feel they should have direct say in the bear's management; many support the idea of a "Citizens Management Committee." Still others feel the grizzly bear should not be reintroduced through their "back door" unless there is a majority of local support. Many commenters feel the Federal Government is not listening to them. Conversely, some respondents contend that since grizzly bear recovery is a national issue then management should be at a national level; and the bear should be managed by a broad based "scientific committee."
BEST AVAILABLE SCIENCE (314)
A small legion of people feel that the Citizen Management Committee (CMC) will not use the best available science because members will not have a biological background and have a bias against grizzly bear recovery. Many feel that the CMC should be replaced with a different type of committee with more ecology and genetics training. This committee, appointed by the National Academy of Sciences, would determine where bears could come from as well as make management decisions related to recovery in the Bitterroot Ecosystem (BE). Many of the commenters express support for Alternative 4 saying it is based on the needs of the grizzly bear and not on politics. A few people contend the idea of reintroduction into the BE is based on poor science, and therefore should not be attempted.
GRIZZLY BEAR RECOVERY PLAN (315)
A few respondents address the Recovery Plan specifically and how it relates to the DEIS. A discussion of linkage zones is in the Recovery plan but they are not addressed in the DEIS. Several people mentioned this fact. The other general theme is how the CMC will enact the Recovery Plan that has already been developed for the Bitterroot Ecosystem.
400 - ECOSYSTEM MANAGEMENT
GRIZZLY BEAR AS A MISSING COMPONENT OF THE ECOSYSTEM (401)
The vast majority of comments on this issue express the grizzly bear is a missing component of the Bitterroot Ecosystem (BE). They feel the grizzly bear will enhance their wilderness experience by restoring the top predator of the food chain. People claim the grizzly is an indicator species that will improve the health of the ecosystem once the bear is reintroduced. Some feel it is mankind's responsibility to return the grizzly to the BE because man caused its eradication. However, several people state the grizzly is not native to the BE. Others feel that the BE doesn't need the grizzly bear to function properly, and to make the land like it was "circa 1847 is utter nonsense."
IS GRIZZLY BEAR NATIVE TO BITTERROOT ECOSYSTEM? (402)
This is an interesting issue. On one hand the public is adamant that a population of grizzlies exist in the Bitterroot Ecosystem (BE). Yet, people from the same general area question whether grizzlies are even native to the BE. The spectrum of comments received reflect this discrepancy within the public. Respondents frequently use these arguments to disagree with the idea of reintroduction. People say if there are already grizzlies there, they should be allowed to grow at their own rate. Bears, therefore, cannot be reintroduced as experimental nonessential. On the other hand, if grizzlies are not indigenous to the BE, the habitat to support a population must not be there for a self-sustaining grizzly bear population. Reintroduction would be a waste of resources.
WHAT IS A VIABLE GRIZZLY BEAR POPULATION? (403)
The general theme of these comments is whether or not the recovery goal of 280 bears is a self-sustaining grizzly bear population. Some feel that more bears will be needed in the Bitterroot Ecosystem to establish a healthy bear population and to increase the long term survival. Several respondents feel that grizzly bear recovery in the BE is not needed for the long term survival of the bear.
POPULATION CORRIDOR LINKAGES (405)
A plethora of comments were received on this issue particularly relating to travel corridors and linkages. Many people call for linkage zones to be incorporated into the FEIS. Linking the Bitterroot Ecosystem to other ecosystems such as the Cabinet/Yaak and the Northern Continental Divide Ecosystem will improve genetic diversity and improve the overall health of grizzly bear populations in the lower 48 states. People are critical of Alternative 1 because it would prohibit linkage zones between the experimental-nonessential population and other bears; on the other hand, Alternative 4 supporters favor corridor management. Only a handful of comments were against establishing linkage zones.
RANGE REQUIREMENTS OF GRIZZLY BEARS (406)
The comments on this issue seem to center on the habitat base within the Bitterroot Ecosystem. People feel that the preferred alternative doesn't provide enough habitat to support a grizzly bear population. To address this issue, some feel that the recovery area should be enlarged to encompass the entire 'Greater Salmon Selway Bitterroot Ecosystem.' Others feel that since the habitat is insufficient, reintroduction should not progress. People feel there is no spring range in the recovery area, so bears will move to the valley bottoms and run into problems with people.
EFFECTS TO GRIZZLIES (407)
(Genetics, disease, colonization, bear safety, adequate food)
People are concerned the grizzly bear in the lower 48 states will suffer a genetic bottle neck. Many support the reintroduction of the grizzly bear in to the BE and managing corridors between ecosystems to help elevate the threat of inbreeding. An additional population of bears will increase the genetic diversity and increase the long term survival of the grizzly bear. For these reasons respondents appose Alternative 1 which 'isolates' the BE while they support Alternative 4 because it encourages the development of linkage corridors.
Related to this issue, some feel that there is not enough habitat for a population of grizzly bears in the BE. Many state that natural food sources for the bear (salmon, white bark pine masts, and huckleberries) do not exist in the BE, and bears will come into conflict with humans in its search for food. Therefore some respondents feel grizzly bears should not be reintroduced into the BE.
HABITAT SECURITY (408)
EFFECTS ON GRIZZLIES FROM HUMAN INCURSIONS OUTSIDE THE WILDERNESS (409)
Many people feel that the preferred alternative does little to protect habitat needed by grizzly bears. People feel that resource extraction activities will continue as in the past and this will have a negative impact on a recovering population of grizzly bears. People feel road building has to be stopped and road densities need to be established in the recovery area to protect habitat for the bear. Alternative 1 does nothing to address these issues in their mind and therefore this alternative should be rejected. On the other hand , people support Alternative 4 because it protects habitat from extraction industries. People who feel habitat security is a priority feel, road removal and protection of roadless areas within the recovery zone should be a priority. People are concerned that a road density standard is not established for the BE in this DEIS, some suggest that road densities be maintained at less then .25 miles/sq. mi. Many feel management standards in place for other fish and wildlife will not be adequate for grizzly bear recovery.
ECOSYSTEM PROTECTION (411)
Many comments were received stating that habitat protection in roadless areas is important for a healthy ecosystem. People feel that road building and extractive industries should be stopped to help recovery of the grizzly bear. Many express their belief that if the ecosystem is managed for the grizzly bear it will improve habitat of the ecosystem for other wildlife species as well. Here again, numerous people voice their support for Alternative 4 and their disapproval for Alternative 1.
500 - EFFECTS OF GRIZZLIES
Comments Supportive of Reintroduction:
Supporters of Alternative 1 think land management activities are compatible with grizzly bear reintroduction, and Alternative 1 will prove the effects to be minimal.
Supporters of Alternative 4 look at evidence in other grizzly bear ecosystems, and make the point that grizzlies and humans can coexist with minimal effects to grazing and pets.
Other respondents feel some limitations on human activities will be necessary if bears are reintroduced to the BE, but creative solutions will help to minimize impacts to humans. A case example from the Salish and Kootenai Tribe illustrates that grizzly bears and humans can coexist, and that extractive activities can continue with a few insurmountable compromises made.
Comments Opposed to Reintroduction:
Comments indicate a concern that grizzly bear reintroduction to the BE would cause numerous negative impacts to the livelihoods and life-styles of local residents, especially areas in central Idaho and the Bitterroot Valley of western Montana that are adjacent to the BE. There is distrust of the DEIS analyses that indicate minimal impacts to extractive industries, recreation opportunities, and human safety. Some respondents list their concerns and then advocate Alternative 3 as the only possible solution.
EFFECTS OF GRIZZLIES ON HUMAN HEALTH AND SAFETY (501)
Comments Specific to the Alternatives:
Supporters of Alternative 1 minimize the actual threat to humans from reintroduced grizzly bears because they think bear numbers will be few and they will be in remote areas with plenty of forage. They also think Alternative 1 offers adequate protective measures for humans.
Those opposed to Alternative 1 feel the alternative does not permit enough protection for humans that recreate or work in the recovery area.
Supporters of Alternative 2 want a more gradual recovery of grizzly bears in the BE, because they think reintroduction would cause an accelerated population increase and result in more human conflicts. Some support this alternative as a default if the bears have to be recovered under ESA.
Numerous comments support Alternative 3 because of concerns for human health and safety. Most comments are from local residents who live or work near the BE, and are concerned about encountering a bear on public or private land. They are not tolerant of any human injuries from grizzly bears.
Those supportive of Alternative 4 feel the chance of grizzly/human encounters will be minimal due to the vastness of the recovery area. They also feel the grizzly bear is a missing component of the wilderness, and are willing to accept an increased risk to their safety when in the wilderness. Most think they can easily minimize any risks by planning and practicing safe camping techniques.
These comments were all of two distinct and opposing schools of thought. Obviously, one line of thinking is that grizzlies are certain to attack humans, and the other that grizzlies pose less of a threat than some people would believe and in comparison to other dangers people live with on a daily basis, grizzly dangers are less risky.
Not a Risk: The comments following reflect some of the common themes regarding bears' effects on human safety. The first group of comments favor reintroduction and generally do not feel the bears will be a big problem.
Bears Pose a Threat to Human Safety: By far the most comments received on this proposal, come from the vast majority of people who are concerned with the human safety issue. The comments below reflect the fear people have regarding grizzly bears.
EFFECTS OF GRIZZLIES ON LIVESTOCK & PETS (502)
Comments Related to Alternatives:
Comments that relate to Alternative 1 indicate the supporters of the alternative think there will be a low probability of conflict with the livestock industry because there are no grazing allotments in the wilderness portion of the recovery area north of the Salmon River. Those opposed to Alternative 1 feel that either; Alternative 1 places the welfare of the subsidized livestock industry over that of the threatened grizzly bear, or that there is too much economic risk to ranchers and the FWS would not be able to respond to depredation incidents in a timely manner.
Other comments question the analysis and the dataused in the DEIS to determine anticipated depredation rates and impacts to the livestock industry. Another suggests additional analysis is needed regarding impacts to grazing permittees.
There are also many commenters that think the loss of a few livestock is well worth it, compared to the importance of recovering grizzly bears in their native habitat. People feel that the bear should be given priority over non-native domestic animals.
Comments that relate to Alternative 3 are largely supportive because the respondents are concerned about grizzly bear depredation and impacts to the livestock industry. They view this alternative as an answer to their concerns. Those opposed to the alternative think it was written by the livestock industry.
A few opposed Alternative 4 because it does not provide enough protection to livestock owners.
There is concern expressed by local ranchers that their livelihood and life-style would be seriously impacted, and they are not willing to tolerate this impact. They think the DEIS underestimates the impacts to the livestock industry. One commenter mentions the economic hardship caused by non-lethal bear attacks on livestock (i.e. veterinarian fees). Other commenters think that the grizzly bears and the livestock industry can coexist, and offer examples where this has been successful.
A common concern of people who fear grizzly reintroduction will negatively impact their livelihood and safety, is that the recovery area will not provide adequate food for bears, and they will follow game populations into the valley bottoms where there will be conflicts with human habitation. One commenter mentions the change in the recovery area boundary from FWS early planning efforts to the boundary for Alternative 1 in the DEIS, and notes the increased area of impact.
EFFECTS OF GRIZZLIES ON BIG GAME SPECIES (503)
Respondents support Alternatives 2 and 3 because they feel the reintroduction of grizzly bears would decimate the game populations in the recovery area. Some comments refer to the recent decline of elk herds in central Idaho, and state that grizzly bears would only exacerbate the problem.
Some respondents make the point that grizzlies are omnivores and a large percentage of their diet (in excess of 90%) is vegetation and insect matter. They are not carnivorous, like the wolves. These people dispute the concerns of hunters that the grizzlies will kill all of their game. They also feel game populations will adjust to the minimal amount of increased predation from grizzly bears.
Others feel there are enough predators already in the ecosystem, and that it cannot support another predator. They particularly feel hunters are managing the game populations and there isn't much surplus.
Most commenters think the current game populations can't withstand a loss of the DEIS estimate of 504 to 720 ungulates per year to grizzly predation. They assert hunter opportunity is more important to them, and that they would rather have healthy game populations to hunt than have grizzly bears. Some comment that they depend on game meat to feed their families.
There are a few commenters that think the grizzly bear would seriously impact the recruitment of young ungulates (especially elk calves), and that would cause further declines in the game populations.
EFFECTS OF GRIZZLIES ON HUNTING OPPORTUNITIES (504)
Comments that Address Alternatives:
Supporters of Alternative 1 see the potential to hunt grizzlies in the future as one benefit of a successful reintroduction of grizzly bears. They also suggest the prohibition of bait and hound hunting of black bears in Idaho as a modification to the alternative.
Those in favor of Alternative 3 think that grizzly reintroduction will cause serious declines in big game populations, and reduce or eliminate hunting opportunities.
Those in favor of Alternative 4 strongly support this alternative because it proposes to eliminate baiting and hound hunting of black bears, in order to protect grizzly bears from illegal killing. They also feel that protection of roadless areas will benefit game populations and increase hunter opportunity.
Respondents had differing views regarding the potential effects of grizzly bear reintroduction on outfitters and guides. Some thought there would be no effect because so few grizzlies wouldn't interfere with outfitter expeditions, and others thought outfitters would see a positive benefit from clients paying to see a grizzly in the wild. Others thought there would be a negative impact from access restrictions, and reduced business due to depleted game populations and fearful clients.
Many comments suggest a goal of the recovery effort in the BE should be to ultimately manage for a huntable population of grizzly bears. They discuss the importance of hunting (especially grizzly bear) in the Montana culture.
Some commenters are supportive of the elimination of bait and hound hunting for black bears in Idaho, and others are concerned that the Special Rule doesn't assure the maintenance of these hunting methods for black bear. One person mentions the possibility of black bears losing their fear of humans if they area not hunted.
Some comment on the potential negative economic effects to local economies from reduced game populations and hunting opportunities (due to grizzly bear depredation on game populations).
Some respondents discuss the considerable effort in professional management of game populations to provide hunter opportunity. They feel that grizzly reintroduction would negate or complicate these efforts by reducing game and fish populations, and thus seriously impact hunter opportunity.
A concern of some respondents is potential access restrictions which would impact hunting and recreation opportunities. Safety of hunters in "grizzly country" is also a concern. The hunting public is fearful of encounters with bears while they are hunting, and fearful of grizzlies being attracted to downed game that is cached in the woods or hung in camps.
EFFECTS OF GRIZZLIES ON OTHER PREDATORS (505)
Some commenters specifically refer to the effects of black bears from grizzly reintroduction. They question the effects of the proposed ban on baiting and hound hunting of black bears to black bear populations and their fear of humans.
The majority of comments question the general effects that grizzly bears would have on other predators already present in the ecosystem. They feel the DEIS does not adequately address the relationships between grizzly bears and other predators, and question the suitability of the habitat in the BE to support an additional predator. A few comments regard the recent gray wolf transplant into central Idaho. People think monitoring and research of the impacts of the gray wolves should be conducted before grizzly bears are added to the ecosystem.
EFFECTS OF GRIZZLIES ON OUTFITTERS AND GUIDES (506)
Most respondents are concerned about the economic impacts to outfitters and guides and local economies from various potential impacts associated with grizzly reintroduction in the BE. They feel the DEIS does not adequately address these impacts. Questions are raised about sanitation requirements...if bear proof containers will be mandated, who will pay for and install them, and maintain them in the numerous backcountry campsites. Outfitters comment they will have to purchase a lot of new equipment to meet safety requirements, and this will be an economic hardship that has not been addressed in the DEIS. Commenters list numerous impacts such as trail closures, depletion of game herds from grizzly bear and wolf depredation, and area closures for bears that could have negative impacts to outfitters and guides. A few outfitters are concerned about safety for them and their clients in bear occupied backcountry areas when game meat is present.
Some respondents think there will be positive impacts to outfitters and guides from grizzly bear reintroduction. They note in other areas occupied by grizzly bears, people hire outfitters to take them camping and to see a grizzly bear in the wild. They think this would happen in the BE, and would benefit the outfitter/guide industry. One person argues that such a small population of bears would have no impact to outfitters, and suggests industry is making an issue of nothing. A few others see a benefit from reintroduction in that outfitters would be forced to keep clean camps. On commenter thinks grizzly bear recovery is more important than protecting outfitters' jobs, and feels that if there is a conflict, the bears should take precedence.
EFFECTS OF GRIZZLIES ON RECREATIONAL OPPORTUNITIES (507)
Comments Related to Alternatives:
A few people specifically address alternatives with respect to impacts on recreation. Comments regarding Alternative 1 address the impacts to recreation activities from issues related to human safety. Most are opposed to Alternative 1 because they think it would negatively impact access and recreation opportunities.
People favor Alternative 2 because they don't want any negative impacts to recreation.
Many comments favor Alternative 3 because people are concerned for public safety during backcountry recreation, and they don't want to change their current recreation activities for grizzly bears.
Commenters support Alternative 4 because people want to recover grizzly bears in the BE and want to see them in the wild, or just know they are there. They are willing to deal with any inconveniences from grizzly bear presence. One person opposes Alternative 4 because the proposed road closures would impact public access and recreation opportunities.
Many respondents feel impacts to recreation activities in the Bitterroot Ecosystem will be minimal to nonexistent if bears are reintroduced. They think such a small number of bears placed deep in the Selway-Bitterroot Wilderness will not disperse eastward into the Bitterroot Valley, and if one wanders that way, it would not cause trail closures. Most people comment they are willing to adjust their habits in the backcountry, and to learn proper camping techniques in order to coexist with grizzly bears. One person commented that grizzly bear reintroduction would greatly increase tourism and benefit local economies.
Some comments relate specifically to the DEIS, and question the analyses or suggest additional analyses. Respondents think grizzly bear reintroduction will significantly impact the nature of existing recreation uses in the BE, and think the DEIS did not address this. Specifically, they write the DEIS did not address the qualitative impacts to recreation experiences in the BE from things like sanitation orders, restrictions on trails, limited access, etc. They also feel the DEIS did not address the economic impacts to individuals from having to comply with sanitation orders.
Many comments reflect a general concern for public safety during recreation activities in the BE if grizzly bears are reintroduced. Some people want a wilderness area to recreate in that does not have grizzly bears, and currently choose the BE because they don't want to have to worry about their safety. Others think people will avoid the BE if bears are reintroduced, and think this will seriously impact the local economies that are dependent on tourism dollars from hunters, hikers, rafters, etc.
A number of comments made by river rafters relay their concern that sanitation requirements in the recovery area would seriously impact their enjoyment of the river. They question whether the FWS could adequately outfit all of the river camps with sanitation equipment. One person thinks all rafters would have to carry guns, and feels this would change the character of the outdoor experience. Rafting outfitters think this would seriously impact their business.
EFFECTS OF GRIZZLIES ON OTHER ENDANGERED SPECIES (509)
Specific Comments Related To Alternatives:
One commenter asserts the DEIS does not consider the impacts to ESA listed anadromous fish from the reintroduction of grizzly bears. They are opposed to Alternative 1 and don't think bears should be reintroduced given the current National Marine Fisheries Service directives to protect these fish.
A few people support Alternative 3 because they are concerned about impacts of grizzly bears on other listed species.
Supporters of Alternative 4 think this alternative will protect other listed species by protecting and restoring large habitat areas in the BE.
Most comments relate concern for the potential negative impacts grizzly bears would have on listed salmon and steelhead in central Idaho. They feel the federal government is spending much effort and money to recover depleted anadromous stocks, and the grizzly bear is known to forage on these fish. Others question the NEPA process and think the biological assessment of impacts from grizzly reintroduction to other listed species should be done after the final EIS is written and an alternative selected. One person suggests the FWS should take a multiple-species approach to managing listed species in the BE, and not just focus on one species at a time. There is also concern for the potential negative impact to gray wolves in central Idaho from grizzly reintroduction.
EFFECTS OF GRIZZLIES ON OTHER ANIMALS (510)
There is some concern the reintroduction of grizzlies would cause population declines for a number of other wildlife species in the BE. Respondents think the grizzly bear is a fierce predator, and will especially cause declines in game populations.
Many commenters mention the grizzly bear is an indicator or umbrella species for other flora and fauna in the ecosystem. They feel if the ecosystem is healthy enough to support grizzlies (either through protection or habitat restoration) it will support all other species. Many support Alternative 4 because of the habitat protection it proposes.
Other respondents are concerned about the impact to black bear populations in the BE from the reintroduction of the grizzly bear. One person thinks there will be only minimal displacement of black bears by grizzlies, while others think black bears will be outcompeted for food and habitat, and will be displaced to fringe habitats. Some make the point that the displaced black bears will move to populated areas where they would be in conflict with humans, and would predate on already depleted game populations. One person thinks the elimination of black bear hunting with baits and hounds will cause excess bears to move into populated areas.
600 - ECONOMIC/SOCIAL
Comments received in this category state that the grizzly bear is part of our national heritage and therefore should be conserved for future generations. The presence of grizzly bears in the Bitterroot Ecosystem would improve the experience of some recreationists while visiting the wilderness. Many people believe the grizzly bear will make the wilderness more complete. Some claim the grizzly bear will degrade their experience in the Selway/Bitterroot area by increasing the risks to their personal safety, the safety of livestock and animals. Some people feel the government should not play 'God' and leave the bears to recovery on their own accord. A representative of the Shoshone-Bannock people states that the grizzly bear "is part of the circle of life."
One individual speaks to the social significance of hunting and how it pertains to reintroducing the grizzly bear.
Several individuals speak of the importance this issue of reintroduction will be on the future generations. Some believe it will help ensure the grizzly will be there as a natural component of the ecosystem; still others believe they want to preserve the ecosystem as it is without the grizzly bear.
ENJOYMENT OF GRIZZLY - WATCHING/KNOWING IT'S THERE (602)
Some commenters feel there is an intrinsic value in having grizzlies in the Bitterroots. People do not necessarily need to see a grizzly bear; simply knowing the bear is in the area is good enough for some. Several say the idea of recreating in an area with grizzlies improves their quality of life as well as the lives of future generations. Some people dislike the DEIS putting a price tag on the bear and making it a "commodity." They feel this detracts from the wildness of the grizzly bear.
COST OF THE PROGRAM TO TAXPAYERS (603)
The majority of people commenting on the program are concerned with the high cost. They feel that grizzly bear recovery is not a priority to them, and therefore any monies spent on bears is too much. They say it is a waste of tax dollars and a "fleecing of America." Some people do not like the idea of spending tax dollars on grizzly bear recovery and make suggestions on their priority for tax dollar expenditures: Deer and Elk management, trail maintenance in National Forests, helping homeless people, education, unemployment, and balancing the Federal budget. Numerous comments were received about the economic analysis in the DEIS. Since there are no 'real dollars' seen in the impacted local communities, people feel that it is misleading to say that grizzly bears have a 40 to 60 million dollar value.
Some people make the general comment that they approve of their tax dollars being spent on grizzly recovery in the BE. Many people who are in favor of grizzly bear recovery support Alternative 2 because it promotes the grizzly bear while not costing the taxpayer as much as the other alternatives. Many are concerned with the cost of Alternative 3, "It would still spend the money but remove any bears that might happen to be there." Proponents of Alternative 4 feel that this will save tax dollars by eliminating below cost timber sales and associated road construction in the recovery area.
Some people are concerned about the long range funding outlined in the DEIS. They feel that the estimated cost of reintroduction is underestimated and no long-term funding source has been identified. Some fear that the federal government will 'drop' the recovery responsibility on the states of Idaho and Montana without adequate funding.
700 - MISCELLANEOUS
NEED FOR EDUCATION (701)
Respondents from all sides of the reintroduction issue see a need for a comprehensive public information and education program. A frequent suggestion is to increase education on installing sanitation equipment. Several feel a public education effort needs to be instituted prior to start-up in the local areas so the awareness factor is up. Interestingly, they believe the "other side" is the one that needs educating in order to swing them around to the "right" viewpoint.
Those who favor reintroduction of the grizzly bear claim education will help reduce the fear factor, help people understand the risks versus unfounded fears, and help alleve misinformation regarding grizzly bears and their place in the ecosystem.
Those against reintroduction of the grizzly bear claim education will help others realize the idea is a poor one because they claim the grizzly is not threatened and endangered. They also ask why here and why now? They call for more public education on bear safety and defending self, family, livestock, and property.
POLITICAL INFLUENCE (702)
The respondents who discuss this issue as it relates to grizzly bear recovery express widely divergent views. Many respondents at both ends of the spectrum convey their exasperation with the political system and the role it has played in determining the outcome of reintroduction. Several people in favor of grizzly bear reintroduction state that state politicians and local groups have hindered the reintroduction effort. Others also disparage having politics instead of science be the guiding force in reintroduction efforts.
Many respondents reiterate their view that the political process has not worked to their advantage. Several individuals are concerned with the role the Secretary of Interior will play in the "political decisions" played out with the Citizen Management Committee. Most do not trust the Secretary to delegate authority to a group of citizens. A few people express their fears of "hidden agendas" by pro-grizzly advocates to "lock up the land". Many respondents resent people or groups outside the local area having undue influence on bringing grizzly bears into an area in which they live. Several respondents mention they believe the Endangered Species Act is being misinterpreted.
Numerous residents of Idaho state they are amazed reintroduction of the grizzly bears is being "pushed ahead" when there is so much opposition politically from the elected officials within the state.
APPENDIX A. Answers to Common Questions About the Draft EIS
Raised During the Public Comment Period
Are grizzly bears native to the Bitterroot Ecosystem, and do they reside there today?
Historically, the grizzly bear was a widespread inhabitant of the Bitterroot Mountains in central Idaho and western Montana. When Lewis and Clark traveled through the Bitterroot country in 1806, grizzly bears were abundant. They killed at least 7 grizzly bears including 1 female and 2 cubs while camped near present-day Kamiah, Idaho. Grizzly bears were common in central Idaho until the early 1900's. Conservative estimates indicate trappers and hunters killed 25 to 40 grizzly bears annually in the Bitterroot Mountains during the early 1900's. A major influx of hunters, trappers, and settlers at the turn of the century, and later sheepherders were responsible for direct mortality and elimination of grizzly bears from the Bitterroot Ecosystem.
The last verified death of a grizzly bear in the Bitterroot Ecosystem occurred in 1932 and the last tracks were observed in 1946. Although occasional unverified reports of grizzly sightings persist in the Bitterroot Ecosystem, no verified tracks or sightings have been documented in more than 50 years. Based on the best scientific evidence available, and the lack of verified evidence for more than 50 years, there appear to be no grizzly bears in the Bitterroot Ecosystem at this time.
What is a nonessential experimental population?
Before 1982 the U. S. Fish and Wildlife Service (USFWS) could reintroduce threatened and endangered species into unoccupied historical range; however, many attempts to do so were fervently resisted. The USFWS was not able to assure other federal agencies, state and local governments, and private landowners that transplanted populations would not disrupt their future land-management options due to the "jeopardy" prohibition of Section 7 and/or the taking prohibition of Section 9 of the Endangered Species Act (ESA). In an effort to encourage acceptance of reintroductions, Congress amended the ESA in 1982 to include a new Section 10(j) that allowed the Secretary of Interior the opportunity to designate reintroduced populations as "experimental." Section 10(j) gives the USFWS more flexibility for the management of these populations by providing that all experimental populations shall be treated as threatened species regardless of the status of the donor population. Special rules concerning prohibited acts must be written by the USFWS. Basically, the writing of special rules provides the USFWS the opportunity to tailor the reintroduction of an experimental population to specific areas and specific local conditions, including specific opposition.
"Nonessential" refers to an experimental population whose loss would not be likely to appreciably reduce the likelihood of the survival of the species in the wild. Because nonessential experimental populations are treated under ESA Section 7 as "proposed species," federal agencies must only confer with the USFWS on activities that the agencies believe might jeopardize the species. Moreover, the agencies would be under no obligation under Sec. 7(a)(2) to avoid actions likely to jeopardize the species. Congress expected that most experimental populations would be considered "nonessential."
What are the advantages to local citizens of designating bears as a nonessential experimental population?
Numerous public comments and positions of elected local, state, and federal government officials during the early scoping processes for the Bitterroot Draft Environmental Impact Statement (DEIS) indicated they would repeatedly and fervently resist attempts to reintroduce grizzly bears without assurances that current uses of public and private lands would not be disrupted by recovery activities and that grizzly bears that attack livestock would be controlled. Such assurances can be made under nonessential experimental population designation.
In 1982, Congress amended the Endangered Species Act (ESA) to permit greater management flexibility for species that are reintroduced to their historic range. The purpose of the added flexibility was to garner more local support for restoration efforts. Such populations may be designated as "experimental" and managed within a delineated area according to special rules designed to balance needs of both people and listed species. Citizens can be involved in crafting such management rules.
Under Alternative 1 of the DEIS, the U.S. Fish and Wildlife Service proposes to designate the reintroduced population of grizzly bears in the Bitterroot Ecosystem as "nonessential experimental." Such designation would allow these grizzly bears to be treated as a species "proposed for listing" rather than "threatened" for the purpose of section 7 of the Endangered Species Act, and thus would not be subject to the formal consultation provision of the Act. Flexibility is provided by limiting the consultation requirements of section 7 of the ESA and by permitting special rules to be written covering section 9 takings of the ESA. Activities undertaken on private lands are not affected by section 7 of the Act unless they are funded, authorized, or carried out by a Federal agency. The biological status of the grizzly and the need for management flexibility resulted in the Service proposing to designate the grizzly bears reintroduced into east-central Idaho as "nonessential." Because reintroduced grizzly bears would be classified as a nonessential experimental population, the Service's management practices can reduce local concerns about excessive government regulation on private lands, uncontrolled livestock depredations, excessive big game predation, and the lack of State government and local citizen involvement in the program.
Can a person kill a grizzly bear in self-defense?
Yes. Within the Experimental Population Area, the preferred alternative (Alternative 1) would continue to allow a person to kill a grizzly bear in defense of that person's own life or the lives of others, provided that such taking is reported within 24 hours to appropriate authorities. Under Alternatives 2 and 4, grizzly bears could be killed in defense of life, but not in defense of property.
Does the preferred alternative allow people to harass or kill grizzly bears in defense of property?
Yes. Under the preferred alternative (Alternative 1), any livestock owner may be issued a permit by the U.S. Fish and Wildlife Service, the Idaho Department of Fish and Game, or the Montana Department of Fish, Wildlife , and Parks and appropriate Tribal authorities to harass grizzly bears found in the experimental population area that are actually harming or killing livestock (cattle, sheep, horses, mules), provided that all such harassment is by methods that are not lethal or physically injurious to the grizzly bear and such harassment is reported within 24 hours to appropriate authorities.
A livestock owner would be issued a permit by the appropriate authorities to kill a grizzly bear killing or pursuing livestock on private lands within the experimental area once a permit has been obtained, the response protocol established by the Citizen Management Committee (CMC) has been satisfied, and efforts by the wildlife agency personnel to capture the depredating bear have been unsuccessful. If significant conflicts, as determined by the CMC, occurred between grizzly bears and livestock in the Experimental Population Area, these could be resolved in favor of livestock by the agencies moving the bear or removing it.
If grizzly bears become a problem or nuisance to human safety or private property, could they be controlled?
Yes. Bears that frequent areas of high human use, act aggressively toward humans, or kill livestock would be dealt with under the Interagency Grizzly Bear Committee Nuisance Bear Guidelines. This means they would be trapped and moved, or destroyed by management agencies. Grizzly bears posing problems to camps, cabins, individuals, and stock may be relocated rapidly to remote areas, or killed by authorized personnel of state, tribal, or federal agencies. For example, individual bears that wandered into areas deemed unsuitable for bear residency (such as agricultural, residential, or recreational developments) could be removed. Other potential management options also may be used, such as aversive conditioning techniques that train individual bears to avoid humans and their property. Under the preferred alternative (Alternative 1) the Citizen Management Committee (CMC) would be responsible for making management recommendations in nuisance bear situations.
What does the U.S. Fish and Wildlife Service propose to do to reduce the risk to human safety from reintroducing grizzly bears in the Bitterroot Ecosystem?
The U.S. Fish and Wildlife Service (USFWS) would take all possible actions to reduce the risk of human/bear conflicts. Only grizzly bears with no history of conflicts with people would be considered candidates for reintroduction. Suitable bears would be released at wilderness sites within the Bitterroot Ecosystem to reduce the likelihood of encounters with humans. All released bears would be fitted with radio collars and their movements would be monitored to keep the public informed of general bear locations and recovery efforts. A proactive public outreach information and education program would be initiated to inform the public about the recovery program, grizzly bear biology, and how to safely recreate in the Bitterroot Ecosystem. Sanitation improvements would be made to campgrounds and backcountry campsites. These programs would be initiated during the first year of implementation of Alternative 1 before bears are reintroduced, and would continue through the implementation phase, and into the monitoring and management phase.
Under Alternative 1 (preferred alternative), unless the CMC determines otherwise, private lands outside the national forest boundary in the Bitterroot Valley (private lands lying within the experimental population area and outside the Bitterroot Forest boundary south of U.S. Highway 12 to Lost Trail Pass) would be an area where any human/grizzly bear conflicts would be considered significant. Grizzly bear occupancy would be discouraged in these areas and grizzly bears would be captured, destroyed, or returned to the recovery area. If a grizzly bear enters this exclusion area, the USFWS would attempt to capture it and notify the public immediately of its presence. The public would be updated until the bear is caught.
Will public lands be closed as a result of reintroduction?
No. The U.S. Fish and Wildlife Service (USFWS) preferred Alternative 1 proposes no changes to existing land management practices or plans. The proposed special rule indicates that the Citizen Management Committee (CMC) would review any potential impacts to land uses and assure that resource extraction activities would be maintained at levels consistent with grizzly bear recovery. The proposed special rule also indicates that existing USDA Forest Service Forest Plan standards and guidelines, as amended, would be deemed adequate pending review by the CMC. It is anticipated that laws and regulations, in effect at the time of issuance of the special rule, and governing land management activities would promote grizzly bear recovery.
Alternative 4 proposes some restrictions on uses of public lands, in the form of road closures and obliteration in the proposed Recovery Zone and Corridor Special Management Area.
However, the scope of the Draft Environmental Impact Statement (DEIS) only covers the actions of the USFWS and cooperating agencies in evaluating alternatives to recover the grizzly bear in the BE of Idaho and Montana. The actions evaluated in the document relate to those actions involving direct management of grizzly bears. Actions involving allocation of public resources such as timber, mining, road building, or grazing on National Forest lands and State lands are not a part of the DEIS. Decision documents involving allocation of these resources on National Forest and State lands are the legal responsibility of the USDA Forest Service, and the states of Idaho and Montana, through appropriate Forest and State planning processes.
Is recreation compatible with grizzly bear survival?
Yes, recreation is compatible with grizzly bears. As long as people use common sense in bear habitat to keep clean camps and avoid surprising bears along trails, there is little impact on either people or bears from recreation. Most grizzly bears try to avoid people, so an encounter or even seeing a bear is unlikely. Hundreds of thousands of people hike, fish, hunt, camp and enjoy grizzly bear habitat every year with very few conflicts of any kind.
Could recreation be impacted by grizzly bears?
There could be rare instances in which a grizzly bear is frequenting an area used by recreationists or other forest users where the safety of the people or the bear is at risk. In such cases, temporary closures of the area may be instituted until the safety risk is past. In the Northern Continental Divide Ecosystem, where a minimum population of about 500 grizzly bears currently exists, only one trail was closed on national forest lands because of grizzly bears in the last 10 years. This closure was a result of concerns for human safety when a bear was seen feeding on an elk carcass along a trail. During the peak of the visitor use season in Glacier National Park, fewer than 5% of trails are closed at any time as a result of safety concerns. Because of the difference between national park and national forest management, closures in the Bitterroot Ecosystem (which is mainly National Forest land) would be extremely rare and probably be similar to the Northern Continental Divide Ecosystem. Also, under the preferred alternative (Alternative 1), trail and road closures are not expected solely for grizzly bears at this time. And any trail, road, or area closure would based on recommendations of the Citizen Management Committee (CMC), and their charge would be to minimize social and economic impacts from the management of the reintroduced population.
Would hunter opportunity be reduced due to grizzly bear predation on ungulates?
Grizzly bears are omnivores, but feed primarily on vegetation. Studies indicate that a grizzly bear diet consists of about 90% vegetable and insect matter. Studies also indicate that because of their eating habits and short periods of predation (usually only during ungulate calving season), 280 grizzly bears may eat as many elk as would 20 adult cougars over a one year period. A population of 280 bears would be expected to prey upon 504 ungulates per year across the Bitterroot Ecosystem. The loss of 504 ungulates to a recovered grizzly bear population would represent approximately 0.11% of estimated pre-harvest populations of ungulates in the Bitterroot area. It should not be necessary to adjust hunting seasons to compensate for grizzly bear predation on ungulates. In central Idaho, baiting of black bears and pursuing black bears with hounds in wilderness areas could be evaluated by the CMC to assure that these activities do not hinder grizzly bear recovery.
Would grizzly bear recovery in the Bitterroot Ecosystem affect current land-uses such as timber harvest and mining?
Under Alternative 1, reintroduction of a nonessential experimental population of grizzly bears into the Bitterroot Ecosystem is not expected to impact land uses, including timber harvest and minerals extraction activities, as long as they meet the existing standards and guidelines of the USDA Forest Service Forest Plans. Minerals extraction would likely not be altered due to grizzly bear concerns alone. Recommendations would be made to land management agencies by the Citizen Management Committee (CMC) to reduce potential impacts if the need arises. The CMC would be responsible for recommending changes in land-use standards and guidelines as necessary for grizzly bear management.
Grizzly bears would be listed as a fully protected threatened species in the Bitterroot Ecosystem under Alternatives 2 and 4, and all federal actions within the applicable recovery zones would be subject to Endangered Species Act Section 7 consultation with the U. S. Fish and Wildlife Service. Based on this, there could be impacts to existing land uses under both alternatives.
Would grizzly bears in the Bitterroot Ecosystem kill livestock and how many?
Livestock grazing, although presently either not occurring or at very low densities within the Alternative 1 Recovery Area, is not expected to be impacted. However, within the Experimental Population Area boundaries, grazing occurs predominantly in the southern portion of the Bitterroot Ecosystem. Consequently, at recovered grizzly population levels and current livestock stocking rates, impacts to livestock would be expected to be similar to levels occurring in portions of the Northern Continental Divide Ecosystem and the Yellowstone Ecosystem. In 50-110+ years (the estimated time to recovery assuming a 2- 4% growth rate) grizzly bears would likely be present within the southern portion of the Bitterroot Ecosystem. Projections indicate that at a grizzly bear population level of 280 bears in the recovery area, yearly livestock losses to depredation by bears could range from 4-7 cattle and 0-44 sheep. Management activities would try to preempt livestock problems. The Citizen Management Committee would try to make all uses compatible with recovery.
Livestock depredations estimated for a recovered population of 280 grizzly bears in the Alternative 2 Recovery Zone range from 1-3 cattle and 0-6 sheep per year. Livestock depredations estimated for a recovered population of 400 grizzly bears in the Alternative 4 Recovery Zone range from 12-22 cattle and 0-355 sheep per year.
Why are grizzly bears listed as a threatened species when there are plenty of grizzly bears in Canada and Alaska?
Grizzly bears once ranged across most of the western two-thirds of North America from Alaska to Central Mexico. Due to indiscriminate killing and habitat modification, grizzlies currently occupy less than 2% of their former range in the lower 48 states, and number only 800 to 1,000 bears in five populations. Before 1800, the total population in the lower 48 states is estimated to have been more than 50,000 grizzly bears.
In 1975, the U. S. Fish and Wildlife Service (USFWS) determined that less than 1,000 bears lived in the lower 48 states and that population declines, habitat loss, and population isolation warranted listing these grizzlies as a threatened species. Listing decisions are based on the available evidence that a species "is in danger of extinction throughout all or a significant part of its range or likely to become so" (ESA Sect. 3(6), (20)). The Endangered Species Act (ESA) defines "species" in terms of distinct population segments (ESA Sect. 3(16)). That is, the ESA applies not only to species and subspecies, but also to distinct population segments of species. If populations are reproductively distinct, they are considered "distinct population segments." Thus, if a population of bears is reproductively isolated from other populations, that population is defined as a species under the ESA. If the population meets the statutory criteria as either "threatened" or "endangered," it is subject to protection under the ESA. This means that the status of grizzly bears in the Yellowstone Ecosystem, for example, is determined independently of the status of grizzlies in Alaska, or the Cabinet/Yaak Ecosystem, or other grizzly bear populations. Bears in one area could be taken off the endangered species list while bears in another could remain listed as threatened or endangered.
How are fully threatened bears affected by moving them to the Bitterroot Ecosystem?
If the USFWS preferred alternative (Alternative 1) is selected and implemented, then grizzly bears from source populations listed as threatened that are moved to the Bitterroot Experimental Population Area under section 10(j) of the ESA would be given "nonessential experimental" status. For the purposes of the ESA, each member of a nonessential experimental population would be treated as a threatened species except that: (1) under ESA Section 7 they would be treated as a species "proposed" to be listed; and (2) critical habitat would not be designated for the nonessential experimental population. Section 10(j)(2)(A) of the ESA states, "The Secretary of Interior may authorize the release (and the related transportation) of any population (including eggs, propagules, or individuals) of an endangered species or a threatened species outside the current range of such species if the Secretary determines that such release will further the conservation of such species."
If Alternative 4 is selected and implemented, then grizzly bears from source populations listed as threatened that are moved to the Bitterroot Ecosystem Recovery Zone would retain their threatened status.
Are bears listed under 10(j) status protected against illegal killing by the ESA?
Yes. The Proposed Special Rule 10(j) for Establishment of a Nonessential Experimental Population in the Bitterroot Ecosystem and Alternative 1 indicate that grizzly bears reintroduced to the BE under ESA 10(j) nonessential experimental population status would be fully protected against illegal killing. The Special Rule indicates the only circumstances under which a grizzly bear within the Experimental Population Area could be legally taken. Persons could kill a grizzly bear in the Experimental Population Area in defense of their own life, or the lives of other persons. Additionally, persons with a valid permit issued by the USFWS, could legally take grizzly bears for scientific or conservation purposes, or a livestock owner on private lands within the experimental area could take a grizzly bear to protect livestock actually pursued or being killed (after efforts to capture the bear have proven unsuccessful). Also, authorized employees of specified management agencies could take a bear in the experimental area that constitutes a demonstrable but nonimmediate threat to human safety or that is responsible for depredations to lawfully present domestic animals or other personal property, if efforts to capture the bear have failed (under Interagency Grizzly Bear Committee Nuisance Bear Guidelines).
Does the Bitterroot Ecosystem provide enough suitable habitat to support a recovered grizzly bear population?
The Bitterroot Ecosystem is one of the largest contiguous blocks of federal land remaining in the lower 48 United States. The core of the ecosystem contains three wilderness areas which make up the largest block of wilderness habitat in the Rocky Mountains south of Canada. Of all remaining unoccupied grizzly bear habitat in the lower 48 States, this area in the Bitterroot Mountains has the best potential for grizzly bear recovery, primarily due to the large wilderness area. As such, the Bitterroot Ecosystem offers excellent potential to recover a healthy population of grizzly bears and to boost the long-term survival and recovery prospects for this species in the contiguous United States.
Does the habitat in the Bitterroot Ecosystem provide adequate food resources for grizzly recovery?
Habitat quality has been studied extensively. At least 6 different studies have been conducted within the Bitterroot Ecosystem that have direct applicability to the potential for grizzly bear recovery. Habitat quality varies throughout the Experimental Population Area, and likewise throughout the Recovery Area. However, studies indicate that a great variety of preferred grizzly bear foods are present in the Bitterroot Ecosystem. A wide variety of all season foods are present including good quantities of several key berry species, forbs and grasses, as well as historically high levels of ungulates to provide carrion during the fall and spring months. Food habits of black bears are quite similar to those of grizzly bears. Healthy populations of black bears live within the Bitterroot Ecosystem, and annual hunter harvest totals about 1,000. A recovered population of 280 grizzly bears should be able to find sufficient high quality forage within and adjacent to the Recovery Area. Although bear densities may not recover to their historical levels when salmon and whitebark pine were plentiful, the population should achieve densities similar to those found in other interior ecosystems where those food sources are limited or not present. The key to recovery in the Bitterroot Ecosystem would likely be effective management including limitation of human-caused mortality rather than quantity or quality of habitat.
How long would it take to recover grizzly bears in the Bitterroot Ecosystem?
Reintroduction of grizzly bears into the Bitterroot Ecosystem would enhance bear metapopulation viability in the northern Rockies by increasing genetic diversity, and potentially increasing genetic interchange among populations if bears immigrate or emigrate. It would also accelerate achievement of recovery goals through reintroduction over natural recovery.
The tentative recovery goal of Alternative 1 is approximately 280 grizzly bears. The Citizen Management Committee could recommend a revised recovery goal, based on scientific advice, once sufficient information is available. Population projections indicate that bear populations would require at least 110 years at a 2% growth rate or a minimum of 50 years at a 4% growth rate to reach the tentative recovery level of approximately 280 bears. Realistically, grizzly bear recovery in the Bitterroot Ecosystem could take a minimum of 50 years, and given more realistic estimates, could likely take more than 110 years.