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. The full coding system that was used is in Appendix A.
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.
!?The economic analysis is a travesty. On the one hand, you discuss costs in hard dollars - real money. On the other hand, benefits consist of what someone says they would be willing to pay to have grizzlies in someone else's backyard.... 'voodoo' economics at it's best.@
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. Popular comments to specific data are highlighted here. When specific pages are referenced or lengthy comments are presented, the ID team is referenced to the original letter.
Some people feel that the experimental nonessential designation would not be legal under 10(j) of the ESA. They ask if the Selway Bitterroot ecosystem is geographically separated from other ecosystems such as the Cabinet/Yaak. Some people feel there is a remnant population of grizzlies in the BE, therefore not meeting the requirements of Section 10(j) of the Endangered Species Act.
!?The DEIS incorrectly cites papers by Melquist (1985) and Groves (1987) as presenting conclusive evidence supportive of the USFWS position that there are no grizzly bears in the Bitterroot Recovery Area. Both papers contained sections on conclusions that at least a few grizzlies were likely to be inhabiting the area.@
!?The DEIS does not site any legal authority for the provision on page 2-8 , 'the CMC would be exempt from the FACA... before they would be implementing an approved recovery plan'. The DEIS is flawed for leading the public to believe that the CMC will have management options available to it that go beyond the contents of the recovery plan, while also asserting an exemption from FACA...@
!?The development and analysis of alternatives in the DEIS assumes that a population of grizzly bears is required in the study area by the ESA. This assumption does not seem to be true when you review the CFR (50 CFR 424.11 (d) (1)) and how clear the definition of 'extinction' is for delisting the grizzly bear.@
The Nez Perce Tribal Executive Committee makes recommendations to reflect specific changes to existing language in chapter 2- alternative 1. See Technical letter 836 for details.
!?In appendix 6, page 6-69 and 6-70 are identical, but the page that was suppose to be 6-70 is missing.@
!?On page 4-9, fourth paragraph, it appears that the reference to Table 3-7 should be to Table 4-1.@
!?Several treaties affect how the federal government manages federal land and wildlife, page 1-11. Each treaty should be identified along with how it effects American people and property rights. The part of the treaty that supersedes American law and rights under the Constitution of the United States should be identified.@
!?It would be helpful if the same base map were used in comparing differences in alternatives and management options, specifically maps S-1 through S-4. One uses highways as geographic references, another uses communities, and yet another uses some but not the same set of communities.@
!?The Summary needs to reconcile the costs of implementing Alternative 1. On page XVI of the Summary, the costs are estimated to be $393,632/year for the first five years, and on page XVII of the summary the costs are estimated to be $395,892 - $401,635/year for the first five years. Which estimate is correct?@
!?On page xxi of the summary the western most boundaries of the Nez Perce National Forest and Payette is EAST not west of U.S. Highway 95 and Idaho Highway 55.@
!?What is the Scientific basis for considering grizzly bears as part of America's rich wildlife heritage? 'Rich' seems to be more of a value judgement that a factual claim and needs to be changed because it could mislead the Decision Maker.@
!?The Draft EIS should be changed to state that in all alternatives, under present laws, there will be alterations in land use when conflicts with bears arise. Truthfulness should be an essential ingredient to any EIS. Past practices have shown that when there is a conflict with a listed species and humans, the listed species takes priority over the human.@
!?Alternative 4, Impact on Economics and the Social Environment, I believe you should delete the last 2 paragraphs of this section.@
!?There is a minimum number stated, but no maximum number. My question is , is there a maximum number of bears?@
!?The EIS states that no bear with a history of conflicts with humans will be used in reintroduction. This should be altered to state 'any bear determined to be a nuisance under the Nuisance Bear Guidelines'. Otherwise livestock killing bears or other 'problem' bears could be used which would not be acceptable.@
!?The DEIS states the cost wherein introduction is not undertaken (Alternative 2 - Natural Recovery) is $140,000 annually, whereas the DEIS preferred alternative introducing a nonessential experimental population costs, on average, $393,632 annually for the first five years and $168,000 a year after that. Wyoming is currently spending $800,000 per year on Grizzly management. Why is it going to cost significantly less in Idaho and Montana? Shouldn't the preferred alternative be increased by $1,200,000/annum to realistically cover the costs to the states of Idaho & Montana?@
Livestock and Wildlife Mortality
!?Numbers and conflicts are grossly under reported and estimated, especially for livestock. The subcommittee minutes of Oct. 7 and 8, list 167 bear conflicts in Wyoming, only from January, 1997 through September. They list 97 sheep depredations. Yet the Draft EIS attempts to use The Yellowstone Ecosystem as evidence that problems with sheep will be small, 0-44 per year. A relevant method of projecting the impact of reintroduction and recovery upon sheep would compare the decline in numbers of sheep grazing the Yellowstone system prior to listing with today, with the decline in an equivalent system outside of the Yellowstone recovery area.@
!?The predicted ungulate mortality in each alternative appears reasonable, but the percent calculations of loss cannot be correct. For example, on page 4-51, 720 ungulates is 0.15%. This would mean the PAA population is 480,00 (720/.0015).@
!?Page 4-29 states that 'total livestock mortality each year attributed to weather, health, poison, theft, and other non predator related mortality account for the majority of livestock losses in Idaho', and quotes a 1993 reference for this information. In the case of sheep this statement is somewhat misleading. While all the combined non-predator related causes of mortality do account for the majority of Idaho sheep losses, predation is consistently the single biggest cause of mortality for Idaho sheep producers.@
!?P. 4-11, The draft states that grazing would not be impacted. This assessment is probably not accurate given that the wolf figures were not accurate. There has been many more livestock, sheep and cattle kills than had been forecast.@
!?The Draft EIS estimates sheep losses to be small, 0 - 44 sheep per year. This number, however, does not reflect the fact that bear predation is localized, which translates into a large financial loss to a small group of ranches.@
Growth Rate Data
!?The growth rate chart for the Yellowstone grizzly population is using statistics compiled by the Craighead brothers prior to their expulsion from the park...so as far as I'm concerned, the population growth chart is misleading.@
!?Projections for grizzly population growth for the Salmon-Selway (2-11) is seriously flawed by the fact that the source data comes from the YE and NCDE, both of which have bears with the full protection of the ESA. By designating the bears in the Salmon-Selway as nonessential, experimental, they will definitely experience higher mortality that those in the YE or NCDE.@
Public Opinion Poll
!?The poll was not documented in the DEIS. It was a non-included but cited reference. It is critical to know how the poll was run, what (exactly) the questions were, what (exactly) was the definition of a 'local' etc. Since the poll was sponsored by groups advocating introduction, the data should be suspect.@
!?I believe key questions used in the public opinion survey used by the USFWS to justify public support for reintroduction were biased by implying that bad human behavior in the past was responsible for the reduction of grizzly bears in the United States.@
!?...to state that at least 50% of the local people in the Bitterroot want the grizzly bear reintroduced. This is absolutely incorrect information.@
!?...further regards to economic considerations, please clarify how the lost timber harvest calculations were made on P. 19 of the Summary DEIS. What level of harvest does this presume and how was it derived?@
Road and Trail Management
!?The 'moving windows' technique is the current best available science and must be used in the FEIS to accurately report road/trail densities. Second, some of the 'trails' are apparently open to motorized use but we are not told what percent of mi./sq.mi. As far as bears are concerned, these are 'roads' and need to be reported separately from hiking only trails. Third, high use trails have been shown to cause grizzlies to under-use habitat, yet we are not told if any of these exist, and if so where.@
Human Population Density Data
!?The use of sparsely populated county data to dilute population and other demographic data associated with impacts directly related to the most affected county is a clear demonstration of the questionable scientific data used to support this reintroduction program. The questionable population data will also affect the assessment of grizzly bear interactions or conflicts with private property, and again we assert that this issue is also not adequately addressed in the document.@
!?...adequacy and scientific basis of the cost-benefit analyses, Is there a more rigorous and defendable valuation methodology? ...use of the economic analysis endorsed by the Alliance for Wild Rockies is not defensible in this context. @ See letter 122 for details.
!?DEIS refrains from assigning dollar value to the 138 to 1,136 lost jobs to local communities under social impacts.@
!?The figures used for Alternative 1 in Table 4 - 6 on page 4 - 23 should be documented and explained. Was computer modeling utilized to arrive at this figure? If computer modeling was used what was the data provided to the computer?...Also table 4 - 6 shows some cost associated with grizzly bear recovery and besides the approximately $400,000 for grizzly bear management, you show no loss in hunting revenue and between $2260 and $8003 in value of livestock losses. The basis for these figures should be explained.@
!?What interest rates were used? In what year are benefits first assumed be begin? What value do you place on human life and what costs are associated with those hurt by bears.@
!?...how accurately can the public estimate what they would be willing to pay if most of them have on previous experience with trust funds of this kind? The economists 'scaled' the answer by a whopping 28.6%, that is, the amount people were willing to pay is about 70% more than what they would actually pay.@
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.
!?In addition, IWGA feels that there have not been adequate public hearings on the issue.@
!?We believe that the success of this endeavor hinges upon broad public acceptance of a method for bear recovery. The decision-making process should allow more time for an active public out-reach program that reaches down to county and local groups, elected officials, and concerned individuals...The proposed reintroduction schedule for the preferred alternative seems ambitious given the need to have the broader base of public support .... Adequate time should be added to the reintroduction schedule for this alternative.@
!?The Draft EIS violates the National Environmental Policy Act. It does not include a full range of alternatives. In particular it does not include an alternative that will eliminate the conflicts between opposing groups regarding Grizzly bears and provide for the future of the Grizzly bear...The missing alternative would, based on the expanding populations of Grizzly bears in other Montana areas, delist the Grizzly bear, and revest the management of the bear in the respective states. Allow Grizzly bears to reoccupy the Bitterroot ecosystem on their own volition, and as the habitat will support.@
!?The Salmon hearing was not a fair hearing. There were local folks outside who were afraid to speak up to support grizzlies. The moderator was lame, lame, lame, Strike the record of that hearing@
!?The U.S. Fish and Wildlife should be honest with the people, instead of leading them once again that their opinion might count. The city dwelling 'animal activist' have lead the march on this issue. And the U.S. Fish and Wildlife agrees because it means work and jobs for them.@
!?The DEIS states that the U.S. Fish and Wildlife Service met with all the county commissioners in adjacent counties, but that was before the introduction area changed. Lemhi County Commissioners have never had a meeting...the EIS coordinator would not accept certified mail from the county containing a Freedom of Information Act request...the analysis and proposal do not correspond and this constitutes a major violation of NEPA...because there is no study of the area south of the Salmon River or the new grizzly bear reintroduction area.@
!?The only problem here was the fact that the real, precedent - setting decisions are being made behind closed doors in the consultation process. The people were shut out of the process at the critical level that generated the 'on the ground' implementation that had real-life impacts to our customs and culture, our traditional way of life in small rural communities.@
!?FWS DEIS fails to incorporate a true 'No Action' alternative. Upon 'implementation' of the 'No Action' alternative, the FWS would impose Section 7(a) (2) consultation requirements, and would designate the Selway-Bitterroot Recovery Area. These requirements are actions.@
!?...the No Action Alternative does not comply with CEQ regulations, and the FWS must prepare and circulate a revised draft incorporating a true 'No Action' alternative...@
!?...USFWS is not fulfilling its NEPA obligations by circulating one proposal, only to alter it, with no opportunity for public input, in an effort to build support for the preferred alternative... (the) DEIS... should be withdrawn.@
!?...few hearings have been held...Neither the Scouts nor the many other Churches and organizations which have facilities within the affected area on National Forest lands have been notified by you in any way.@
!?We strongly feel that the failure to even mention delisting as a possibility is a violation of both NEPA and ESA. It is our belief that the failure to analyze an alternative that would delist grizzly bears violates both NEPA and ESA; misleads the interested public; is counter to issues discovered through the scoping process; and fails to consider the opinion of Idaho citizens.@
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.
!?There is nothing in the EIS that establishes that reintroduction of Grizzly bears into the Bitterroot ecosystem is essential for the maintenance of a healthy, viable Grizzly bear population, either in the lower 48 United States, in North America, or in the world. In fact the preferred alternative recommends that reintroduced grizzlies be established as, 'experimental, non-essential', meaning that the survival of this population of Grizzlies is not required to maintain the Grizzly as a species.
!Where does this mandate to reintroduce grizzlies come from? From whom does the overwhelming clamor to reintroduce the grizzly, where does it come??
!?...we've got bears in the Yellowstone ecosystem,... on the Rocky Mountain Front,... up around Northwest Montana and we're having trouble recovering those populations, so why are we going to embark on another program in another area with a whole new set of management issues and problems and habitat impacts for the sake of saying that we're going to recover or manage bears.@
!?The 'Need for Action' section on pages 1-4 and 1-5 should explicitly state that USFWS is not legally required to reintroduce grizzly bears in the BE. There is considerable confusion among constituent groups regarding whether introduction of an experimental non-essential species is a mandatory act. By creating the impression that USFWS is legally required to reintroduce grizzly bears into the BE, the DEIS offers the public a false choice.@
!?If the USFWS and other groups want the grizzly bear so bad why don't they reintroduce them back to California?@
!?This document does not convince me there is a need, and in fact seems to suggest that the bear should be delisted because it is not only surviving but beginning to thrive in the areas it is already in.@
!?...the need talks about legal need and a biological need for the bear. It should talk about the need for reintroduction. Two different things. So I think you need to rewrite the need because if the decision maker is going to make a decision that could ultimately lead to somebody getting killed, he needs to have a really good need to make that happen.@
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 One'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.
Publication of the Proposed Rule in the Federal Register
Several individuals feel the U.S. Fish & Wildlife Service are taking a liberal interpretation of the Endangered Species Act that will circumvent the present protection given to the grizzly bears.
!?Section 10(j) contains no provision whatever which authorizes delegating ESA responsibilities to a citizen committee. The USFWS has embraced a liberal interpretation of Section 20(j) special rules to mean they can make up anything they want. All rules must be consistent with the governing law, in this case the ESA. The special rule also mandates the citizen committee must minimize social and economic impacts, which is not a part of ESA planning. This mandate will easily be construed to mean that the citizen management committee must not allow any reductions in timber harvesting or roadbuilding in order to aid recovery of grizzly bears. This is a clear violation of the ESA....the preferred alternative is not a legal alternative. To adopt the preferred alternative as the action alternative will require amendments to the ESA.@
!?The Proposed Rule delegates an excessive amount of authority to the Citizen Management Committee...What is to guide the Committee when recovery goals clash with social or economic interests? ...delegating management authority to the CMC is beyond the authority of the Secretary...it would require a change in the law by Congress.@
A few respondents make the following suggestion regarding the special rule and the CMC:
!?Under the special rule, replace the Citizen's Management Committee with a Co-Management Committee consisting of citizens, agency representatives, and scientists.@
Numerous commenters question the legality of publishing the preferred alternative and not the other alternatives in the proposed rule because it appears the decision is already made. They claim this is in violation of NEPA, the National Environmental Policy Act, to present all alternatives in an equal fashion.
!?Alternative 1...also appears as a proposed rule published in the Federal Register...Although selecting an alternative as preferred in a DEIS does not violate NEPA, publishing that alternative to the exclusion of others in the Federal Register gives it special favored status. This action gives the distinct impression that a decision in favor of Alt. 1 has already been made. The DEIS is written with the assumption that the public favors re-introduction, which is not the case.@
!?This leads one to conclude that the decision on which plan to implement has already been made, instead of the required NEPA process to determine the best alternative to choose. Only AFTER the record of decision has been signed, should comment be solicited on the proposed rule change.
!?NEPA prohibits federal agencies from committing resources toward a NEPA project prior to issuing a final decision when such a commitment may prejudice its selection of one alternative over another...By publishing the Proposed Rule in the Federal Register concurrent with releasing the DEIS, FWS has...cast serious doubt on the integrity of the NEPA process...The NEPA regulations also prescribe agencies from taking any action that limits its choice of reasonable alternatives prior to making a final decision. The preparation and publication of the Proposed Rule violates this directive.@
Some people comment on the possible conflicts the proposed special rule would have with Forest Plans.
!?The DEIS fails to consider possible conflicts with Forest Plans. The proposed special rule would govern recommended changes to Forest Plans. The DEIS discussion fails to adequately address the effects of the proposed alternative on the Forest Plans ...comprising the Experimental Population Area...The provision allowing the CMC to recommend changes to forest plans indicates that the current and future plans may conflict with the proposed alternative. Instead of addressing possible conflicts as required by CEQ regulations, the DEIS simply presumes harmony, probably because the FWS will require it through forest plan amendment or revision.@
The following comments reflect additions and/or recommendations to the special rule:
!?...The CMC and the public should have assurance...grizzly bear recovery will be adequately funded for the entire process to delisting. The CMC should be given full authority to recover grizzly bears, as long as decisions and actions ultimately lead to recovery...Oversight of the CMC could lie with the Interior Secretary or an independent panel of scientists. The final rule should encourage participation by more than just CMC members. A strong public education component must be part of Alternative 1 and be sufficiently funded.@
One respondent suggests the Fish & Wildlife Service needs to clarify they will adopt the recovery goals and guidelines established in the Bitterroot Chapter of the Grizzly Bear Recovery Plan, and that these will be used by the committee (GBRC) to guide their management process.
!?Recommend that the USFWS establish initial guidelines for tasks (J), (L), and (M) as...listed in Appendix 13 of the DEIS. ..We suggest..the final rule establish and provide the committee with clearly stated recovery goals and guidelines based on the biological requirements necessary to recover a grizzly bear population in the Bitterroots...management committee could be allowed to review recovery goals and guidelines and make recommendations to fine tune or improve criteria to better ensure recovery of bears, however such recommendations must meet biological recovery requirements and could only be approved by the Secretary of Interior.@
Another individual suggests the addition of short and long-term evaluation criteria be established in the Final Rule.
!?Recovery evaluation criteria should include protocol for determining when reintroduction has failed. Reintroduction efforts should only be determined to be @unsuccessful? based on biological grounds...should include the intent of developing an alternative recovery strategy if failure of grizzly bear recovery in the Bitterroots is determined to stem from socio-political reasons or a flawed recovery strategy.@
Numerous people write in their comments they support Montana Governor Marc Racicot's suggested changes to the proposed rule. Due to the number of people voicing their support, Governor Racicot's suggestions are provided here:
!?In the event the Secretary of Interior determines the actions of the Committee are not leading to recovery of the Bitterroot grizzly bear population, then the Secretary of Interior shall recommend, based upon the best scientific and commercial data available, alternative actions and provide a 6-month time frame in which to accomplish those actions. Should the Committee reject those alternatives, the Secretary shall submit for peer review to a scientific panel of three those CMC actions or decisions upon which the Secretary's based his decision to reassume lead management authority. The panel shall review the information, solicit additional information if necessary and, using the best scientific and commercial data available make a determination based upon the preponderance of the evidence, whether the CMC actions or decisions would lead to recovery....The Secretary shall...consider the recommendations of the panel in determining whether to reassume lead management authority. The Secretary shall select one member of the panel, the CMC another and those two shall select the third who shall act as Chairman. Should the Secretary...decide to resume lead management responsibility, he shall seek consultation with the Governors of Montana and Idaho to review with them the reasons for his decision and attempt to resolve the discrepancies...If after that meeting, the Secretary resumes lead management responsibility, he shall publish a rule outlining the changes intended for the management of the grizzly bear in the Bitterroot Ecosystem.@
A few people feel the proposed rule treats private landowners in Idaho differently than those in Montana.
!?Section 17.84(k)(12)(ii)(L) of the proposed rule specifies that @private lands outside the national forest boundary in the Bitterroot Valley are an area where any human/grizzly conflicts would be considered significant. Grizzly bear occupancy will be discouraged in these areas and grizzly bears will be captured and returned to the Recovery Area.? This seems like a reasonable proposal for reducing the likelihood of human/grizzly conflicts, but it also seems arbitrary and discriminatory not to authorize similar guidelines for private lands in Idaho. Why should private landowners in and adjacent to the Experimental Area in Idaho be treated any differently than private landowners in Montana?@
The State Director for the Idaho State Animal Damage Control Board (APHIS) requests this agency be involved in capture of depredating grizzly bears in Idaho.
!?Sections 17.84(k)(5)(iii) and 17.84(k)(6) both refer to take of grizzly bears by the US Fish & Wildlife Service or by State or Tribal wildlife agency personnel, but there is no mention of involvement by personnel from the APHIS Wildlife Services program. Under the current MOU between the Idaho dept. of Fish & Game and the Idaho State Animal Damage Control Board, APHIS...has the lead responsibility for capture of depredating grizzly bears in Idaho. The proposed rule as currently written might preclude this cooperation..., but this...could be easily addressed by including reference to APHIS as one of the potential cooperating entities.@
The Nez Perce Tribe requests the wording changes reflected in the next two quotes to be incorporated into the final rule.
!?Management direction outlined in Alternative 1 for bears outside of the recovery area is vague, stating that bears outside would be @accommodated? rather than @emphasized?. The Nez Perce Tribe is concerned that @accommodated? may not insure adequate protection of bears that may be attracted to suitable high quality habitats within the BEA but outside of the recovery area...Define @recovery emphasis? and @accommodated? management strategies in terms of specific management guidelines and actions that clearly distinguish between them. These guidelines should be included in the Final Rule.@
!?...determination of an Unsuccessful Reintroduction@ is not clear. The reintroduction efforts may fail for three distinct reasons: 1) biological, 2) socio/political, and 3) flawed recovery strategy. It is important to identify the cause before making a ?Determination of an Unsuccessful Reintroduction@ as it may be appropriate to terminate reintroduction efforts if the effort is failing for biological reasons, but not appropriate if the cause is socio-political or due to a flawed recovery strategy.?
Several respondents claim the rules for dealing with problem bears on public lands are unreasonable, and are particularly critical of the requirement to report problem bears within a 24-hour timeframe.
!?Rules dealing with problem bears on public lands are unclear and confusing. PP.6-127(6)(iii), appears to offer a way to deal with problem bears even on public lands, but when taken with other elements of the rules this remains unclear. Since Idaho has very little private land, clear rules to deal with problem bears on public land is essential...24 hours to report the harassing of bears to two government agencies is foolishly unworkable, and represents a gross lack of understanding of and communication with affected parties.@
Experimental, Non-essential Designation
Several respondents support the designation of experimental, non-essential for alternative 1 because they feel it provides management flexibility and is able to address unique local concerns. Some say it worked well for the reintroduction of the wolves, so the proposed rule on this effort should correspond to the proposed rule on the reintroduction of the gray wolf.
!?As with wolf reintroduction in Yellowstone and Idaho the nonessential experimental designation appears to work best at calming local interest fears and doubts. Has the most flexibility, which is essential.@
!?Alternative One will allow flexibility in dealing with human/bear conflict that would not exist were the local bear population to enjoy the full protection of ESA as envisioned under both Alternatives Two and Four.@
!?A designation of nonessential and experimental will help appease people opposing the proposal and might also help limit human/bear conflicts...The grizzly bears in the Bob Marshall and the Cabinet Mountains seem to avoid people and are rarely a problem, as far as I'm aware. Historically, they have also been less protected and this seems to have fostered a healthy respect of humans.@
The biggest opposition to this designation comes from those who feel it is in violation of the Endangered Species Act and does nothing to protect the habitat in the Salmon-Selway-Bitterroot Ecosystem. They also denounce this designation because there would be no linkages between this population and other populations in the Northern Rockies. Several respondents also assert there are bears in the Bitterroot Ecosystem now so the designation of the population of experimental, non-essential should be denied.
!?...the removal of protected bears from an already threatened population and designating them @experimental, non-essential? blatantly undermines the Endangered Species Act.@
!?I oppose Alternative 1, which reduces protections for reintroduced bears to non-essential status...Removal of bears from threatened populations in the lower 48 states constitutes a @taking? under the Endangered Species Act and is therefore illegal.@
!?Designation as nonessential experimental, however, is not supportable under the ESA for grizzly bears in the lower 48 states particularly when the source of the reintroduced bears is a fully protected population.@
!?...downgrading protected Yellowstone and Northern Continental Divide Grizzlies to an @experimental, non-essential? population is dangerous. Not only will it threaten the populations the bears are taken from, but it also does nothing to protect the habitat in the area the bears are going to.@
!?The designation...and no impacts on land use activities including timber harvesting, road building and mining influenced our decision not to support alternative 1.@
!?I strongly oppose Alternative 1 submitted by the Resource Organization on Timber Supply and others, which gives the grizzly a status of @experimental, non-essential? and which removes habitat protection while providing for an extremely limited and isolated recovery area.@
!?TWS [The Wilderness Society] does not support this approach because the DEIS admits that under this classification the agency is forbidden from fostering any connections between a Bitterroot population and other populations in the Northern Rockies.@
!?...to even be considered for this designation the recovery population must be physically and geographically separate from all other populations. The Salmon-Selway Ecosystem is only 40 air miles from the Cabinet-Yaak grizzly population; there has been documentation of a radio collared bear from the Cabinet-Yaak moving south and establishing a den in the Salmon-Selway.@
!?...a list of credible grizzly bear sightings south of the Clark Fork River were provided by the U.S. Fish & Wildlife Service (1997). The list of 17 sightings between 1979-1996, included some in the Bitterroot Recovery Area...The DEIS incorrectly cites papers by Melquist (1985) and Groves (1987) as presenting conclusive evidence supportive of the USFWS position that there are no grizzly bears in the Bitterroot Recovery Area. Both papers contained sections on conclusions. Both concluded that at least a few grizzlies were likely to be inhabiting the area.@
Some respondents counter the argument that the experimental, non-essential designation has not precluded recovery of wolves in Yellowstone (leading some to argue that it will work for bears as well). These respondents say they disagree with that argument because bears have significantly lower reproductive rates than wolves and are therefore much more sensitive to increased mortality.
!?While the ... designation for wolves appears to be a success, based on their recovery to date, it is not valid for grizzlies because it ignores an important biological difference between the two species; that is, their different reproductive potential. Bears are not wolves, and cannot be successfully managed as if they were.@
!?Although use of Section 10(j) appears to have benefitted the recovery plan for the gray wolf, we believe that the wolf situation was different because the individual wolves were being moved from an area of less protection to an area where protection was higher.@
Consultation with the Fish & Wildlife Service
Only a handful of respondents responding to this issue say they support the proposal to do away with the Section 7 consultation under the Endangered Species Act in order to continue resource extraction activities. Many of those in favor of this proposal also support alternative one and more management flexibility.
!?Because the USFWS would continue to have section 7 ESA consultation in this 'no action' alternative [Alternative 2], I am opposed to it.@
!?...we underestimate what the negative impact Section 7 consultation can be on our use, recreational use of the forest.@
Those opposed to the proposal for eliminating Section 7 consultation with the USFWS say it is because there would be no protection of habitat from extractive activities. Many see this as sacrificing habitat needed, especially roadless areas, to ensure the grizzly bears' survival.
!?There would be no protection of habitat, nor would the Forest Service be required to enter formal consultation with the U.S. Fish & Wildlife Service on timber sales, mining, roadbuilding, grazing, or other development.@
!?Habitat degradation, referred to time and again in the DEIS as a significant factor in the demise of the grizzly will accelerate under an experimental, non-essential designation by removing the requirement of the ESA mandating formal Section 7 consultation with the USFWS to ensure activities by the Forest Service such as logging, mining, burning, and roadbuilding will not adversely affect recovery...By trying to maintain @land management flexibility? USFWS is potentially sacrificing necessary habitat which is the only way bears will survive in the Greater Salmon-Selway.@
!?The recovery program might, in the long term, be jeopardized by the cumulative habitat degradation which will occur due to the omission of Section 7 consultation by the U.S. Forest Service and other agencies.@
Endangered Species Act
Comments on the Endangered Species Act overlap with those of the previous three topics, and the reader needs to consider that interrelatedness . Several comments from the previous topics also pertain to this section.
A few individuals are supportive of the U.S. Fish & Wildlife Service for their positive interpretation of the Endangered Species Act. The supporters of this interpretation are also usually fans of the Citizen Management Committee
!?We believe the citizen management alternative represents a positive and significant breakthrough approach to the Endangered Species Act...the citizen management committee, representing a cross-section of interest, would be able to readily address problems involving both interstate and intergovernmental issues...use of the citizen management committee would facilitate communication between the various government entities and would ensure swift response to problems should they arise.@
!?The members of the Montana Society of American Foresters (SAF) believe the conservation of species and ecosystems is important to society and the profession of forestry...that the Endangered Species Act would be improved by speaking to the rights of people as well as the plant and animal species in jeopardy...the SAF does not have a formal position on the various alternatives...however, we support two key elements...experimental population to expand the range of threatened and endangered...development of a citizen management committee.@
!?...citizen management offers a precedent for changing a cumbersome, bureaucratic, incredibly costly law that has an extremely poor record of recovering species. The current ESA also fails to fully enlist the resources of citizens and private landowners in the recovery process.@
!?...the Endangered Species Act directs us to recover grizzly bear populations. However, it provides broad discretion in how management responsibilities are met, especially where experimental population are designated. We sincerely believe that the Citizen Management Alternative best accommodates the recovery of a grizzly bear population while sustaining vibrant economies and allowing effective citizen participation.@
Most of the comments received on this issue are extremely critical of what they view as a misinterpretation of the Endangered Species Act. Several call for the full protection of the grizzly bears under the ESA. Many question the legality of removing the protective status of the grizzly bears. Several also point out that Section 10(j) contains no provisions to authorize delegating ESA responsibilities to a citizen committee.
!?Section 4(a) of the ESA presents five factors to be considered in decisions to list or de-list a species. Creating @experimental, non-essential? population using bears currently listed as @threatened? is not included in the five factors.'
!?Given the biology of the bear and some of the misconceptions of a portion of the public, the bear does not stand much of a chance without full ESA status.@
!?The reduced level of protection under the Endangered Species Act will lead to a greater number of mortalities and more severe destruction of habitat, thereby jeopardizing the chances of successful reintroduction.@
Several respondents call for de-listing the grizzly bears as they believe there are plenty of grizzlies now. Frequently they also ask that the management of grizzly bears be controlled by the States where they live. Some ask for analysis of an alternative to delist grizzly bears. Most of these comments come from supporters of alternative three. Conversely, critics of alternative three claim it does not meet the legal mandates of the ESA and should not have been included in the DEIS.
!?Grizzly bears as a species are not threatened with extinction. There are viable populations of these predators in Glacier and Yellowstone national parks as well as the Mission Mountains north of Missoula and many areas in Canada and Alaska.@
!?IWIT finds that analysis of alternatives in the DEIS misleads the public into believing the ESA requires populating the study area with grizzly bears. We strongly feel the failure to even mention delisting as a possibility is a violation of both NEPA and ESA; misleads the interested public; is counter to issues discovered through the scoping process; and fails to consider the opinion of Idaho citizens.@
!?The State of Montana unequivocally agrees the populations in the two U.S. ecosystems are healthy, they have exceeded recovery goals and should be removed from the list of threatened species under the ESA...those populations could support the withdrawal of the bears projected in the EIS. However, the EIS inadequately and incompletely analyzes the consequences of such withdrawals, particularly the cumulative impacts, to delisting these populations.@
!?We further recommend that the Grizzly bear be delisted and management returned to the State.@
!?The Draft EIS violates the National Environmental Policy Act. It does not include a full range of alternatives. In particular it does not include an alternative that will eliminate the conflict between opposing groups regarding Grizzly bears and provide for the future of the Grizzly bear...The missing alternative would, based on the expanding population of grizzly bears in other Montana areas, delist the grizzly bear, and revest the management of the bear in the respective states. Allow grizzly bears to reoccupy the Bitterroot ecosystem on their own volition, and as the habitat will support.@
!?Alternative three does not meet the legal mandates of the ESA and therefore should not have been included in the DEIS.@
A great number of supporters of alternative four say it is because it maintains full protection under the ESA for all grizzly bears.
!?There are several reasons why I support the Conservation Biology Alternative [Alternative 4] proposal. First, grizzlies are currently a threatened species under the Endangered Species Act and CBA would continue this status while the other two would not.@
!?Under Alternative 4 there will be full protection for the grizzly bear as a threatened species under the ESA. The grizzlies will receive protection whether they are reintroduced or immigrate of their own accord.@
!?I want all grizzly bears to receive full legal protection as a threatened species under the Endangered Species Act. Further, if grizzly bears are to survive, they need protection of roadless areas and they must be connected to other grizzly bear populations with corridors.@
Critics of Alternative One frequently see it is a political move to take the grizzly bear off the endangered species list and to eliminate the Endangered Species Act.
!?I have no question that Alternative 4 would be better for the grizzly bear. But I have to live in the real world, whether we like it or not we've elected a whole bunch of congressmen and senators who would like to gut the Endangered Species Act.@
One person contends the Fish & Wildlife Service is violating the ESA by not evaluating the effects of the grizzly bear on salmon.
!?...if they had done their environmental impact study correctly they would have mentioned that the grizzly is a threat to the fragile status of the endangered salmon...willing to violate its own Endangered Species Act.@
Distrust of decision makers and anyone in control of any part of this process is evident.
!?Even if the USFWS would consider this @containment zone? alternative, I am still very troubled by the ESA and the arrogance displayed by the USFWS in carrying out mandates of the ESA. Please tell me where in the ESA the decisionmaker for this recovery plan is authorized to commit assault with a deadly weapon, manslaughter, and even pre-meditated murder, using the grizzly bear as his weapon of choice?@
!?Alternative one is merely a political move to take the Grizzly off the endangered species list.@
!?...subjugates more and more people and land use control under the strangling grip of the Endangered Species Act.@
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.
!?The impacts of Brucellosis vaccines on Grizzly Bears were not addressed in the Grizzly Bear Recovery in the Bitterroot Ecosystem Draft EIS, therefore the EIS is inadequate...The Draft EIS must be withdrawn and re-written or amended to include results of the research, with appropriate comment periods, to address this vital issue.@
!?...there is something wrong with the 40 million dollars per year existence value that's credited in all the alternatives for the bear. I think that flaws the whole economic analysis and I think in the final document you need to take a look at that.@
!?In Alternative #1, the EIS fails to adequately analyze the impact of the grizzly bears as they leave the Selway and begin to move into the Bitterroot Valley of western Montana.@
!?The Grizzly Bear Recovery in the Bitterroot Ecosystem fails to note the off-highway vehicle use is also expected to have moderate growth to the year 2010. Last year, our off-highway motorbike/ATV registrations grew 18%. Our program recommends that the Fish and Wildlife Service use our new 1997 Idaho Comprehensive Outdoor Recreation and Tourism Plan for more up to date information in the final report.@
!?In estimating predation on livestock and ungulates, it is indicated that a recovered population would kill up to 504 ungulates per year...Though not stated , in reading your rational, one would have to assume these levels would not actually be attained until recovery was fully achieved, or approximately 100 years. It may help to clarify this aspect of the proposal.@
!?...Throughout the various alternatives, an average cost of $160,000/yr. is presented as an estimated annual implementation and monitoring cost of 4-6 bears in the program during the first five years, recognizing that they could go as high as $800,000 over five years. ... given the scope of your proposals in any alternative, it would appear to me that the $800,000 figure would be a low end annual estimate, especially during the first five years of implementation.@
!?...omitted is (an) analysis of the cost to backcountry travelers of purchasing the equipment necessary to comply with these kinds of requirements. The only reference I find to these considerations is on page 4-18...regulations requiring outfitters...to use bear-proof garbage and food containers or hoists...Are you stating that these regulations would not apply to the non-outfitted backcountry traveler? What are all the impacts on recreationists - quantitative and qualitative? This entire section needs re-analysis and a much more candid discussion.@
!?The 'moving windows' technique is the current best available method, and must be used in the FEIS to give an accurate picture of actual road densities. Second, only half the 'trail' miles are currently closed to motorized use, thus essentially roads. Finally, there is no description of high use trails and their extent, which causes grizzlies to underutilize habitat in these areas...@
!?Even though...public scoping identified corridors as a major issue that a large number of the public wanted addressed in the DEIS. The DEIS failed totally to analyze the benefits of road obliteration and recovery of habitat security within this proposed linkage zone.@
!?The mathematical equation used on page 4-9 to predict the estimated annual livestock losses relies on use of the mean annual depredations experienced in the Yellowstone (YE) and Northern Continental Divide Ecosystem (NCDE). The figures used for calculating the mean annual grizzly depredation on sheep in the YE are only for the 1994-1995 period, and the mean is zero...while there may not have been any reported grizzly predation on sheep in 1994 or 1995 there was definitely grizzly depredation on sheep in the YE in 1996 and in 1997... Wyoming Game and Fish Department (WCFD) ... records indicate that grizzlies in the YE were responsible for the deaths of 47 sheep in 1996 and 106 sheep in 1997. There is more recent data available regarding livestock losses in Idaho than what is cited on page 4029 on the Draft EIS.@
!?Research should be initiated to satellite map this area in detail...in order to evaluate and identify habitat types, quality, and distribution throughout the expanded recovery area.@
!?...it's important for the service to take advantage of opportunities in 1998 to gather additional information on habitat quality, especially south of the Salmon River. We also urge the Service to incorporate the data on habitat quality in this area that have been developed by Dr. David Mattson.@
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.
!?Missing from the DEIS is a review of the employment and earnings by industry for the PAA, to give the reader an appreciation of the relative importance of the industries within the PAA.@
!?Re: Economic factor (see table 5-3) no discussion of possible loss of timber jobs for Alt 1 & 4. No livestock loss with Alt. No. 2.@
!?No where in the DEIS is there any specific analysis of the economic impacts on the Idaho outfitting and guiding economy, which is closely associated with the rural communities that surround the recovery area.@
!?The DEIS completely fails to analyze the impacts on the local communities, and in fact fails to even describe the local communities.@
!?There is on appraisal of the number of jobs gained due to road reclamation efforts. Table S-3 shows that approximately 3500 miles of roads would be reclaimed, requiring significant amounts of labor to implement.@
!?The DEIS fails to include in the summary that Alternative 4 would increase job opportunities for a period of time through active restoration of logging roads. It misleads the public by not including all of the economic consequences of the alternative.@
!?The USFWS should specifically delineate these roadless areas and corridors and establish management prescriptions for these key areas.@
!?I would encourage incorporation of the Mattson and Merrill appraisal of grizzly bear habitat to buttress the Butterfield and Davis appraisal.@
!?I do not feel that you have done an adequate study of the habitat needs of a grizzly population in the Selway-Bitterroot compared to the available habitat...@
!?The DEIS is quite deficient on quantification of food supplies, indicating only that the appropriate vegetation types and known Grizzly Bear food plants are present in the BE. Vegetation types...should not be so used to predict wildlife habitat quality-only the possibility that a species might be present...the fact that Grizzly Bear foods are present says nothing about abundance and nutritional value, two topics for which the DEIS offers no information...@
!?The EIS fails to adequately analyze the impacts of grizzly bear reintroduction when such bears move into the Bitterroot valley of western Montana.@
!?The issue of liability is crucial to policy makers, yet it is unresolved in the EIS. (indeed, it is not even mentioned.)@
!?A substantial amount of fear of this species is rooted in the unknown, but it nevertheless is real and must be dealt with. The best way to deal with it is to introduce the bear and let people get used to its presence@
!?IWIT respectively requests a supplement to the DEIS that considers delisting as an alternative.@
!?Though Montana has received verbal assurances that no bears will be taken from either U.S. ecosystem if mortality quotas have been reached of exceeded in a particular year, this is not explicitly stated in the draft EIS. Further, the EIS fails to analyze the cumulative implications on delisting. [See Technical letter 2747 for additional details].
Relationship with Other Wildlife Species
!?I think you should address this issue to a greater extent than by just assuming that since there is presently a thriving black bear population in the area there should be enough food for grizzlies. Grizzlies will probably displace enough black bears to make up for the additional food requirements if they can survive on the same food sources, but this should be documented if at all possible before funds are committed for transplanting.@
!?...The final EIS must include a comprehensive analysis of what effect grizzly bear recovery in the GSBE will have on other threatened and endangered species such as salmon and steelhead. In other words, a multiple species ecosystem approach should be taken that does not benefit one species while at the same time it increases the imperilment of other species.@
!?The cumulative effect of wolves and grizzlies was not covered well or at all in the DEIS. They need to be treated together and the total effect presented in the EIS.@
!?The EIS should incorporate as an appendix written assurances from appropriate officials in British Columbia that a certain number of bears will be made available. Without that assurance, the EIS must analyze the potential impacts of obtaining all the required bears from U.S. ecosystems.@
!?Based on the Cabinet (Yaak) experience, the EIS is deficient in that it fails to evaluate whether the numbers of bears projected for reintroduction is sufficient to establish a viable population and fails to evaluate the opportunity for success at various levels of bear numbers introduced.@
!?The DEIS lacks many details necessary for evaluating of justifying the plan. For example why was the number '25' chosen as a minimum for reintroduction? In what areas (specifically) will the bears reintroduced and how will these areas be chosen?@
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.
!?If bears should get on anybody's property and damage it in any way, they should be shot and killed.@
!?I think shooting a bear is only justified when your life is in danger.@
!?If there is a problem when the grizzlies are harassing livestock just move the grizzly bear around and that way the grizzly will not harass people anymore.@
!?This is a practical plan, however I believe it allows too much latitude in killing 'nuisance' bears.@
!?Remove any bears that wander off or present any danger to communities.@
!?While I sympathize with ranchers' possible losses of livestock, killing threatened animals seems like a large price for the loss of livestock, that has a high mortality rate by other means.@
!?If landowners run into problems with the grizzlies, the problem should be reported and dealt with by professionals.
!?The proposed rule does not specify, whether or not a livestock owner must first have suffered some kind of harm or killing of his livestock by grizzly bear before the permit can be issued, or whether such a permit could be issued ahead of time to any livestock owner who might reasonably be expected to encounter grizzly bears on his grazing allotment....It would seem to be in the best interests...if the Final Rule would facilitate any nonlethal, noninjurious attempts to harass or scare grizzly bears away from livestock...allow livestock producers to opportunistically harass grizzly bears when they are found near their livestock, without any need for a permit, but with the provision they must report such harassment as soon as possible, but always within some reasonable time period, such as 3-7 days.@
!?An absolute requirement to notify the FWS within 24 hours is not reasonable, given that some sheep herders may be miles away from a road and may not be able to communicate with the livestock owner for days at a time. It also seems unreasonable unless the FWS and other agencies requiring notification are available 24 hours a day.@
!?Rubber bullets and hazing aside, it would seem logical that some form of behavioral conditioning on the bear's part, would also be in order to establish or maintain an aversion to things human in nature.@
!?Your ideas for allowing livestock owners to harass bears and kill with a permit is an idea with zeal. If bears are released in good habitat this becomes a non-issue as the bears will stay home.@
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.
!?I am concerned the efforts to destroy bears by some of the public may negatively affect the recovery...@
!?I am confident that the bears will be killed as quickly as they are introduced.@
!?These magnificent animals deserve respect. Radio collaring, trapping, translocating , and removing their protected status under the ESA does not provide that respect.@
!?I am deeply saddened to see animals, particularly endangered ones, drugged, caged, and completely removed from their element. I think this serves to isolate and harm far more than it fosters or protects.@
!?There are very few berries in Central Idaho and no salmon, hence no natural food. So the grizzly bear will have to harass the residents or just leave, probably explaining why they aren't here now.@
!?Alternative 1 will not provide the corridors between the Selway/Bitterroot ecosystem and other nearby areas the bears use. This limits long-term recovery effectiveness and may yield inbreeding and genetic problems.@
!?We find no biological evidence that the identified recovery area provides sufficient habitat to achieve grizzly bear population recovery objectives.@
!?If whitebark pine is on the decline because of blister rust, and there are not as many fish as there once were, and huckleberries are an unreliable source of food for grizzlies, depending on the year, what is to keep the bears in their @Recovery Zone? instead of in people's apple orchards
!?...the Yellowstone populations and the Northern Continental Divide populations need to intermix with other bears or their genetics are going to get inbred and eventually become extinct. It is absolutely essential that the entire ecosystem include biological connecting corridors.@
!?The selection of certain areas over others just because they are currently vacant of the bear ignores the long term real nutritional needs of the bear. The Idaho Fish and Game Commission finds that no biological evidence is presented in the plan to establish the habitat as adequate.@
!?It seems that the folks who are pushing the recovery agenda are not interested in the factual evidence of poor habitat and bear-human conflicts, and are focused only on winning the philosophical arguments, at the expense of the bear.@
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.
!?I now (9 years) live near Gibbonsville ID on Hwy. 93 within the BE as it is drawn. I will protect my property (in your words-livestock in my words) even though you tell me I should call USFWS while a GB kills them.@
!?I don't think the bears should be killed because of livestock being attacked. However, a compensation fund, from USFWS or a private organization like defenders of wildlife would help ease the minds of farmers and ranchers.@
!?...it is highly likely that management under this proposed status (10(j)), combined with the direction from the Citizen Management Committee would result in an excessive and illegal level of 'take'.@
!?In EDF's view, therefore, the special rules developed under Section 10(j) with respect to the taking of the wolf in Yellowstone should serve as a model for similar rules applicable to the taking of reintroduced grizzly bears....In general, the closer the proposed rules correspond to those that apply to the wolf, the more supportive of them we are.@
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.
!?I do feel that, if such a fund is established, it should be included in the overall budget for reintroduction rather than depending on private donations as was done for wolf reintroduction.@
!?Those who wish to promote the reintroduction of grizzlies should bear the responsibility of this wild creature upon their fellow citizens. The least that can be done is to financially reimburse the individuals and families that will suffer physically and emotionally from bear maulings.@
One person makes the following comment related to grizzly bear's effect on animal damage control activities:
!?We do anticipate, however that grizzly bear recovery would eventually impact ongoing animal damage control operations to some degree. With the creation of another potential predator/livestock conflict situation, the Wildlife Service program can expect to receive additional requests for assistance to help resolve problem that had not previously existed.@
Some respondents take aim at the Defenders of Wildlife and other groups who support compensation.
!?If some zealots want to spend a bunch of money, let them take their dollars and put up a private money bond, to reimburse people and governments who are adversely affected, either economically or physically, by the grizzly bear reintroduction. Let them also spend some time, calculating just how many dollars a human life is worth.@
More popular comments have the following themes:
!?It is my understanding that any restitution for damages to property, livestock or anything else will be from the Pro Bear Advocates, I believe that the USFW Service should be responsible for this.@
!?I would like to see local people involved and a fund set up for genuine kills involving ranchers@
!?We should also establish a fund similar to what they've set up for wolf killings (Defenders of Wildlife/Yellowstone wolf reintroduction).@
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.
!?Whole communities are placed within the suggested management area which includes schools, public buildings and other gathering places. The risk is just too great to allow.@
!?It is unclear in Alternative 1 of the draft EIS what would happen to bears that might migrate outside of the Recovery area and into the larger Nonessential Experimental Population area...Alternative 1 of the EIS does not specify what would happen to bears that might happen to expand from their current range in north Idaho and northwestern Montana southward into the recovery area...@
!?We must maintain bear recovery ecosystems whose boundaries are defined based on habitat necessary to sustain a viable bear population, rather than by a political boardroom act.@
!?...as presently established, (the recovery area) includes at least seven high schools, as well as grade and elementary schools of our valley in Montana.@
!?The best grizzly habitat is found in the north end of the ecosystem, outside the wilderness is unprotected roadless areas in the upper Clearwater and St. Joe drainages and in the isolated back country of the River of No Return Wilderness.@
!?I fully realize that in order to achieve your recovery results, you need acres and real bear habitat in the Selway is not sufficient for the sustained population of bears. In order to meet your requirements, you have added large tracts of a completely different ecosystem in the Frank Church Wilderness and surrounding lands. While this looks good on paper, it is not permissible under the Act. The area selected is not grizzly bear habitat and will effect an ecosystem only marginally adapted to their use. It is not the Act's purpose to displace existing species in favor of non-natives.@
!?Alternative 1...is far too small to ensure that long term survival of a population of grizzlies.@
!?The total recovery zone specified by Alternative 4 will include 21,645 square miles, large enough to sustain a viable population.@
!?The reintroduction of grizzles into Idaho is opposed by our entire Congressional delegation, Governor Batt, the Idaho legislature as well as Idaho Fish and Game.@
!?We feel it's a very good idea to have the Grizzly Bears back in their natural habitat, the Selway-Bitterroot area.@
!?The boundaries of the recovery area need to be large enough to allow the bears their full range. They should not be artificially controlled by the boundaries of the wilderness.@
!?The time frame for determination of probable success or failure should be extended to at least 30 years for a reasonable data base to be acquired.@
!?One hundred plus years is a long time! In my opinion not much of an alternative!@
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'.
!?The Ecology Center supports Alternative Four, with one modification: No bears should be taken from the already threatened populations of the Greater Yellowstone and Glacier/Northern Continental Divide ecosystems for reintroduction into Idaho.@
!?We have not even obtained agreement from the Canadians indicating they are willing to provide us with bears. Given the current mortality limits in the YE and the NCDE, we are not sure we can safely provide these bears locally, without adversely impacting recovery efforts in these areas, and inflicting future set backs in grizzly bear recovery and delisting efforts.@
!?It seems more plausible that the reintroduced population should be coming from already biologically intact and unthreatened populations (e.g. Alaska , Canada) where the translocation of the proposed number of individuals will not endanger the parent source.@
!?...no bears should be taken from any threatened populations including Yellowstone, and Glacier/Northern Continental Divide ecosystems for introduction into Idaho.@
!?I can't imagine a worse idea than taking bears from areas where they are already struggling to maintain healthy populations to move them to an area where they won't receive the protections from the ESA that they will undoubtedly need to survive.@
!?Alternative 4 prohibits taking bears from threatened populations for reintroduction into Idaho. Determination of source bears would be left up to the Scientific Committee.@
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. Below are some of the recurring points people make.
!?We are concerned because grizzly bears in both Yellowstone and the Northern Continental Divide have exceeded recovery levels and should have been delisted no later than when the revised recovery plan was adopted in 1993. Instead...the Service manipulated numbers and the recovery criteria for the sole purpose of not having to begin delisting efforts.@
!?Recovery successes such as delisting of the bear in the Yellowstone ecosystem are needed to foster public acceptance of endangered species recovery, including the Bitterroot grizzly.@
!?The reintroduction plan would have a direct impact on other recovery efforts in Montana and would delay the delisting process for grizzly bears. Substantial opposition to endangered species recovery programs for bears and other species is compounded by the fact that the USFWS keeps moving the goal posts.@
!?On the Targhee restrictions were developed in secret by Federal agencies and their subcommittees...the USFWS required they be included in the Forest Plan Revision under terms and conditions of their biological opinion. The point being the same thing will likely happen to a citizen's committee in central Idaho. (see letter 2636)@
!?...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 NCDE.@
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. Some additional comments are as follows:
!?We feel that specific indicators of recovery progress, developed by the scientific advising committee provided to the Citizen management Committee would be useful in making subsequent management decisions.@
!?...grizzly bears are a relatively long-lived species, yet there does not appear to be any discussion about replacing radio collars on bears so that monitoring could continue...how will biologists and the public know the status of reintroduced bears if batteries in radio collars fail and the animals can not be successfully recaptured for replacement of radio collars?@
!?I am opposed to placing radio collars on any wild animal.@
!?...The Co-management Committee should monitor success and have the flexibility to modify the number of bears reintroduced, if necessary.@
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.
!?The draft EIS is not specific in providing the plan for placing grizzly bears in the Bitterroot Ecosystem. Where, specifically will the bears be collected? Where will the bears be released? How will the bears be transported?@
!?...to capture five or more (bears) each year would not seem feasible as proposed, based upon the results from the work in the Cabinet mountains. The EIS should consider the human and money resources this experience indicates would be necessary in the Bitterroot undertaking.@
!?In our view, animal populations can hardly be considered natural and free roaming when they are, as a matter of protocol, routinely trapped, drugged, and handled by humans.@
!?...there is an Idaho State law that reads that no person shall import into this state or release in the wild any species of wildlife except by a permit issued by the director of the Idaho Department of Fish and Game. To the best of my knowledge this has never been done and will probably not be done.@
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. Representative comments are:
!?Alternative 4 is the one only realistic alternative if the goal is indeed to restore a viable grizzly population....@
!?Alternative 4 sets aside plenty of habitat and restricts activities when necessary to give the bears the best chance for success.@
!?...Alternative 4 is the only proposal to recognize the wisdom of altering land use on public lands for the benefit of biological diversity.@
!?I am in exuberant support of Alternative 4...a habitat-based approach. Grizzlies need full legal protection, as well as linkage corridors for genetic interchange...I say protect the habitat, restore the vital corridors, create passageways under interstate highways in particular, and other heavily travelled highways as well....@
!?We are opposed to the implementation of Alternative 1, the ROOTS alternative, as it provides insufficient protection for reintroduced grizzlies and their habitat.@
!?Alternative 1 removes most of the legal protections which the grizzly needs. It does not protect habitat from human economic use, delegates management of the grizzly to individuals chosen in an arbitrary fashion, isolates the Bitterroot Ecosystem from other ecosystems where the grizzly may live, and restricts grizzly recovery to 25% of the Greater Salmon-Selway-Bitterroot Ecosystem.@
!?...Alternative 1 essentially agrees to allow a significant degradation and destruction of undisturbed wildlife habitat in return for the right to @dump? bears into the ecosystem.@
A large number of people make reference to the Endangered Species Act :
!?It is imperative that the Grizzly be given full legal protection under the Endangered Species Act.@
!?I think all grizzly bears deserve the full legal protection as a threatened species under the Endangered Species Act.@
!?Alternative #4 would maintain full legal protection for grizzly bears as a threatened species under the endangered species act for all grizzlies, whether they are reintroduced or immigrate naturally.@
!?How can unprotected habitat be factored into recovery plans, especially when no formal Section 7 consultation will be required with the preferred alternative? The mission of the US Fish & Wildlife Service is to conserve, protect, and enhance fish and wildlife and their habitats...The preferred alternative does nothing to validate this mission statement.@
!?Full protection under the ESA is crucial to successful reintroduction. Because resource extraction may proceed under Alternative 1 without formal Section 7 consultation, it is inevitable that significant amounts of bear habitat will be compromised.@
!?The roadless forest surrounding the two Wilderness areas are part of this high quality habitat and is necessary for the reestablishment of a long term viable population. In alternative 1 it is stated that 'much of the experimental population area has high-quality bear habitat with low likelihood of conflicts between grizzly bears and humans' and the 'bears found outside the recovery area but within the experimental population area boundaries would be counted as part of the recovery goals', evidencing that even under Alternative 1 the land surrounding the two Wilderness areas is regarded as important to the bears. Nevertheless, Alternative 1 fails to protect this habitat by allowing continuing resource extraction and by revoking protection under section 7a of the ESA.@
Some comments are quite specific as to what grizzly bear needs are:
!?Bear requirements for forage and security are well know. Basic standards must be outlined in the FEIS. Habitat standards should define allowable road densities for the full bear population area.@
!?To ensure grizzly survival, these clear habitat standards and objectives must be incorporated into the grizzly bear recovery plan and other management plans:
* Remaining security habitat, especially roadless areas and public lands in grizzly habitat, should be maintained as roadless.
* On roaded public lands in grizzly bear habitat, road densities should be maintained below one mile per square mile.
* Key food source areas should be protected from human disturbance during bear use and from habitat destruction.
* Isolated island grizzly bear ecosytems in the lower 48 should be reconnected.
* Instead of a bear recovery zone, with boundaries defined by politics, boundaries should be defined based on the habitat necessary to sustain a viable bear population.
Many people refer specifically to roadless and wilderness areas:
!?Alternative 1 does not provide for the protection of grizzly bear habitat, especially in the roadless areas that adjoin the Wilderness. Bears are adversely affected by roads because of a loss of habitat security.@
!?...protecting roadless areas is a simple way to preserve habitat...@
!?The closing and abolishment of the Magruder Road and Hells Half Acre Mountain Road, as well as stopping roadways into roadless areas will ultimately secure a quicker and more solid recovery of the grizzly in the Bitterroot Ecosystem.@
!?The roadless areas need to be protected. It never hurt anyone to walk. Any extraction of resources should be limited to what can be carried out on one's back...@
!?Alternative 4 is the only Alternative that would lead to recovery over the entire 21,000 square mile area. Protection of the roadless lands surrounding the designated wilderness is an important and valuable aspect...@
!?...remaining security habitat, especially roadless areas on public lands in grizzly habitat, should be maintained as roadless.@
(409) A large number of people comment specifically on the effects that roads, logging, and mineral extraction have on grizzly bears:
!?If the planned area is to be logged in the next ten years, the roads will cut off migrating trails used by the bears to get into central Idaho.@
!?No road construction should be allowed in the Inventoried Roadless Areas within the Recovery Area.@
!?...the preferred alternative would rely on Forest Plan management@... Forest Plans include high volume timber harvest and hundreds of miles of new logging roads. These activities are known to have detrimental effects on grizzly bear habitat.?
!?...alternative one allows and in fact, from a political perspective, encourages more road building, industrial logging, and mining, etc. in the roadless areas that surround the designated wilderness. This will lead to increased bear mortality@...
!?Grizzly bears avoid roads by an average distance of one half mile (Boss 1994). This leads to a tremendous reduction in their available habitat.@
!?In the DEIS it is assumed that projected land use in the area surrounding the recovery as road building and logging will not have a significant negative impact on @... successful establishment or population growth rate. However, the best available biology indicates that the largest threat to grizzly bear populations.?
!?Allowing timbering, mining and roadblocking to continue in grizzly bear habitat is a surefire method of guaranteeing that the reintroduction will not succeed.@
!?...the CMC will have to work around scheduled timber harvests in making recommendations to the Forest Service and FWS...This is simply unacceptable if the recovery of grizzly bears is to be taken seriously.@
Very few commenters express that logging and other extractive activities would not affect the grizzly:
!?Logging, per se, is not a permanent disturbance to the grizzlies, being completed in a short time....@
!?The alternative (1) also will eventually demonstrate that many land management activities are compatible with the presence of the grizzly bear and some may indeed enhance habitat.@
!?Because the DEIS fails to evaluate the quality of Grizzly Bear habitat, it therefore does not describe plans for any habitat management activities. Prescribed fire, vegetation manipulation...judicious logging can improve Grizzly Bear habitat. I strongly encourage upgrading the final EIS by discussing the positive management factors that increase populations.@
(412) Many people call for a more aggressive approach to habitat restoration. A very large percentage of people prefer Alternative 4, in part because it will remove 3,500 miles of logging roads:
!?Look for opportunities to rehabilitate damaged habitat to more quickly bring those lands back into shape to improve grizzly habitat/corridors. This may include road removal, vegetation rehabilitation, riparian restoration, etc.@
!?...the biology on the matter of roading effects on grizzly bears is well-established, and we need not wait to institute necessary habitat protections when it comes to roads.@
!?...final EIS should ... suspend all building on USFS roadless lands within the Recovery Area. In areas where there are already excessive road densities, such as the Lolo Restoration Area and the Corridor Special Management area, roads should be closed and reclaimed or restricted in accordance with the best available science.@
!?... enhancement of habitat through acquisitions and easements are all highly critical to the establishment of a sustainable bear population.@
!?Since an indirect relationship has been observed between the amounts of logging roads and critical grizzly bear habitat, Alternative 4 also provides restored habitat for threatened bears by reducing road densities to 0.25 miles per square mile within habitat linkage corridors. Roads are also a key factor in grizzly bear deaths, thus ESA provisions would require consultations by the U.S. Forest Service with the USFWS on future habitat alterations in the recovery area.@
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.
!?This proposal shows USFWS trying to accommodate the many pressures the recovery effort seems to project on the public, it shows balance and concern.@
!?I am especially supportive of the Citizens Management Group because it gives control to local people who are familiar with local problems & local solutions.@
!?This plan would provide for a committee of local citizens to manage the reintroduction and strike a balance between protecting the grizzly bear and maintaining the needs of communities surrounding the recovery area.@
!?Citizen management places confidence in a fundamental democratic principle that people should be involved.@
!?The Citizen management plan is significant because: It validates front-end coalition building as a way of bringing conservationists, industrialists and other @non-traditionalists? together to achieve balanced solutions to wildlife recovery and management issues.@
!?The committee would be made up of governor appointees. Since the governor receives political contributions it is likely that the committee would be made up of people whose main concern is the timber industry, which is very wealthy and influences too many politicians already.@
!?It protects a process that is being heralded as a win-win approach to conservation. I do not trust either Idaho or Montana's Governors to appoint truly conservation minded committee members. As political cycles change so will the committee -- will this bode well for the bear in the long term?@
!?...Alternative 1, with a Citizen Committee, is a scam, a come-along in order to gain a foothold to control people and land. The Interior Secretary never releases control of the CMC and can dissolve the committee at his pleasure. The membership of the CMC is unequal. Idaho has the most land, but Montana has the most people exposed...which indicates Ravalli County with an excess of 30,000 citizens would be enclosed within the management area.@
!?The DEIS requires that CMC members come from @within and adjacent to the recovery and experimental population areas.? Thus, some of the region's most informed biologists and conservationists are automatically and arbitrarily excluded.@
!?IOGA wonders why Idaho would receive only 7 of the 15 slots on the CMA when nearly 80 percent of the 28.4 million acres recovery area lie within Idaho? IOGA recommends that the ratio of makeup on the CMA be changed substantially between Idaho and Montana residents to reflect the affected recovery area. Furthermore, should the preferred alternative be implemented, IOGA recommends that the makeup of the CMA be tilted heavily toward current users of the wilderness areas. We recommend at least two outfitters for the CMA - one water and one land-based.@
!?The CMC is a political expedient. The political makeup of the CMC is assured by allowing the govs of Idaho and Montana to appoint members to this committee, with NO requisites for training, expertise, or knowledge of the grizzly and its biological needs. Also by stating that only people from areas adjacent to the recovery area can sit on the CMC, the majority of the experts in the field of grizzly biology, population genetics, habitat, etc., will be EXCLUDED.@
Comments pertaining to Alternative One:
Numerous respondents who support Alternative One 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.
!?This alternative allows local people and scientific experts to cooperatively decide on how grizzly bears will be restored and managed. Without this alternative, it is doubtful that grizzly reintroduction could proceed. Adoption of this alterative would also provide an exciting opportunity to determine whether such shared management can be successful.@
!?We firmly support the Citizen Management Alternative...People living in the bear introduction area must have a management role....62% of residents support grizzly recovery if the citizen committee is established.@
!?Personally, I support the proposed action...if ESA is to survive as a legal mandate, more active involvement by local citizens and governments will be required.@
!?The plan is timely and cost-effective. Because it includes oversight by a Citizen Management Committee, it is acceptable to local residents. This tested approach to restore a threatened species to an area specifically set aside by our government for the protection of wild lands and wild species has the full cooperation of coalitions from the timber industry.@ [petition 66 - 10,350 signatures]
!?We are also aware of proposals to provide a scientific @arbitration? process in the event that the Secretary of Interior and the Citizen Management Committee programmatically disagree about...grizzly bear management...While by law the Secretary of Interior must retain ultimate decision-making responsibility and could reject the findings, this strikes us as a sound way of resolving disputes and providing appropriate incentives to both the Secretary and the CMC to avoid such confrontations.@
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.
!?The Secretary of Interior cannot delegate his duties or authority to the CMC. In reality it appears that the CMC will only be window-dressing for decisions to be made by the USFWS. Due to the present status of the ESA, no assurance can be made that the CMC will have an effective voice in management of the Grizzly Bear.@
!?With the exception of one appointee from each of the state's Fish and Game Departments, there is no requirement to nominate anyone who is an expert on grizzlies, or anyone who has ever seen a recovery plan...very likely that this committee would be made up of people selected for political reasons and the whole recovery effort put in jeopardy.@
!?Alt. 1 is flawed because it delegates the authority of the USFWS to a citizen's management committee. The endangered species act does not allow delegation of authority. This committee representation is not balanced properly because Montana and Idaho have nearly equal number of members. However, over 90% of the area affected lies in Idaho.@
!?Please provide the legal basis for the proposed (CMC) under the Endangered Species Act, the National Forest Management Act, the Federal Lands Policy Management Act and the Federal Advisory Committee Act.@
!?...the CMC is a bad idea...No requirements for experience managing or even having any knowledge of grizzlies. Selection of members only from communities from within and adjacent to the recovery and experimental population areas (precludes the selection of most of the citizens of the U.S. and most qualified grizzly bear biologists). Likelihood that most CMC members would place the interests of logging, mining, and ranching above promoting recovery of a health population of grizzly bears in the BE.@
!?...the Citizen Management Alternative, is merely a continuation of the theme park mentality, based on politics and 'feel-good committees' rather than biology.@
!?Clearly define role of the Citizen Advisory Group. This role must require all actions by this group meet the intent of the Endangered Species Act to move the grizzly bear toward recovery and off the ESA.@
!?...given the controversial nature of this issue and the probable lack of experience that members of the management committee will have in dealing with this form of conflict resolution, it would seem appropriate to include on the committee a professional negotiator or mediator (one not representing any agency or group and who has no stake in the issue other than helping the committee achieve a consensus decision).@
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.
!?...citizen management committee I fear would be a very political entity. I feat they will be very powerful in affecting management of over 25,000 square miles. I worry their decisions will be weighted toward a single species, the grizzly bear. We need to avoid single species management. What about other species with different needs? Will the committee ignore landscape and ecosystem issues? I'm concerned that a powerful and myopic political committee focused solely on grizzlies will usurp other conservation efforts in the recovery area.@
Comments Pertaining to Alternative Two:
Proponents of Alternative Two suggest grizzly bears should be allowed to recover naturally while being managed by the Citizen Management Committee as outlined in Alternative 1.
!?Alt. 2 offers the opportunity to incorporate the concept of citizen management into natural recovery...a CMC would provide valuable input into Section 7 consultations initiated with regard to activities in the Bitterroot ecosystem or migratory corridors and enhance local support of the grizzly bear.@
Comments Pertaining to Alternative Three: There were no CMC comments on this alternative.
Comments Pertaining to Alternative Four:
Supporters of Alternative Four 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 One. 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 four 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.
!?Alternative 4 implements grizzly bear management by a scientific committee of experts appointed by the National Academy of Sciences and would include scientists from the private sector, the U.S. Fish & Wildlife Service, the Nez Perce Tribe, and the state wildlife management agencies in Idaho and Montana. Alt. 1 provides for a citizen management committee appointed by governors of Idaho and Montana. In Idaho, our governor is seriously biased against grizzlies and would not likely be objective in his appointments. We need to have scientists managing these bears, not local people with little wildlife management experience.@
!?The FS and FWS are by no means perfect, but compared to management by local citizens committee and Governor decree, they represent the end of the rainbow...The CMC proposed ... is an extremely dangerous precedent because it is intended to alienate Americans, on a national scale, from their land and their wildlife: this amounts to a spike in the heart of democracy.@
!?As a wildlife biologist, I am also hesitant about bear management being overseen solely by non-scientists. Having a citizen (or community) representative or two on a scientific committee might be worthwhile in order to reduce the hostile sentiments by those against the re-introduction & to involve those whose communities will be most affected by the reintroduction efforts.@
Other General Comments Pertaining to the CMC:
!?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.@
!?If the Secretary retains the final authority and veto power over the CMC then it will be nothing more than a fixture intended to promote the illusion of @public involvement.?
!?Citizen management sounds like a good thing. Who could be against it? It is certainly preferable to federal management. What gets lost in the attractive catch phrase...is the reality that the Secretary of Interior has not only the absolute authority, but the legal duty to reject those committee recommendations with which he disagrees. That means if the committee decides not to close a trail and the Secretary...thinks they should, they get 6 months to toe the line. If they do not, the Secretary may disband the CMC and resume management implementation himself.@
!?Establish a Citizen Management Committee to bring innovative ideas...Despite the best of intentions, however, failure to bring the affected communities into discussions early in the development of this proposal has resulted in a situation where local residents do not believe they have had any real voice in making decisions that will substantively affect their lives.@
!?Page 2-8 of the DEIS states the...CMC @would be exempt from FACA...before they...would be implementing an approved recovery plan.? The DEIS does not cite any legal authority for this proposition. Only duly appointed recovery teams are exempt from the requirements of the FACA...The potential members of the CMC had nothing to do with the development of the grizzly bear recovery plan. ...CMC management has been presented to the public as an opportunity for @greater flexibility than ever before allowed under the ESA?...it is impossible to both manage with @greater flexibility than ever before allowed? and manage pursuant to an already developed recovery plan...The DEIS is flawed for leading the public to believe that the CMC will have management options available to it that go beyond the contents of the recovery plan, while also asserting an exemption from FACA.@
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.
!?The EIS is deficient in that it does not address in any way the implications of this (removal of bears) on delisting. The State of Montana will vigorously oppose an EIS that does not comprehensively and scientifically address the full range of delisting issues presented by the yearly or cumulative impacts... and will oppose any alternative that would slow delisting in the NCDE and the Yellowstone ecosystem.@
!?We find most objectionable the position of Montana Governor Racicot; that bears so removed from the NCDE or Yellowstone (ecosystem) not be counted against mortality quotas.@
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.
!?...the 10(j) rule, supporting to place management of imported bears in the hands of a citizens committee, does not do so. The reality is that authority would be retained by the Secretary of the Interior...The county questions that the secretary can in fact delegate final authority.@
!?Recovery is about the blatant exercise of federal power, usurpation of state sovereignty.@
!?The secretary of Interior must remain ultimately responsible for all final actions of this experimental program...should not diminish the overall responsibility of the applicable agencies to adequately oversee this process.@
!?Alternative 3 seems to require that state law be in conflict with federal law.@
!?Idaho has the right to self determination under the constitution of the United States. And you have the obligation to respect that right...@
!?Section 4 (d) 8 of the Wilderness Act states that, nothing in this Act shall be construed to affect the jurisdiction and responsibilities of the states with respect to wildlife and fish in the national forest. Section 201 of the Fish and Wildlife Conservation Act of 1960 require concurrence of state agencies and a cooperative agreement prior to implementation of a management plan...the opposition of the elected officials (of Idaho) in a joint resolution enacted in the last session of the Idaho legislature should convey a clear message to the undesirability of introduction of the grizzly bear in Central Idaho.@
!?FES cannot elevate wildlife habitat over other uses of the forest, such as livestock, grazing, outfitting, water storage and timber harvesting. The Multiple Use Sustained Yield Act requires that land use plans be written to harmoniously coordinate the listed uses of the National Forests...The existence of large wilderness areas within the recovery area does not authorize the elevation of wildlife habitat over other uses of the forest such as those listed above...(See Letter 121).@
!?Lemhi County has a civil rights ordinance...It is against the law to introduce anything that endangers the lives of my family and my friends. If the U.S. Fish & Wildlife Service insist on proceeding to finality, we will sue in a class action suit against not only the U.S. Fish and Wildlife Service but every person responsible for the violation of our civil rights. This includes the members of the citizens management committee...This is not a threat, it's just a statement of fact.@
!?I don't think the federal government should have the right to overstep the jurisdiction of the citizens of the State of Idaho. Our governor, Phil Batt, the Idaho State Fish and Game, and the majority of the citizens of Idaho are opposed to the introduction of the grizzly bear to our state.@
!?Montana Fish, Wildlife and Parks has an excellent, proven track record in grizzly bear management...by bestowing the management of the grizzly in the State, the authority and responsibility are placed together with the skill and knowledge to meet the will of the people.@
!?I think you are overlooking equally important treaty rights, authorities and federal trust obligations owed other tribes. See p. 1-11 and 2-8 on the draft...more generally, the draft EIS should describe how activities will be coordinated among federal, state and tribal sovereigns with these additional tribal governments afforded opportunities to participate...@
!?I encourage that the endangered species law be rewritten to take the authority from the US Fish and Wildlife Service to administer programs such as this and the wolf reintroduction unless the states have requested the USFWS be involved. The way this program has been handled is a violation of the 10th Amendment to the Constitution and should be challenged.@
!?The USFWS has not identified the long-term funding source for the plan under any of the alternatives. It has not offered written assurances to Montana and Idaho that the states will not be forced to bear additional costs. An unfunded federal mandate to Montana and Idaho is not acceptable.@
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.
!?I saw what the government of Montana did to the bison last winter, and I want only the federal government to be in charge of the restoration of the grizzly, with input from groups that have the best interest of the bear at heart, such as the @Predator Project.?
!?Recommend the area be served for grizzlies with land management guided under the auspices of ESA protections. This means reducing the logging, road building.@
!?Aside from ethics, it is the USFWS's obligation to protect the existing grizzlies as well as do whatever possible to bring the bear's population numbers back to a stable, healthy, self-sustaining entity.@
!?The Secretary of Interior must remain ultimately responsible for all final actions of this experimental program...should not diminish the overall responsibility of the applicable agencies to adequately oversee this process.@
!?Under Alternative 4 primary grizzly bear management responsibility would reside within USFW and include active participation by federal land management agencies, the states of Idaho and Montana and the Nez Perce Tribe - as it should. The Secretary of Interior would appoint the Scientific Committee in cooperation with the National Academy of Sciences.@
!?I want the U.S. Fish and Wildlife Service to continue responsibility for grizzly bear management.@
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.
Closures and Restrictions:
!?...the DEIS reserves significant power for the CMC to curtail current land use practices...without sufficient discussion of the likely decisions that may occur...the DEIS completely fails to be forthcoming and candid with the public concerning the potential land use restrictions... Since the primary purpose of the DEIS is to disclose these likely impacts, the DEIS is flawed and should be withdrawn.@
!?Are you stating that the USFWS is reversing its long-standing position relative to trail and road use and public access? If so, please provide a positive statement of actual USFWS policy...rather than a vague and misleading statement of 'expectation'.@
!?I strongly feel that this program will result in loss of use of much of the reintroduction area by ordinary citizens...because of the possibility of closures of parts or all of the area if personnel in the program determine the bears are not reproducing fast enough and they are being disturbed by general use of area by the public.@
!?The undersigned citizens are opposed to the introduction of Grizzly Bear into the Bitterroot Selway Wilderness Area because of the threat to life and property, and restrictive use of this area.@ [Petition 41]
!?I feel that by establishing a grizzly population in the Bitterroot-Selway as an endangered species the pro-bear movement will simply use them as a tool toward their ultimate goal of locking down the entire forest area for their exclusive use.@
!?I'm not afraid of the grizzly attacking me while I'm on an excursion in the mountains on a trail, but of not being able to get to the mountains or to that trail my Dad & I once rode when I was young. I want my kids to have the same opportunity I had to hunt & fish in these prestigious mountains and streams. It's just another endangered animal on the list and another reason to shut all this country down.@
!?IOGA wonders what new restrictions would be placed on boating outfitters....does the USFWS plan to deposit government approved bear proof containers in the over 200 campsites associated with these river systems?@
!?We strongly object to closures of roads, hunting restrictions, mining restrictions, logging restrictions and access restrictions that grizzly bears will bring to the state of Idaho.@
!?...the preferred Alternative 1 has the possibility of affecting trail-based recreation, especially off-highway vehicle recreation within the Bitterroot Grizzly Bear Experimental Area.@
!?...Alternative 1 has the possibility of affecting trail-based recreation, especially off-highway vehicle recreation within the Bitterroot Grizzly Bear Experimental Area. On page xvii of the summary, it states @There would be no anticipated impacts to land use activities on public or private land to include timber harvest, mining, and public access/recreational use.? However, our department does see the potential for some impacts to public access/recreational use.@
Timber Supply, Mining, Grazing:
!?Alternative #4 would require extensive habitat protection of the bears which would require large set asides of productive natural forests. To place the well being of the bears ahead of a...human population would be folly.@
!?...the first time a grizzly bear-human confrontation happens, one way or another the humans lose. If nothing else, the Federal Government will close the area to citizens for recreation, hunting, fishing, logging, wood hauling, mining and any other activity in the area.@
!?I think part of this is a plot to tie up all our natural resources.@
Questioning Motives behind Reintroduction:
!?I...view this reintroduction attempt to be another ploy...to close off public lands....When will the issues of land closures, hunting, recreation and natural resource utilization honestly be addressed in relation to this reintroduction proposal?@
!?...with a Citizen Committee, is a scam, a come-along in order to gain a foothold to control people and land.@
!?Public lands managed by the federal government in the state of Idaho are not to be managed solely by directive from Washington D.C. To do so is a violation of the public trust...that public lands will be managed in a manner that enjoys the support and consent of the people.@
!?...the pro-bear movement will simply use [the bears] as a tool toward their ultimate goal of locking down the entire forest area for their exclusive use.@
!?The CMC would be responsible for recommending changes in land-use standards and guidelines as necessary for grizzly bear management. Will the public have any input into these recommendations or changes in management plans? If these plans need to be incorporated into the various Forest Plans for implementation that would provide an avenue for public review. The process should be verified in the final EIS.@
!?...we see this reintroduction as a subtle means to restrict multiple use of our public lands....@
!?To reintroduce grizzly bears to the Bitterroot Mountains is an attempt to make all of the surrounding areas a defacto wilderness....it is my opinion that grizzly bears would be one more reason to close the Lolo Pass and Great Burn areas to snowmobiling.@
!?This alternative gives biologists in the Interior Dept. final say on land management on most public lands and associated private lands without any commensurate responsibilities.@
!?Grizzlies in the BSW Will result in wilderness closures. Packers and all humans WILL be locked ut to keep conflicts minimized.@
!?The granting of easements to private ground...is being protested by bear supporters....No compensation to landowners is being offered.@
!?It is meant to make criminals of as many people as possible as they retaliate by fighting for their personal and land rights.@
!?There goes our right to enjoy our personal freedom and to enjoy our national forests, our rivers, and even our own personal property.@
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.
![Does not favor alternative one because] ?...it allows road building and logging in roadless areas that are needed for bear habitat.@
!?Development of all kinds should be kept minimum in areas bears are likely to frequent.@
!?Certain limitations may be necessary, but creative solutions can be found to allow bears and humans to use the same areas.@
!?...the proposed action...appears unlikely to produce substantial conflicts with our legal mandate. We would anticipate that any minor conflicts that did arise could be resolved satisfactorily.@
!?Ranchers would be forced to share at least a portion of the PUBLIC LANDS which they now consider their own land to do with as they wish. Other resource users would also be required to share. That is a difficult prospect for many people. Selfish habits, such as the ones they've spent decades cultivating, die hard.@
!?Those utilizing public lands for their own self interest have developed a paranoia against the government and thus sound resource management. Their activities, through legal and illegal channels, would no doubt delay and possibly ultimately thwart recovery efforts.@
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.
!?I feel this EIS is treating livestock owners unfairly. Anyone who loses property due to government action should be compensated for that loss...given the recent Supreme Court ruling on unfunded federal mandates and given that the ESA has been mandated by congress, I suspect that one or more livestock associations will contest this plan in Federal Court.@
!?The grizzly bear is your vehicle to steal private property rights under the disguise of the Endangered Species Act, and to establish more government control.@
!?I believe the introduction of grizzly bears into this area of Idaho and Montana against the wishes of the elected officials and residents of this area is nothing less than an act of terrorism, and should be treated as such by law enforcement officials.@
!?The Endangered Species Act is in effect being used to control humans and has major implications on private property rights as well as access to public lands and the natural resources industries.@
!?Since most plant and animal habitat in the US is on private land, the US Fish and Wildlife Service and other agencies administering the ESA must adopt collaborative approaches to improve species recovery.@
!?This proposal is @smoke and mirrors? to camouflage a vast @land grab? which is aimed at excluding loggers, miners, stockmen, road recreationists and many others.@
A few respondents voice their concern with how this effort will affect their access to irrigation dams in the reintroduction area.
!Private property rights will be at risk for 18 irrigation dam associations with reservoirs in the grizzly bear re-introduction areas. Access to these sites will be jeopardized by this program.?
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.
!?...failure of the FWS to dicuss the possible conflicts between the alternatives and the forest plans prevailing in the Experimental Population Area violates CEQ regulations. Instead of developing possible conflicts, the FWS indulged the presumption that the plans are compatible with grizzly recovery...undermining the goal of providing a full and fair discussion of significant environmental impacts...@
!?It is impossible to both change existing forest plans and also avoid altering 'existing land management activities,' since the DEIS does not include sufficient environmental or economic analysis of changing existing forest plans, the DEIS is flawed and should be withdrawn.@
!?Existing Forest Plans are not sufficient for grizzly standards and guidelines. New standards and guidelines, specific to grizzly bears, must be established using specific data for bears.@
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'.
!?This plan (alternative 1) allows for local involvement in the process and allows for local problem-solving of any issues that occur.@
!?The Citizen Management Plan is significant because: It supports the unprecedented approach of placing real authority for wildlife recovery management in the hands of local citizens.@
!?There already is too much local control over public lands issues in the west today without antipredator local politicians controlling the CMC. A committee of scientists should make the key decisions aided by citizen input.@
!?How is it that the powers that be in Washington D.C. can dictate to the Idaho citizens what is to happen in our back door?@
!?I do think it is a national issue. In my line of work, I meet a lot of hunters that come from all over, not just Idaho and Montana. They come from, believe it or not, New York and California, from Connecticut. So it is of the national concern and I encourage you to adopt Alternative four.@
!?No matter how much people in other states may want to see grizzly bears in Idaho, Idahoans should have the right to make that decision...Turn this question around for a minute. This isn't just an Idaho issue...I don't think that I have the right as an Idahoan to insist that California accept introduction of the grizzly to the Central Valley just because I think there is food and habitat to support it there.@
!?This whole process...is Socialism in it's purest form...The U.S. Fish and Wildlife has ignored the State of Idaho and the constitutional legislative process. Our County Commissioners say no. Our Governor and Lt. Governor say no. Our state Legislature says no. Our U.S. congressional delegation says no. Our Fish and Game Department says no.@
!?I also oppose people in Washington D.C. telling the people in Idaho what to do - as well as people in Montana telling us what to do.@
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 four 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.
!?Flathead Audubon strongly supports the return of grizzly bears to the BE. However, we believe the analysis contained in the DEIS is currently insufficient to justify a reintroduction program like those described in Alternatives 1 and 4. We cannot support Alternative 1 because: 1) a mechanism for identifying and infusing the @best available science? is lacking, 2) the @experimental? status as currently defined, interferes with necessary connectivity with natural populations, and 3) the DEIS lacks a scientifically credible assessment of risk to source populations.@
!?(management) should be implemented by oversight management by a Scientific Committee having scientists from the private sector plus some input from U.S. Fish and Wildlife Service, the Nez Perce Tribe and state wildlife management agencies in Idaho and Montana all with some ecological comprehension.@
!?It (alternative 4) is the only ecologically and scientifically justifiable approach to reintroduction of this important animal.@
!?I want wildlife biologists to design management standards not politicians.@
!?Alternative 4 implements management by a Scientific Committee of experts appointed by the National Academy of Sciences and would include scientists from the private, the U.S. Fish and Wildlife Service, the Nez Pierce tribe, and the state wildlife management agencies in Idaho and Montana.@
!?Guesswork and skewed research designed to fit policy espoused by the green groups and their defenders on the federal bench is the driving force behind the reintroduction science...junk science.@
!?Although I support the Citizen Management Committee alternative I also feel there is room for improvement. Science appears to be playing a secondary role to politics. Bear population links or interchanges with existing bears should be strengthened, wildlife biologists should design management standards and the wildlife professionals should also manage bear recovery in cooperation wit state and local residents...I realize grizzly bear restoration is controversial and it is necessary to build a broad base of public support but we also need to include scientific information in any plan.@
!?Will these committees be schooled on recent findings in genetics, population biology and landscape ecology?@
Some respondents suggest compromise or changes to the alternatives as follows:
!?I favor a joint scientific and citizen management committee. This would guarantee all aspects of grizzly bear recovery and management be considered and provide an educational opportunity for strengthening this type of partnership.@
!?We would suggest the formation of an additional Independent Scientific Review Group (ISRG) which would evaluate the decisions and actions of the CMC annually for the first 6 years of the project, and every two years thereafter. This committee should be comprised solely of experts in the fields of grizzly bear ecology and conservation biology who are not otherwise involved in the recovery effort. Appointed by the National Academy of Science, this group would have no management or decision-making authority but would provide recommendations to both the CMC and the Secretary of Interior. The ISRD would provide feedback to the CMC in ... a scientific critique of the actions of the committee and a review of the scientific literature upon which the critique is based. @
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.
!?The actual recovery plan should be further outlined in the FEIS and refined by the Fish and Wildlife Service for later publication and peer review, before it is turned over to a management committee for implementation. The management committee should be responsible for achieving the goals of the recovery plan, not for development of a recovery plan.@
!?See, page 2-15, DEIS, Please provide all analysis or information contained in the Grizzly Bear recovery plan which related to that Plan's goals for Grizzly Bear Linkage zones and management. If the linkage zones in the Grizzly Bear Recovery Plan include the area of the proposed action, how could the reintroduction population under Section 10(j) of the ESA be considered geographically separate from existing grizzly bear populations? Please explain.@
!?This proposal would do exactly what the recovery plan said was harmful to grizzly bears--create another insular population...the recovery plan says that the way to recover grizzly bears is not to create additional small populations of them...We suggest that the Service heed the recovery plan and not spend taxpayer funds on a project that is not even supported by the grizzly bear recovery plan.@
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'.
!?...the griz belongs in central Idaho, as it does in several other ecosystems across the West. It is an integral part of the ecosystem, and is part of our wildlife heritage.@
!?To call these bears a 'nonessential population' is tragic. They are an essential part of the ecosystem and their reintroduction is way over due.@
!?There are those that say the wilderness is not 'complete' without grizzly bears but that is a philosophical point of view, an opinion no more reasonable than our opinion that grizzly bears are not needed and actually make the area less desirable.@
!?They can't be reintroduced since there is insufficient record of there ever being a residential population.@
!?This was not grizzly habitat in prehistoric times. The grizzly was a plains animal.@
!?I hate to disillusion people, we don't have black bears in our back yard. These bears and the lions and the tigers and everything else, have people in their front yards.@
!?The members of the Ecological Science League at Capital High School in Boise Idaho do hereby write our support for alternative 1 of the Grizzly Bear Recovery Project in the Bitterroot Ecosystem. We believe that the grizzly bears have a rightful place in the Bitterroot Ecosystem, and that they, with man's help, should be restored there...@
!?...something is missing if the full component of species, including grizzly bears are not present in a wilderness environment.@
!?Returning grizzlies to the country they once occupied will restore the ecological balance to the largest piece of roadless land in the lower forty-eight states.@
!?The presence of grizzly bears in the Salmon-Selway will enhance the biodiversity and restore the wild heart of this wildland, along with providing a vital link for existing grizzly populations.@
!?Grizzly bears along with other large predators, namely wolves, cougar and black bears are an integral part of a complete and healthy forest ecosystem.@
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.
!?There exists reliable evidence that a small population of grizzlies exist in the Salmon-Selway. This invalidates any attempt to institute the non-essential, experimental population status...Kunkel and Servheen 'cautioned that their efforts did not confirm the absence of bears in the BE because of the small area surveyed and low camera density(1/110 sq. mi.) used (3-15). The Melquist analysis (1985) of 88 reports of grizzlies in the Salmon-Selway found that 14 (16%) were 'Probable' and 37 (42%) 'highly possible'. The USF&WS cannot continue to ignore these results and maintain its credibility.@
!?There is no suitable habitat for grizzly in that area and from what we have heard have never been grizzly bears in that area.@
!?I believe they already exist in the wilderness and if man does not overact - the bear will naturally recover.@
!?This proposed 'reintroduction' is in no way vital to survival of the species and it is questionable whether much of the proposed recovery area was ever grizzly habitat to begin with.@
!?I'm against reintroducing grizzly bears in the Bitterroot-Selway because they are already there. I called a sow and two cubs into me four years ago when I was elk hunting@
!?If this part of Idaho were native to and conducive to the propagation of these animals, they would already be there.@
!?Certain reports of grizzlies already there have been repeatedly denied, in order to maintain existing land management practices...any bears put into the area will augment the existing grizzlies in the Bitterroots, and if considered augmentation, will allow the added protection that the ESA allows.@
!?I do not want the Grizzly Bear introduced in Idaho. This was not a historic Grizzly area, as California was. When Lewis and Clark came through central Idaho they did not find very much game, and no mention of Grizzly Bears was made in their journals in this area.@
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.
!?...(the) recovery population goal should be refined and solidified from the current statement that establishes 'a tentative recovery goal of approximately 280 grizzly bears...' While we understand this effort is an 'experiment' there is no basis to believe that an isolated population of 280 is legitimate size to be considered 'recovered'...@
!?...alternative 1 call for a recovery goal of 280 grizzly bears...recent work by conservation biologists would suggest that 500 grizzlies is more likely to approximate a minimum viable population.@
!?Research by Allendorf, et. al. shows that a minimum viable population of grizzly bears is between 1,670 - 2,000 bears. The land area required to support this number of bears, based on even the most conservative approach...shows that over 15 million acres of undisturbed habitat is required.@
!?There is nothing in the DEIS that establishes that reintroduction of Grizzly Bears into the Bitter root ecosystem is essential for the maintenance of a healthy, viable Grizzly Bear population.@
!?It has not been determined what a viable population is so how do we know whether reintroduction is necessary or practical?@
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 four supporters favor corridor management. Only a handful of comments were against establishing linkage zones.
!?Alternative 4 provides wildlife corridors so essential for genetic interchange, which maintains the health of the population.@
!?We find Alternative 4 also valuable because it links the GSSB and the Cabinet Mountains with a habitat linkage corridor to help foster natural grizzly bear movements and genetic interchange.@
!?Alternative 1 isolates the GSSB from other ecosystems by deliberately failing to provide linkage corridors. Its legal and political strategy includes artificially isolating the GSSB population from others in order to maintain the 'experimental non-essential' status.@
!?...for grizzly bears to survive in the lower 48 states, each additional population with potential linkage to other populations increase the probability for survival (1-5). Alternative 1 provides for NO linkage corridors, and in fact precludes them by designating the Bitterroot population as experimental, non-essential, a population which by definition must be geographically isolated from all other populations.@
!?...protecting vital biological corridors is the key, not just to a long-term viable population of grizzlies, but it's the key to our way of life.@
!?I support a grizzly bear plan that develops migration corridors between Idaho's grizzly habitat and other populations to ensure genetic health and diversity of all Northern Rockies populations.@
!?Further, if grizzly bears are to survive, they need protection of roadless areas and they must be connected with other grizzly bear populations with corridors.@
!?This association (Idaho Cattle Assn.) views with concern the repeated reference to linkage zone analysis and management contained in this DEIS. It appears that this portion of the plan is not to be subject to the public comment process.@
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.
!?Bears need fall and spring range that would include foothills and private land. With only two months of summer in the wilderness, there is not forage for them to survive.@
!?...the area is not a suitable habitat for them. If the habitat is not suitable transplanted bears will be down on the valley floor looking for easy food: calves, sheep etc. As small ranchers we're definitely against working that hard to feed bears!@
!?When grizzlies did inhabit this area, where did they find food in early spring? Surely it was the lower elevation valleys, including the Bitterroot Valley. They will still find good spring range in the populated valleys...There will likely be conflicts between ranchers and bears, and both will lose. I would have a great concern for our horses, foals, and mules.@
!?The recovery zone and recovery goals under alternative 1 are too small. Research (Mattson) has shown that a viable grizzly population in this part of the world needs at least 20,000 square kilometers. The recovery zone under alternative 1 is slightly less than 15,000 square kilometers.@
!?The recovery area of alternative 4 is approximately 4 times the size of the recovery area in alternative 1. Alternative 4 will result in more freedom of home range selection for individuals, a larger food base when food becomes scarce, less immediate density-dependent influences that will slow growth, and fewer human/bear interactions leading to bear fatalities.@
!?...recovery area should be expanded to include essential grizzly bear habitat...one quarter of the Selway-Bitterroot ecosystem...alone will not supply enough food and space for grizzlies to survive.@
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 one which 'isolates' the BE while they support alternative four 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.
!?The USF&WS contradicts itself in arguing for an experimental, nonessential population designation contending that the recovery effort would increase genetic diversity and potentially increase genetic interchange among populations 'if bears immigrate or emigrate ... By definition the experimental, non-essential designation can only be for an ISOLATED population. Thus, in order to achieve the genetic interchange which USF&WS apparently supports, these bears MUST retain their full protected status under the ESA...@
!?This alternative (1) will not provide the corridors between the Selway/Bitterroot ecosystem and other nearby areas the bears use. This limits long-term recovery effectiveness and may yield inbreeding and genetic problems.@
!?The proposed action...fails to assess the impact of reintroduction efforts on the bears themselves, particularly relative to habitat suitability including sufficient food resources to ensure survival of a reintroduced population, and therefore may jeopardize grizzly bears and grizzly bear recovery efforts.@
!?It is terribly important to establish a new population with a diverse gene pool created from all of the existing populations possible. The very existence of grizzly bear in the lower United States may be depended on this diverse gene pool.@
!?Reintroducing grizzlies to this wilderness will provide good opportunities for genetic interchange between different groups of the bears, thus improving recovery efforts.@
!?...the Yellowstone populations and the Northern Continental Divide Populations need to intermix with other bears of their genetics are going to get inbred and eventually extinct. It is absolutely essential that the entire ecosystem with biological connecting corridors be implemented.@
!?...alternative four's recovery area is four times as large as the recovery area in alternative one...offers grizzlies a greater variety of feeding habitat and home ranges thereby limiting conflicts between bears.@
!?We (Montana Wildlife Federation) believe that there is an adequate base of wild habitat to support a grizzly bear population, and that existing management guidelines are a good place to start our grizzly management efforts.@
!?(alternative 4 is) too land greedy, includes large areas with inadequate or questionable habitat. Imposes ESA restrictions over 16,000 sq. miles of national forests with questionable and nonexistent Grizzly habitat.@
!?Unfortunately much of the Frank Church, Gospel Hump, and Sawtooth areas of Idaho are used far too much to have bears or even to allow them a decent enough food source. Your availability and 'actual grizzly bear habitat' is well below your projection. Identify the prey base most removed from human use and that should be your habitat.@
!?The selection of certain areas over others just because they are currently vacant of the bear ignores the long term real nutritional needs of the bear. The Idaho Fish and Game Commission finds that no biological evidence is presented in the plan to establish the habitat as adequate.@
!?White Pine Blister Rust has sharply reduced the numbers of Whitebark pine and the Salmon and Steelhead that used to spawn in the Selway and its tributaries are no longer present. If grizzlies are reintroduced, we will introduce them into a much altered environment.@
!?...there is an argument that salmon are necessary or were necessary for the bear...there is plenty of bears from the Yellowstone clear through the Bob Marshall into Glacier and on up through the Northwest Territories that exist very nicely in the absence of the anadromous fish. The evidence on this is that in the absence of animal protein, you simply have a smaller bear.@
!?...one could easily predict that food-plant productivity is low due to two points not mentioned in the DEIS. First, advancing natural succession has caused forest vegetation to crowd out much of the understory shrubs. The DEIS should acknowledge the enormous changes that have occurred... following the great fire of 1910, and other fires in 1919 and 1931...Secondly, the dense ungulate population very likely has been equally or even more significant that succession in reducing grizzly bear food plant productivity...by eating important shrubs. Further, the DEIS ignores the widespread invasion by noxious weeds...These plants have seriously reduced the quality of habitat...The EIS could mention the potential value of weed management strategies by the U.S. Forest Service ... the DEIS acknowledges that anadromous fish are not expected to provide significant sources of food... but softens the significance by suggesting that interior population of grizzlies occur... where anadromous fish are not important food sources...@
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.
!?How can unprotected habitat be factored into recovery plans, especially when no formal Section 7 consultation will be required with the preferred alternative? 'The mission of the US Fish and Wildlife Service is to conserve, protect, and enhance fish and wildlife and their habitats.' The preferred alternative does nothing to validate this mission statement.@
!?Under the Section 10(j) scenario the USFWS will continue with any small and medium scale extractive projects...the cumulative habitat destruction which we anticipate will delay or even preclude bear recovery in the Bitterroot ecosystem.@
!?The roadless forest surrounding the two Wilderness areas are part of this high quality habitat and is necessary for the reestablishment of a long term viable population. In Alternative 1 it is stated that much of the experimental population area has high-quality bear habitat with low likelihood of conflicts between grizzly bears and humans' and the 'bears found outside the recovery area but within the experimental population area boundaries would be counted as part of the recovery goals', evidencing that even under Alternative 1 the land surrounding the two Wilderness areas is regarded as important to the bears. Nevertheless, Alternative 1 fails to protect this habitat by allowing continuing resource extraction and by revoking protection under section 7a of the ESA.@
!?Alternative 1 fails to consider critical habitat and simply introduces grizzlies to a habitat that will not sustain them. It also allows for the continued degradation of the ecosystem by continued logging and roadbuilding in roadless areas.@
!?Alternative 4 adequately addresses habitat needs by restoring grizzly habitat (by ripping out logging roads and limiting road densities), protecting the land from further commercial extraction, and encompassing the entire Salmon-Selway-Bitterroot Ecosystem to provide the maximum amount of habitat possible.@
!?The final EIS should address the biological needs of the bear for landscape integrity, that is, in protecting the full scope of existing habitat for bear recovery.@
!?The roadless areas need to be protected. It never hurt anyone to walk. Any extraction of resources should be limited to what can be carried out on back, just as my grandpappy did sluice with the family at the middle fork of the Salmon.@
!?Alternative 1 explicitly allows for the continuance of road building, timber harvest, mining, etc. in the National Forest surrounding the recovery zone will lead to more bear/human interactions and therefore more bear mortalities than if the roadless areas remained so.@
!?...(alternative 1) fails to protect essential grizzly bear habitat by allowing roadbuilding and logging in roadless areas. Alternative 1 essentially agrees to allow a significant degradation and destruction of undisturbed wildlife habitat in return for the right to 'dump' bears into the ecosystem.@
!?Alternative 4 protects the bears' habitat by prohibiting logging and road building in the national forest land in the recovery area.@
!?Roadless areas need to be protected form road building, and road densities need to be limited in key grizzly bear habitat.@
!?Since an indirect relationship has been observed between the amounts of logging roads and critical grizzly bear habitat, Alternative 4 also provides restored habitat for threatened bears by reducing road densities to 0.25 miles per square mile within habitat linkage corridors. Roads are also a key factor in grizzly bear deaths, thus ESA provisions would require consultation by the U.S. Forest Service with the USFWS on future habitat alterations in the recovery area.@
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. Comments related to this issue are very similar to those included in issues 408 (Habitat Security) and 409 (Effects to Grizzlies). The reader is directed to those sections for additional summary of associated comments.
!?Habitat protection is an essential feature to any species' recovery-especially so for grizzlies--so Alternative 1's failure to protect enough grizzly habitat from roadbuilding and logging eliminates the species' chance for survival.@
!?Such closures would also benefit big game and fisheries. Protecting an entire ecosystem, not just a certain species, will help the wild species thrive. It is the only alternative that address sustainability in the region.@
!?...alternative 4 encompasses the entire Greater Salmon-Selway-Bitterroot (GSSB) Ecosystem and includes consideration of the habitat needs of all imperiled species in the ecosystem...recovery of the lynx and wolverine would benefit from adopting Alternative 4...protects roadless grizzly habitat by prohibiting logging and roadbuilding within roadless areas on National Forest lands.@
!?I feel Alternative 4 is preferable, since it provides ESA protection for the grizzly bear, and encompasses an entire ecosystem, and prohibits logging and roadbuilding within roadless areas.@
!?...not only is the U.S. population growing, but at the same time the national supply of wild lands is disappearing. This is one of the strongest arguments of why it is in the region's economic interest to preserve these wild lands in the most pristine condition as possible.@
!?Protecting grizzly bears also means protecting an entire ecosystem...The destruction of central Idaho by logging will destroy valuable social resources and disrupt the ecological balance of the entire region.@
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.
!?The alternative also will eventually demonstrate that many land management activities are compatible with the presence of the grizzly bear and some may indeed enhance habitat.@
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.
!?Grizzlies are in the Scapegoat, Bob Marshall, Great Bear, Glacier, and Yellowstone Park and in those areas it is not the end of the world for people and their pets and livestock. So why not reintroduce grizzlies in that relatively vast area of the Salmon-Selway-Bitterroot Ecosystem.@
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.
!?Others argue that if grizzlies are reintroduced, practices to protect their habitat will prohibit grazing, mining, timber harvest or recreational use. Certain limitations may be necessary, but creative solutions can be found to allow bears and humans to use the same areas.@
!?Salish and Kootenai people. We coexisted there with the grizzly bear just as we do today on the Flathead Indian Reservation. While compromises in human activities are often necessary to do so, our experience has shown that these compromises do not provide insurmountable obstacles. Our management of grizzly bears and the important features of their habitat have not precluded timber harvest, forest access, recreation, subsistence activities or agricultural pursuits. It is quite clear that these activities can occur in conjunction with proper management, a reasonable degree of knowledge and an understanding of the characteristics and requirements of the bear. @
Comments Opposed to Reintroduction:
Comments indicate a concern that grizzly bear reintroduction to the BE would cause numerous negative impacts to the livelihoods and lifestyles 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.
!?I say no to introduction into Idaho, Montana, and Wyoming. This would damage or kill the tourist industry, mining and many outdoor activities connected to Idaho's welfare and income.@
!?Experience tells us grazing allotments will be closed; roads cross-country access will be closed to the public; the suitable timber base will shrink; access across forest land to reach private land will be denied...all in the name of protecting the bear!@
!?As a growing country we cannot afford to tie-up valuable timber, mining, grazing and recreation resources for the sake of a species that is not endangered.@
!?Grizzly bears will seriously impact the current lifestyles of all of us that live and play in Central Idaho. This will include the Hunters, Miners, Wildlife, Backpackers, Ranchers, Floaters, Loggers, Tourists, Outfitters, Landowners, Woodcutters, Hikers, and Fishermen.@
!?When will the issues of land closure, hunting, recreation, and natural resources utilization honestly be addressed in relation to this reintroduction proposal?@
!?There is no assurance the transplanted grizzly would not disrupt future land management options.@
!?Because of lack of habitat we see the possibility of bears moving down into the valley for food. This will result in human-bear confrontation.@
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.
!?...I support the Preferred Alternative 1 with some reservations. However, there are many people in Lemhi County that do not feel this way because they fear the unknown--namely what will happen if a grizzly bear wanders outside of the recovery area into the surrounding experimental population area, such as a ranch in the Salmon River Valley.@
!?...the risk of grizzly attacks would be minuscule in an area with plenty of prey, a low density of bears and humans, and an enormous amount of room in which bears can get away from people.@
!?If this issue was about salmon or bull trout, it would not be as an emotional an issue. Grizzly bear are definitely a threat to man. What better place to put them than in the wilderness ecosystem.@
!?I...feel a thousand times more likely to be injured while driving the highways than from a grizzly bear.@
Those opposed to Alternative 1 feel the alternative does not permit enough protection for humans that recreate or work in the recovery area.
!?Alternative 1...has the potential of causing physical harm or death to anyone in or close to the project area.@
!?I have stated before and will continue to state the plan to reintroduce grizzlies, which is opposed by our entire Congressional delegation, Governor Batt, the Idaho legislature as well as the Idaho Fish and Game, will put many Idahoans into life threatening situations while draining millions of taxpayer dollars from the treasury.@
!?I believe this alternative would be a disaster for recovery of Steelhead, Salmon, etc. It would endanger lives of humans, ranchers, loggers, ...@
!?The safety issue is of great concern to the Guides, Outfitters, & Rafters in the Frank Church & should not be taken lightly, Grizzly Bears Eat People!@
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.
!?Allowing for natural recovery best responds to public concerns regarding the potential for an accelerated increase in the grizzly bear population to result in a higher incidence of human/grizzly encounters on both public and private lands than would normally occur. Local residents are frightened about the safety of their families and their property and believe an active reintroduction program would force them to make significant changes in their way of life. A more gradual, natural recovery process would be less disruptive to local communities while still allowing the possibility for bears to repopulate the area.@
!?...not fond of grizzly bears and don't want to see one. If they must be in Idaho I favor the plan that would let them move back gradually on their own.@
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.
!?Do not bring bears into peoples back yard, Idaho is for humans.@
!?We have 3 married children with 6 grandchildren who work in the mountains. I don't want them to run into grizzly bears.@
!?My back door opens up to the boundaries of the Frank Church River of No Return Wilderness. I will be at risk every time I walk out the door.@
!?...if one life is lost the cost is too high...@
!?People have a right to be concerned wherever large wild beasts are introduced into a settled society's environment. Alternative 3 is the only one for me. Prevent grizzly recovery in the area and change the laws to allow it. @
!?This is the optimal alternative. As I stated before it has taken humankind 194 years to rid this area of this detestable animal.@
!?There is also the danger of maintaining our reservoirs with an increased grizzly bear population (Bitterroot Valley Water Cooperative).@
!?One of the reasons I drive 200 miles to visit this forest is because I don't have to worry about dealing with grizzly bears. If our grizzly bears were living in the wild, natural state they would stay away from people. However, you have @managed? them into having no fear and we must pay for this when we use the forest.@
!?...people keep building into the mountains. It just isn't fair to the grizzly bear or the people to live as neighbors.@
!?I'm requesting that it be mandatory that you address the number of estimated injuries and deaths to humans and explain to the public why you feel your numbers should be accepted.@
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.
!?...four hundred grizzlies in Alternative 4, over 22,000 square miles...the chance of anyone running into a grizzly and getting in trouble is really remote, and the opportunity to provide--to restore the habitat, to restore the bear to its historic habitat is a tremendous opportunity and a privilege for all of us to have.@
!?They will just have to be aware that grizzlies are in the area and be safe. @
!?As for the issue of human safety, isn't the appeal of wilderness due, in part, to its inherent dangers?@
!?With the increased number of bears, the number of attacks may go up slightly, but only if man does not use wise judgement and care to co-exist with these incredible animals.@
!?...public concerns about the danger to humans...clearly this hysteria is not founded on factual information.@
Those opposed to Alternative 4 question some of the analyses of impacts to human safety.
!?...this alternative ignores the human element and how it affects bear populations.@
!?...environmental effects analyzed by the DEIS indicate that threats to human safety would be equal to those projected under the Proposed Alternative, despite the fact that the recovered population under Alternative 4 is 30% greater than that under the Proposed Alternative.@
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.
!?It's true that the presence of grizzlies in the Bitterroots would add an element of risk to outdoor adventures--but it's important to realize just how minute a risk that would be.@
!?Those of us who worked with grizzlies as I did in the Bob Marshall know that we can get along with them. As has been pointed out repeatedly, 99 percent of the time they seek to get away from us.@
!?But hikers and campers can go elsewhere to go for a walk or to go camping if they want to. Montana means mountains, there are many mountains for people to go explore.@
!?I've heard people express so many kinds of phobias, so many kinds of fears, that are very abnormal, very irrational. There's no basis.@
!?I've heard tonight that there's every likelihood that bears are going to eat people. And I think that might be overplayed just a little bit.@
!?Page 10 states that people could kill grizzly bears in self defense or in the defense of others. There is no mention of what constitutes self defense. What kind of evidence would be required to prove self defense?@
!?Grizzlies are not be be feared. I regret very much that somehow we have a state of hysteria in the valley about bears.@
!?...I can honestly say that the most fearsome and vicious predator I have ever met is man. And I am far more afraid of being raped and beaten or mugged or shot on the freeway because I got in somebody's way than being attacked by a grizzly bear.@
!?I feel much more at risk on the highway than I do camping in grizzly country.@
!?Over ten thousand Americans are killed annually by firearms, a third of a million Americans are killed annually by tobacco. Are any of the big bad bear opponents calling to eliminate these much greater dangers.@
!?...the safety concerns are over stated. Yes, there will be attacks occasionally; but most people who are in the wilderness are aware that that's a possibility. You make that choice when you go out there...you are going to have more safety concerns when you drive home tonight than you will when you go into the wilderness.@
!?I am a resident of Idaho and spend considerable time in the Bob Marshall of Montana (guiding) and some time in southeast Alaska...My first visits to these areas I was afraid of the presence of grizzly bears and did not know what to expect. Since that time I have discovered that living with and around grizzlies is not life threatening or terrifying. Living amongst grizzlies enhances my life.@
!?I have spent the last 20 years hiking and living in areas where grizzly bears have been free to roam wherever they wish (Alaska, Yukon, British Columbia, NW Montana), and never have I had trouble after numerous encounters with the bears. Indeed, I have always found them to be quite polite and fearful of humans. After reading numerous letters to the...Lewiston Tribune it seems obvious that the overwhelming majority of people who oppose grizzly bear reintroduction...do so out of fear which stems from horror stories they've heard third and fourth hand. Few, if any of them, have ever seen a grizzly bear.@
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.
!?Grizzly bears attack people, and unlike the FWS, I do not believe these is an acceptable level of injury and death caused by grizzly bears. Bringing grizzly bears to the Bitterroot will cause damage to the economy of the area, injury or harm to persons using public and private land and damage the lives of every person living or visiting this area...Please reconsider your decision on an animal no one would want to face in a camping area, hunting or fishing.@
!?I also strongly feel there would be too many bear and human conflicts...Potential loss of human life is not worth the price of reestablishing a population of bears.@
!?I also am the coroner, so I know I'm going to investigate a coroner call or two. It doesn't thrill me to death to have to go there on some grizzly bear-related death.@
!?Having an environment (which we are a part of) for humans to hike, fish, camp, without fear of confrontation is very important.@
!?This animal is not a pussy cat, but a very dangerous, foul breathed, foul smelling, and finally foul tempered bear. I respect it intensely and prefer to keep my distance from it at all times...This is an adversary unmatched in this part of our world. It is an absolute monarch in his domain with extraordinary capabilities of speed, power, strength, and viciousness. As a human facing such a muscle-mass, you haven't got a prayer.@
!?The purpose of this petition is to display (to the receiver) our opposition to said Introduction, and further to request that (the receiver) honor and respect our wishes on this subject, and pray that we don't become prey of the Grizzly Bear or the U.S. Fish & Wildlife Service's plans.@ [85 signatures]
!?To introduce the grizzly bear would be like having a bunch of rattlesnakes in our kids' playgrounds.@
!?I believe that if they introduce grizzly bears here, within five years there will be at least one person killed...these people that are arrogant and egotistical enough to feel they know more about what we should have than we do, are they prepared to take the responsibility for that?@
!?We enjoy the outdoors and this will seriously affect our daily life. Enjoying our fruit orchard, stopping outside to gather firewood, getting the mail, any normal activity, we will have to check for bears.@
!?People live in this part of the world because we enjoy working and playing in the out of doors. We are opposed to sharing this space with an unpredictable and dangerous predator who will endanger our lives.@
!?I'm a member of the Sierra Club and I'm against any introduction of grizzly bears into the Selway-Bitterroot Wilderness or in any part of the State of Idaho...The reason settlers eliminated the grizzly bear from this part of the world is because this bear doesn't have any aversion to humans and would kill for no apparent reason and this is true today. They are unstable and unpredictable.@
!?Hungry bears will seriously deplete the local game populations of deer and elk, taking away the livelihood of area outfitters, and then migrate down the eastern slope of the SBW into populated areas of Ravalli County, where they will pose a threat to the lives of men, women, and children, as well as to private property and all domestic livestock.@
!?One of the reasons I choose to camp there is because I don't have to worry about being killed by a grizzly bear. @
!?If the data in the @Yellowstone Science? article on bear-inflicted injuries are correct, the odds of an attack are low, but tell that to the people who have to live with the injuries...if they live...Because of the very great danger that Idahoans would face if we allow the introduction of grizzly bears into the State, I cannot support any plan unless it is supported by the people of the State.@
!?...the increasing population of the Bitterroot Valley and surrounding areas brings even more family residences and recreation seekers, thus a bear/human confrontation is inevitable. The bear/human confrontations will shut down many areas to the public, thus causing increased regulations upon man.@
!?The absence of grizzlies makes the Bitterroot Ecosystem one of the last places in the lower 48 that humans can go to experience genuine wilderness without the known presence of dangerous and awesome predators of the grizzlies' reputation.@
!?I fear if grizzlies are introduced into the area because of the danger of them, field trips into the wilderness would have to be cut from many school's curriculum because of safety reasons to protect our children...To cut the kids from the most beautiful time of the year in this wilderness is wrong.@
!?Two problems with the Bitterroot's are that most of the canyons are long and narrow and the trails follow up the canyons. In addition, there is a lot of brush in areas, so I would guess that the bears would use the trails a lot for travel, leading to more chance of human contact. The bears are going to use these canyons to get to the Bitterroot Valley, because that is the only way to get there.@
!?Morally and scientifically I believe that the Grizzly Bear belongs in the Bitterroot Ecosystem and I support reintroduction. However, on a personal basis I am against reintroduction because of my fear of the animal.@
!?...you calculate estimates of injuries and grizzly bear-induced human mortalities. It appears you based the figures on estimates of visitors using the BE. Apparently, you did not consider the number of @visitors? that live within the @experimental population area? here in the Bitterroot Valley on the west side of Highway 93. We @visit? this area 24 hours a day,...all year round...thousands of us. Please factor these people into your estimates, if you did not the first time...and disclose this in the FEIS.@
!?...Grizzly bears crossing the divide of the Bitterroot Mountains will find numerous canyons representing the gateway into the Bitterroot Valley...these canyons are the site for trails leading into the Wilderness area, ...and are heavily used by day hikers, rock climbers, picnickers, fishermen and irrigators servicing their water storages...One lonesome grizzly could create a disaster...as there is no easy retreat for the bear or humans and their stock.@
!?What good is a magnificent wilderness area such as the Bitterroot-Selway if only the people who want a big adrenaline thrill use it? It should be a place where all people, young and old alike, can feel reasonably safe.@
!?We do not want our lives in danger by grizzly bears...If grizzlies are allowed in our area and a member of our family is attacked by one, the USFWS better have a good lawyer, as they will need one.@
!?Grizzlies kill people in Yellowstone, Grizzlies kill people in Glacier, Grizzlies kill people in Canada, and by God, I know Grizzlies kill people in Alaska. What in the hell are you thinking of?@
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.
!?Low probability of conflict with industry. The vast majority of the BE is designated wilderness - there are no public grazing allotments north of the Salmon River.@
!?Also, this alternative resolves conflicts between grizzlies and livestock `in favor of the livestock' on public lands. Protecting cattle or sheep should be secondary to protecting the grizzly.@
!?As farmers and ranchers we see economic risks to our animals and to our livelihood.@
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.
!?If the grizzly is introduced they will deplete the wild game and spread to the areas where there are cattle, sheep, and people.@
!?I don't want to worry that our livelihood (cows and horses) are being killed by the grizzly in our field surrounding our house.@
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 lifestyle 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).
!?Livestock losses have also been underestimated in the plan.@
!?Most of my neighbors are cattle ranchers. Introduction of the bears will seriously threaten their livelihood. They may lose calves to the bears and their grazing rights will be curtailed because of the bears.@
!?Even if a bear cannot catch livestock to kill it, their presence insights fear. Most animals flee from danger by running. Example: If a herd of horses are run through a fence, great injury results. Some horses may die, some may not. There is tremendous stress trying to save your livelihood by trying to doctor and salvage 10-20 or more horses at once. @
!?...on this ranch alone, grizzlies have killed cattle every year. Most years, confirmed losses by grizzlies average 25 to 35 head. This is unacceptable! @
!?I am against any plan to reintroduce the grizzly bear in the United States. It took us 150 years to get rid of a very dangerous animal and make it safe for citizens ....to graze their cattle and sheep without fear of this bear.@
!?You know, that's my backyard and I don't want grizzlies there and I don't want them bothering my livestock and I don't want them bothering other people around here.@
Other comments question the analysis and the data used 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.
!?...formula used by FWS to calculate livestock depredation from grizzlies is unsatisfactory (4-46)...it was developed by wolf biologists, but being applied to grizzlies which are not nearly as mobile as wolves...the equation does not take into account the relative size of the various ecosystems being used to estimate predation rates.@
!?All references to livestock losses should be @documented livestock losses.? There is no way to know the total livestock losses to bears.@
!?Draft EIS stated that grizzly bears haven't killed any sheep in the GYE. They used the reporting period `94 to `95...However, in `96 grizzly bears killed 46 sheep...This year they have lost 106 sheep.@
!?The DEIS based its estimate of probable grizzly predation in the Selway-Bitterroot Ecosystem on predation occurring in other ecosystems....The selection of 1984 as the beginning year for determining predation rates overlooks substantial carnage in the NCDE in 1982... @
!?The EIS/Special Rule did not evaluate the impact of the reintroduction on existing grazing allotments. At a minimum, it should state that all existing grazing allotments within the Experimental Area will be managed similar to Situation 2 habitat, per the IGBC guidelines. The CMC should be directed to adapt this classification to minimize adverse impacts to 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.
!?We consider the loss of 2 sheep minimal and within reasonable expectations when balanced against the myriad of benefits of living and ranching in one of the most beautiful, unspoiled areas remaining in the country.@
!?If there are conflicts between bears and livestock, the livestock should be shot or moved.@
!I am not concerned with the potential for depredations on livestock because this is a use of public land that could be eliminated if necessary to accommodate wildlife. It is a money losing proposition for the government agencies in most cases, and the livestock is not needed to provide food for the nation.
!?One factor that the FWS should consider is that domestic sheep and cattle are not native to the area (BE) in question and should be considered @nonessential...?
Other commenters think that the grizzly bears and the livestock industry can coexist, and offer examples where this has been successful.
!?Cattle ranches on Kodiak Island have operated profitably for decades with grizzly bears.@
!?There is plenty of room for both the cattle industry and bear population.@
!?And every rancher was fearful that his livestock would be shot and killed by some stupid hunter from California or New Jersey than attacked by a bear.@
!?...grizzlies, being mostly vegetarians and fish eaters will only attack livestock if desperate.@
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.
!?When grizzlies did inhabit this area, where did they find food in early spring? They will still find good spring range in the populated valleys, such as white tail deer, domestic sheep, calves, and foals. There will likely be conflicts between ranchers and bears, and both will lose.@
!?There is not a food source in the wilderness to support them. They will follow the deer and elk closer to the Bitterroot Valley floor. The potential for them to encounter humans and domestic livestock could increase.@
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.
!?The area which you currently propose for recovery is vastly larger than your initial proposal. The initial proposal called for no bears in area used by domestic livestock. The current proposal could create depredation problems in Idaho, Lemhi, Elmore, Custer, Boise, and Valley Counties in Idaho and Ravalli and Missoula Counties in Montana. Ranchers who operate in Idaho and Wyoming around Yellowstone Park assure us that grizzly depredation is one problem we can live without. @
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.
!?Introduction of yet another predator would put additional pressure on our dwindling deer and elk herds.@
!?It's nonsense for fish and game to work at building up the wildlife herds in Idaho and then turn around and bring in grizzly bears. ...Also we've all suffered in trying to build up salmon, which I believe is one thing grizzly bears feed on.@
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.
!?Hunters worries that grizzly bears are going to kill off big game are totally false. Grizzlies do not rely exclusively on big game and would kill very few larger animals.@
!?With natural increases of the bears population, game herds will slowly adjust to the impact created by the grizzly's presence.@
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.
!?The cougars, wolves, and coyotes are already taking a toll on our wild game. The grizzly would only make it worse for the game and fish.@
!?I doubt there is enough food for them without having a severe effect on deer and elk populations.@
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.
!?The impact on our wildlife will be devastating to our herds which are in a decline without the presence of the bear. When this would be their main staple of food a loss of 504 ungulates cannot be upheld in any of the area that have been mentioned.@
!?...the DEIS states that the grizzly would kill 504 to 720 ungulates per year while also stating that this would not measurably impact ungulate populations or hunter harvest. Would putting 504 to 720 successful hunters in the field impact the state's game management plan? I think so.@
!?My family and a lot of others depend on deer and elk for our food. We have already had wolves shoved down our throats, now you say we need bears, I can't imagine what for. There are barely enough elk and deer for us now.@
!?...What happens to the revenue of the Fish and Game Department when nobody can hunt because there isn't the deer or the elk?@
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.
!?...our elk herds are being hit hard be the predators that are already here. The recruitment of calves to our elk herds is dismal. Yet now, somebody or some entity wants to introduce perhaps the most efficient predator on calving elk of all time. Not a very reasonable conclusion.@
!?We believe that you have underestimated the potential for the destruction of young ungulates, primarily elk and moose calves.@
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.
!?Maybe one day we can hunt them too.@
!Black bear hunting should not be allowed in any part of the recovery area...too many instances of misidentification by hunters.?
Those in favor of Alternative 3 think that grizzly reintroduction will cause serious declines in big game populations, and reduce or eliminate hunting opportunities.
!?With the wolf and the grizzly in our area soon there will be no elk and deer and no hunting season which will break our economy.@
!?We don't need grizzly bears in the woods. They eat our already low amounts of deer, elks, and other game.@
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.
!?Alternative 4 is the only alternative that addresses the need to address hunting practices in the region to protect the grizzly. In this alternative, @State of Idaho would be requested to eliminate the use of dogs and bait for hunting black bears,? within the recovery zone. It is foolish to risk the loss of the grizzly for a hunting practice when alternatives exist. Dogs and bait are not needed to hunt black bears, and this practice might hurt the recovering grizzly population.@
!?...set the two alternatives side by side, one that conserves the larger roadless space would, in fact, preserve hunting opportunities and that's a pretty clear relationship between habitat security, wildlife populations and hunting opportunities.@
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.
!?...hunters and outfitters...should have the sense enough to know that a tiny population of grizzlies will hardly interfere with their expeditions.@
!?What will happen to traditional Idaho black bear hunting methods used by both guided and unguided publics in the recovery area? Potential trail closures, while noted in the DEIS as rare in other recovery ecosystems, would make it difficult to @get there? to conduct guided hunting or pack trips and would restrict use by guided boating guests.@
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.
!?As a Montanan, there is a significant component missing in the mission to reestablish the bear in suitable regions of Montana, and that is the preeminent goal of return of the status of a huntable, trophy animal. Any EIS concerning the grizzly bear within Montana that ignores this component clearly misses the mark of the emotional, social significance that the traditional hunting of this animal had for us.@
!?The Montana Wildlife Federation would like grizzly bear populations to reach a level where they could be treated like other big game species and excess numbers controlled through hunting.@
!?...reintroduction...if you're going to ...then you should do it with the earmark towards opening a season for them.@
!?...Hunting would be a means of population control and instilling a fear of humans in the bears.@
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.
!?The EIS/Special Rule fails to assure the recreational public the rule anticipates no restrictions on the hunting of black bears within the experimental area for grizzly bear security.@
!What will be the long term ramifications on the black bear populations in this reintroduction area, and what will the limitation on other hunting opportunities within the recovery area be??
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).
!?Adding grizzlies as predators may further decrease populations and, therefore, drastically reduce hunting quotas and the revenue from hunting licenses, lodging, restaurants, retail stores, and outfitter fees. This would hurt our local economy.@
!?...scare off the hunters...We are a low income state and we need the hunters. @
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.
!?...Considerable effort and financial resources are annually expended in this state to manage the game populations on our public and private lands to ensure the optimum health of the resource, and the proper benefit to the sportsmen. I would imagine that forceful reintroduction of grizzly bears will not be in the best interest of the professional management of our game and fish resources.@
!?The Commission and Department (Idaho Fish and Game) will oppose any actions that allow grizzly bear recovery to significantly interfere with hunting or fishing opportunities in Idaho.@
A concern of some respondents is potential access restrictions which would impact hunting and recreation opportunities.
!?We also believe that any introduction of grizzly bears would inevitably lead to area closures, access limitation and change of elk and deer hunting regulations.@
!?I am concerned that portions of the recovery area would be closed to recreational use and hunting to minimize bear/human encounters. I do not want hunting or fishing access limited.@
Safety of hunters in?grizzly country@ is also a concern raised by respondents. 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.
!?...there's not one place the first ten days of hunting. I mean no place. Every meadow, every crook and corner has got people in them. And that's not going to mix with the grizzly bear.@
!?...if my game had to be left overnight in the woods, chances are good that a grizzly would have found it and would challenge me.@
One person wants to stop all hunting in grizzly recovery areas.
!?Please disallow all hunting within recovery areas.@
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.
!?If hunters are not allowed to use viable techniques to hunt black bears or don't hunt black bears because of grizzlies, wouldn't they also lose a level of fear?@
!?What will happen to the Bitterroot's many black bears once bear baiting, hound hunting, and eventually all bear hunting are banned in the proposed Bitterroot Grizzly Bear Recovery Area.@
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.
!?It fails to properly address the complex relationships that exist between bears and other predatory animals like wolves, mountain lions, and black bears. The EIS states: @How predators impact each other and their prey is not very well understood...,? so how can the simple assumption that grizzly bears, wolves, mountain lions, and other predators have and do coexist in other ecosystems be applied in this instance...the question that must be addressed in this instance is whether or not this ecosystem contains all the required habitat attributes, systems, and qualities as other ecosystems that support this mix of predators...We would also like to point out that the Idaho wolf recovery effort has only been in place in this area for two years, might it not be more advisable to establish the success of that effort before we put grizzly bears into the mix.@
!?How do wolves and bears interact, who will be displaced to other areas in the Bitterroot Valley?@
!?With the introduction of wolves in Idaho just last year, there are still a lot of unanswered questions on the management of them. We do not need to double the problems by putting grizzlies in the same area. These two species are going to conflict with each other as well as the many lifestyles in our area. @
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. One comment specifically addresses impacts to boating outfitters and how they would be impacted by sanitation requirements.
!?Nowhere in the DEIS, is there any specific analysis of economic impacts on the Idaho outfitting and guiding economy, which is closely associated with the rural communities that surround the recovery area.@
!?IOGA (Idaho Outfitters and Guides Association) wonders what new restrictions would be placed on boating outfitters who move from river campsite to campsite during their guided excursions that feature dutch oven cuisine...will present aluminum and wood boxes used by boating outfitters be sufficient for storing and maintaining food on guided trips? Or does the FWS plan to deposit government approved bear proof containers in the over 200 campsites associated with theses river systems.@
!?No doubt there will be additional costs associated with operating a hunting or pack trip business within the recovery area due to the necessity to obtain bear proof containers and other associated changes in operations. Where in the DEIS is this economic impact measured?@
!?Who is going to pay an outfitter when there is a bear conflict in his area and all the trails are closed to protect the bear?@
!?...Will outfitters have to move a camp when a bear moves into the same area? Once a bear moves into an area the outfitter is using, will the game stay in the area?@
!?Will the combination of the newly introduced wolf and the grizzly cause unexpected impacts to game herds? If so, what about the loss to the big game hunter and the outfitter who makes his living by managed harvest of big game...will there be increased cost to outfitters due to regulations on camp equipment?@
A few outfitters are concerned about safety for them and their clients in bear occupied backcountry areas when game meat is present.
!?I am an outfitter in the Frank Church Wilderness and do not need to have other hazards for my clients to contend with.@
!?I guide and pack out game. Imagine going 40-50 miles with a pack string full of red meat alone.@
Two respondents think the DEIS does not adequately address the potential conflict and impacts to outfitters and guides.
!?The DEIS fails to consider possible conflicts with outfitting and guide activities. Pursuant to CEQ regulations, the DEIS must discuss the possible conflict.@
!?...the DEIS does not adequately address the adverse impacts that land use restrictions will have on outfitting and other current and potential commercial activities in the Bitterroot.@
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.
!?There are people that pay money to have me take them out there and camp in grizzly country.@
!?...our clients really prefer going into wilderness where there are grizzly bears. They like that.@
!?...hunters and outfitters...should have sense enough to know that a tiny population of grizzlies will hardly interfere with their expedition.@
!?...time to halt the encroachment of...If that means no more outfitting there, so be it.@
!?...Outfitters, if guiding in bear country would no longer be able to keep slovenly camps.@
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.
!?I can promise that I will not take my small children where I know grizzlies are present. I consider that an obvious impact to public access/recreational use.@
!?I don't think we should come up with a special rule that weakens existing standards for trail management....@
People favor Alternative 2 because they don't want any negative impacts to recreation.
!?...at this time I don't see any way possible that on a nightly basis we can hoist a thousand pounds of food into trees 150 yards from camp (rafting camp).@
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.
!?No, I am not running scared as some proponents of this recovery say. I have made a number of pack trips into the Bob Marshall and Scapegoat Wilderness areas, but the preparations I make for this type of outing are different from the recreating I do in the Selway-Bitterroot. I think we need to leave the Selway-Bitterroot Ecosystem alone and leave it as a place where one can go with little or no threat of a grizzly encounter.@
!?I like to hike and camp in the backcountry and would not like to have to worry about a bear that could harm me or my family.@
!?...there are too many people living and recreating in the proposed recovery area.@
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.
!?I am willing to use precautions and educate myself to be more prepared in grizzly country.@
!?If one has a rare opportunity to actually see a grizzly, it is the highlight of their trip, and they talk for weeks or years about how they saw a grizzly.@
!?On Page 4-51, under Impacts on Public Access and Recreational Use the draft EIS states, @There might be a slight decrease in visitor use under this alternative as compared with Alternative 1 due to restricted access from the proposed road closures. This may be offset, however, by an increase in visitors seeking a remote backcountry experience.? Alternative 4 would eliminate 3,500 miles of road within the recovery area. This would make many backcountry scenic areas that are popular now unavailable to the recreationists because of their time limitations. In addition, these roads provide access for fishing, hunting, and driving or pleasure on National Forests lands. The DEIS fails to state whether these closed roads would be available for off-highway vehicle (OHV) use. From our previous experience, in the FWS comments on land management plan revisions, OHV use would not be allowed on these closed roads. This alternative would effectively kill the OHV recreation industry in central Idaho. @
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.
!?...it really disgusts me that people who are recreationists, hunters, backpackers, whatever, when they say they're scared of the bears. I think they want a sterilized, artificial-type environment.@
!?With just a few simple steps, people can take precautions necessary to avoid conflicts with bears in the backcountry.@
!?I am willing to adjust my wilderness travel and camping techniques to accommodate for the presence of grizzly bears.@
!?Because the bear population will be so small to start, I expect most bears to remain deep in the wilderness on the west side of the Bitterroot range. If a bear was to wander to the eastern side, it would not be a cause to close a trail.@
!?Here in California we receive $80 billion per year based on international and national visitation to our state and national parks and forests. ...Tourism is sustainable and grizzly viewing (ex. Yellowstone) is an asset!! All wildlife, whether bison, wolves, or grizzlies bring in tourist money.@
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.
!?The assertion is made that there will be no major impacts upon recreational activities. No studies are presented which objectively compare recreational use, and the nature of that use, in areas before and after grizzly introduction. Page 6-115 states, @Much of the Experimental Area...has a low likelihood of conflicts between grizzly bears and humans. ? Unmentioned is the fact that major portions of the Experimental Area, south and west of the Salmon River have a very high likelihood of conflicts. This approach is carried to the extreme when only human mortalities are deemed important, with no data included on human injuries of conflicts. No data is presented to validly compare or forecast recreational use by families, especially with small children, or even couples. Efforts to compare recreational use in Yellowstone and Glacier with use in the National Forests of the Sawtooth, Pioneers, and around McCall are invalid.@
!?On Page 1-19 and 1-20, @Several people stated the importance of closing roads to all motor vehicles to curtail use.? All motor vehicles are not the same and should not be treated the same. Land managers need to understand the differences and respect them in their management plans. Are year round closures necessary? Equally important, however, is the need for opportunities to recreate on quality wildlands. As our population continues to increase, the demands on our public lands for recreational opportunities will also increase.@
!?...DEIS severely deficient in its handling of impacts on recreational use...The discussion focuses entirely on quantitative effects of reintroduction of grizzly bears; i.e., effects on numbers of recreation visitor days, or visits...Entirely omitted is discussion of impacts on the qualitative aspects of recreational experiences, including adherence to food storage guidelines...restrictions on camping...travel on trails...requirements for game animals killed...requirements for storage of horse feed, etc....omitted is the analysis of cost to backcountry travelers of purchasing the equipment necessary to comply with these kinds of requirements. The only reference I find to these considerations is on page 4-18...regulations requiring outfitters...to use bear-proof garbage and food containers...or hoists...Are you stating that these regulations would not apply to the non-outfitted backcountry traveler? What are all of the impacts on recreationists - quantitative and qualitative? This entire section needs re-analysis and a much more candid discussion. @
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.
!?After grizzly bear introduction, much of the backcountry will, of necessity, be avoided by people who currently enjoy this area...few rational individuals would dare take their dogs with them...people with children who backpack...would probably avoid the area after grizzlies are introduced. This forced avoidance represents a real and very substantial cost to these categories of users. It should be explicitly addressed in the DEIS.@
!?Tourism is the third largest industry in Idaho and plays an important role in Idaho County. This industry would be seriously, adversely impacted when hunters, campers, hikers, mountain bike riders, and berry pickers realize they could very likely encounter a grizzly bear. Most would find other places for outdoor recreation.@
!?I am writing to you as a hiker of the Selway-Bitterroot area, entering mostly from the Bitterroot Valley side. I thoroughly enjoy the peace of mind I have now, knowing I will not encounter a grizzly bear. I purposely stay out of grizzly country (Glacier, Yellowstone, Swan, etc...).@
!?...In my history as a backpacker I learned that should a woman backpack, she should never while she is having her period be in the woods where there are grizzly bears. This reintroduction would be discriminatory against the gentle sex.@
!?I am disabled vet and the only way I can see the backcountry is on horseback. I can imagine what will happen the first encounter with a grizzly.@
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.
!?I am an avid and happy river rafter in the Bitterroot Wilderness area and think that the introduction of grizzly bears would pose way too much danger for rafters.@
!?Ten thousand people per year float the Middle Fork of the Salmon River, nearly seven thousand people float the Main Salmon River, and a lesser number float the Selway River. Adding grizzly bear to this ongoing activity is bad public policy. Floating miles of Wilderness rivers in a grizzly bear recovery zone creates an even more impossible conflict to resolve. It will only be solved by eliminating grizzly recovery or eliminating floaters. @
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.
!?No reasonable consideration is provided in the DEIS to potential conflicts with salmon and steelhead recovery programs also being conducted within the area affected by the Proposed Action. In light of National Marine Fisheries Service (NMFS) decisions to issue @no incidental take? directives to many land management and land use projects and proposals affecting the recovery area and nearby land, it can be presumed that the NMFS `zero risk' approach to listed salmon and steelhead must be taken seriously...Any consideration of grizzly bear reintroduction should be ended until this apparent conflict is resolved.@
A few people support Alternative 3 because they are concerned about impacts of grizzly bears on other listed species.
!?The grizzly bear reintroduction plan is in conflict with recovery plans of other endangered and threatened species, as well as candidate species. The species of particular concern are the chinook and steelhead salmon and the bull trout. These species would be seriously harmed by voracious grizzly bear which feed on these fish.@
Supporters of Alternative 4 think this alternative will protect other listed species by protecting and restoring large habitat areas in the BE.
!?...protecting grizzly bear habitat also helps other endangered species, thereby saving the government money.@
!?Restoration efforts provided for by Alternative 4 would have multiple species benefits, rolling up roads in northern Idaho would have many watershed benefits, which would in turn benefit native salmonids.@
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.
!?...If the grizzly bear is reintroduced how are they going to be kept from feeding on the salmon? Is this reintroduction of the grizzly bear potentially a violation of the Salmon Recovery Act? They are an uncontrollable predator of the salmon.@
!?DEIS does not address the effect of the alternative on populations and habitats of chinook and sockeye salmon, and steelhead. Instead, the FWS is performing an integral biological assessment of the effects...FWS must integrate NEPA requirements with other planning and environmental procedures so that all such procedures run concurrently rather than consecutively...The FWS has failed to integrate the biology assessment of the referenced fish species with the NEPA process, contravening CEQ directives. The effects of a recovered grizzly population on the indigenous endangered fish species is unavoidable but unquantified.@
!?It seems pretty arrogant of the FWS to prepare an evaluation of impacts to other T and E species considering that the DEIS has not even been commented on by the public and no decision has even been made.@
!?...Final EIS must include a comprehensive analysis of what effect grizzly bear recovery in the GSBE will have on other threatened and endangered species such as salmon and steelhead. In other words, a multiple species ecosystem approach should be taken that does not benefit one species while at the same time it increases the imperilment of other species.@
!?...the federal government, whose idea of salmon recovery is to throw tourists off of the Salmon River, is serious about introducing predator that eats salmon.@
!?You must be aware that we have just had the reintroduction of the gray wolf. Introducing grizzly bears will have direct impacts on the effort to recover this population. As biological scientists, you must be aware that not only do wolves and grizzly bears exist as predators in the same food chain, but have direct contact in several ecosystems. In those systems in which bears and wolves both exist, the bears cut the wolves competitiveness by reducing wolf populations directly...What consultation has been performed with the Wolf Recovery Team? Similar problems exist within our fish populations. ...What consultation has been performed with the Salmon Recovery Team? The same goes for Bull Trout, Steelhead, or Western Cutthroat Trout.@
!?Great care should be taken when pitting one listed species against another such as grizzly bears with salmon, bull trout and steelhead.@
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.
!?When we take actions that are narrowly focused to benefit a single target species we often set the stage for less beneficial results for other animals (including humans).@
!?We feel the bears are killing too many elk calves and other wildlife.@
!?We do not need more predators to kill our elk, deer, livestock, salmon, steelhead, etc.@
!?Now some folks want to put the grizzly bear along with the wolf in the Selway Bitterroots. What do you think that will do to our elk, deer and moose herds (sic)? If we put the grizzly in along with the wolf there goes the rest of the crop. Soon the elk, deer and moose will be the endangered (sic) species.@
!?...this @kill rate? may turn out to be correct, the @harassment factor? is far higher. ...when predators are introduced, the prey leaves.@
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.
!?An important benefit of maintaining and restoring grizzly bear populations in the GSSE is that if protection of grizzly bear habitat is fully accomplished, the myriad of those other animal species finding important habitat in these federal lands will be served also. @
!?The habitat restored and preserved for the grizzly bear will also ensure the survival and perpetuation of many other species...Neotropical migratory bird species which have been in serious decline will also be well-served by habitat protected for grizzly recovery.@
!?Alternative 4 provides for the habitat that's so important to big game, elk, fishing, deer, sheep, mountain goats and all the rest. @
!?Because the grizzly bear is an umbrella species, if it survives so will other species. Thus increasing other animal populations.@
!?Clearly, Alternative 4 is the best choice for the grizzly, and those creatures who depend on the grizzly for their own survival.@
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.
!?The grizzly bear, being more aggressive, will probably replace a certain segment of the black bear population. This impact is expected to be minimal.@
!?Grizzly bears will cause displacement of substantial numbers of lesser predators (such as black bears) perhaps generating migration of these other predators into areas of substantial human usage. This could create potentially dangerous human/predator interaction. This issue should be addressed in the DEIS.@
!?...Although the DEIS discussed this issue it does not address their assumed knowledge that black bears will seek new localities where they will prey on other ungulates further changing the present balanced ecosystem...@
!?...The elimination of black bear hunting with dogs and bait in grizzly reintroduction country is especially inappropriate, because the reintroduced grizzly will successfully compete for the black bear's food, pushing the hungry black bears into populated areas, searching for food.@
!?...a grizzly bear killed a black bear sow and orphaned two of her cubs which were then sent to zoos where they will live the rest of their lives, because they would not survive in the Wilderness...Idaho's healthy and stable populations of black bears can fulfill the ecological niche which the grizzly bear might displace our black bears from.@
One person is concerned specifically about grizzly bear depredation on spawning cutthroat trout.
!?They will alter the already delicate balance of our fisheries. The Cutthroat Trout is a species of concern. The lakes and streams that have natural reproduction will be decimated during spawning season when the fish are an easy catch for the bears in the streams and shallow lakeshores...This is a blatant conflict of interest. @
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'.
!?We need to return nature to what it used to be. And not to decide which animals should stay and which should not. We are not God. Only earths keeper for now!!@
!?... the east and west coast people that truly love to hunt in wild places and fish in remote country have come to appreciate the wild splendor that remains of Idaho. They recognize that they've 'tamed' their respective states to the point of no return and they seek places like Idaho and Montana in order to experience what 'used to be'. Now, we in Idaho we still have a chance to recover part of our heritage.@
!?The grizzly is a potent symbol of the American West...@
!?The people of Montana and Idaho have done just fine without grizzly bears in the B.S.W. for almost a century, so leave it alone.@
!?More emphasis needs to be given to humans than animal species or habitat concerns.@
!?While spiritual and cultural considerations did not contribute to the formulation of DEIS alternatives, they are certainly an important focus in setting the upper grizzly population objective. We have gone from a situation where man was essentially an observer in a world where he exerted little control to a situation where we will decide whether the grizzly will, first, exist at all in the BE and second, will he be a major part of the ecosystem.@
!?Looking at alternative one I don't see any fighting for anyone but ourselves. It is just for us. This self-serving mind set scares me because I don't think the human race will make it unless we are fighting for other species to survive.@
One individual speaks to the social significance of hunting and how it pertains to reintroducing the grizzly bear.
!?As a Montanan, there is a significant component missing in this mission to reestablish the bear in suitable regions of Montana, and that is the preeminent goal of returning the bear to the status of a huntable, trophy animal. Any EIS concerning the Grizzly bear within Montana that ignores this component clearly misses the mark of the emotional, social significance that the traditional hunting of this animal had for us.@
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.
!Without bear, the landscape is poorer, as Camas and Bitterroot have declined, in the absence of the grizzly so too does wilderness. It's troubling to think that my grandchildren may not have the opportunity to encounter wild grizzlies.?
!?Our grandchildren will thank us for spending this $. It is far more valuable than many other gov't expenses.@
!?Montana's state animal is the grizzly bear, Montana's state fish is the west slope cutthroat trout, both are in jeopardy...Alternative 4, would provide habitat for the state animal and the state fish and that is very important.@
!?I have two children, ages 10 and 13, and I'd like to say very plainly that I know that their lives would be enriched much more than threatened by the presence of grizzlies near our home.@
!?Perhaps in some small way, saving wild places will be or gift to the future. What a shame if this gift were taken away or discouraged.@
!?Introduction of the grizzly bear into Idaho will destroy the culture and heritage as well as the economy of the region.@
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. One person feels bears have no intrinsic value. Comments similar to this issue are contained in the write-up for issue 401, Grizzly bear as a missing component of the ecosystem. The reader is referred to that section for additional comments..
?...just knowing that they are there has enriched my life, invigorated me, given me a more zest for living that tends to shrink from your other troubles when you know there's a grizzly around.@
?Furthermore, I know that many visitors to the Rocky mountain outdoors regard the presence of grizzlies and wolves as a special attraction, and are willing to seek out these experiences, and pay extra for them.@
?I have never seen a grizzly bear in the wild...at 83 I probably never will, but I still want to know they are out there.@
?People come from all over the world to Katmai park to see bears...because they come from places where there are no bears. And they feel that it's an important thing, and it's valuable to them. And I feel very much the same way about the Bitterroot.@
?The Grizzly bear has no justifiable beneficial value except for preservationists to look at and for Bureaucrats to justify their job.@
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 three; 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.
!?I object vehemently to the expense of bringing them in. We have enough trouble balancing our national budget as it is.@
!?Waste of time , money, manpower that I would rather see used for Deer and Elk Management.@
!?I have a hard time with the money being spent on this reintroduction. A million dollar bear, with the total program cost $130 million? This is ridiculous! Why doesn't the federal Government use it for funding more Aids research, helping out the needy and poor, sinking this money into schools so we can better educate our children?@
!?The cost of introducing species into areas where they are not existing could better be spent in other areas of wildlife management, habitat improvement for existing species and feeding the starving human population in our country and the world. A million plus dollars per animal is excessive when you open your eyes to the world around you.@
!?I an not against the G bear, but I am opposed to the huge amount of tax dollars spent on them.@
!?The cost implementation for all alternatives is completely erroneous. The cost of the wolf reintroduction program was well over four million dollars. The estimate of less than two million dollars for alternative 1 is unrealistic. The Draft EIS should include a complete and detailed budget of all costs involved in this program.@
!?...There is absolutely no discussion on costs associated with 'one injury per year, and less than one bear-induced human mortality every few decades...there is going to be a civil suit of biblical proportions...Please include this potentially large cost that the government will likely have to absorb because it is ultimately the responsibility party by knowingly and deliberately reintroducing these dangerous animals into this area.@
!?...there is another species that I feel the money should be directed toward. Homo sapiens. There are so many, many sick, hungry, and homeless people that I feel should have priority. We have no business spending our taxes on trying to enhance a species so menacing.@
!?Enormous amounts of scarce managerial budgets are re-directed to analysis, coordination, and mitigation efforts required to deal with grizzly bear issues...result in much less available for maintenance management and administration of the trails, campgrounds, and special use permits that actually help the public use and enjoy the backcountry.@
!?I read in the paper where it's going to take 260 million dollars in this economy for these 260 bears. Well, I'd like to apply for a permit to start a game farm to raise grizzly bears because I can sure feed them a lot of cheap beef and make a lot of money.@
!?...the DEIS does not fully develop cost associated with the Proposed Alternative. The benefits associated with recovery under the Proposed alternative range from $40.4 to $60.6 million per year. These benefits are comprised entirely of highly speculative and statistically dubious passive use values. The net benefits fail to consider probable losses due to reductions in resource extraction activities, costs associated with indirect impacts on the local economy, and a probable reduction in visits to the Experimental Population Area which are supported by data collected in anticipation of the DEIS.@
!?If alternative 1 were chosen, the draft EIS states that the annual net social benefit would be $40,449,030 to $60,639,180. But the EIS doesn't state who collects the 40 to 60 millions of dollars. Or who receives the benefits of this money. Does it increase business? Will we have an increase in timber sales? Will outfitters have more tourists?@
!?The $50 million dollars 'existence value' assigned to the bears are not real dollars. REAL DOLLARS are the dollars that are derived from the prudent management of our public lands, including the responsible use of renewable timber supplies that exist on our national forests.@
!?If action is going to be taken I believe that the natural reintroduction of grizzly bears into the area is the clear choice. Not only will taxpayers save millions of dollars by leaving roadless areas alone, but we will also save money by allowing the bears to naturally migrate throughout the territory as they once did.@
!?I am tired of my tax dollars being used for logging and mining and welfare grazing and I want my tax dollars to be used to bring back the grizzly bear.@
!?The cost of the program is a waste of money, especially when the same money could be used to assist grizzly bears in their present habitat.@
!?Alternative #4 results in a net savings to taxpayers by prohibiting road building and logging in the roadless areas located within the proposed grizzly bear recovery area outlined by this alternative. Using figures developed by the General Accounting office (GAO 1995) and retired Congressional Budget Office forest analyst Robert Wolf (1195), logging the roadless areas at levels outlined by the (LRMPs) would result in a net loss to U.S. taxpayers of approximately $137 million over the ten year period of 1997-2006...habitat restoration...the cost of this work over the ten year period 1997-2006 are approximately 467 million. Since the total savings associated with this alternative are much greater than the total costs, the net savings equals approximately $69 million (see letter 185).@
!?The United States Fish and Wildlife Service has not identified the long-term funding source for the plan under any of the alternatives. It has not offered written assurances to Montana and Idaho that the states will not be forced to bear additional costs. An unfunded federal mandate to Montana and Idaho is not acceptable.@
!?...written assurance from the Secretary of Interior that adequate funding is available for both this project and for all aspects needed to delist bears in the Yellowstone and NCDE.@
!?IDFG urges the Service to withdraw the DEIS from public comment until it can provide assurance that the State of Idaho would be provided with funding sufficient to conduct all necessary monitoring and all necessary management actions in both the short and long term.@
!?The EIS also fails to evaluate the anticipated cost of capturing bears...We believe the estimated cost to capture and relocate that many animals is grossly underestimated based upon the Cabinets work, because at least three work crews would be more than likely be needed, trapping at three separate locations. The EIS must be adjusted accordingly.@
!?The Idaho and Montan Chapters of The Wildlife Society support grizzly bear recovery in the Bitterroots. Should the effort move forward, commitments and funding must be sufficient to conduct the reintroduction and more importantly to carry out the monitoring that will be imperative during this undertaking.@
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.
!?The public information and education outreach program should extend beyond the one year @phase in.? Provisions should be made to continue education programs and to adjust special sanitation equipment needs. An ongoing education program should be incorporated into state hunter safety programs, schools wildlife clubs and other community groups.@
!?I think public education will be your best avenue, people always fear change and the unknown.@
!?...there is not nearly enough information reaching the news media on the cost of the various programs.@
!?The press has done a good job of scaring the general public about the danger of the grizzly bear. There would need to be a good public education program implemented prior to the release of any animals.@
!?Sanitation equipment should be installed & education provided before bears have an opportunity to become dependent on human food.@
!?With education and the use of bear proof containers for all backpackers, the humans and grizzly bears can live side by side.@
!?Food storage and camp maintenance guidelines must be developed with outfitters and guides, as well as garbage handling techniques for property owners and small communities adjacent to and within the recovery area. Federal assistance should be made available to help implement these programs@
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.
!?The public needs to be educated about the risk of bears, and the true likelihood of ever seeing one. The public needs to accurately understand the risks versus unfounded fears and political grandstanding. Idaho's elected politicians are shameful with their mis-information.@
!?State officials have spread misinformation, villainizing the grizzly bears to the public...a public information and education campaign needs to be undertaken.@
!?Public education will help to change the fear from a hysterical, fictitious reaction into an informed opinion.@
!?I would also suggest some sort of public information campaign to allay fears that grizzlies are going to walk into Boise and start eating men, women, and children.@
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.
!?This alternative [alternative 4] fails to provide for education about public safety. It offers little or no protection for local landowners or others whose way of life and property may be affected.@
!?An extensive public information campaign to protect people, property, and bears must be developed and made available to all users of the proposed area before reintroductions begins.@
!?There must be more public education on the necessity of the Selway-Bitterroot area for the long term survival of the species; and on the positive aspects of the Endangered Species Act.@
!?If people in the East want more bears, educate them.@
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.
!?Much of the science about grizzlies is being ignored in favor of politics. Instead of knowledgeable wildlife biologists managing for grizzlies, a citizens committee will be in charge of management. Nominees of the Governors of Montana and Idaho will dominate this committee. How can one expect a citizen's committee of that political flavor to provide any reasonable recovery option?@
!?I do not support a citizens committee on grizzly bears introduction, because as soon as the committee comes up with a decision on the grizzly bears it probably would be changed by the Secretary of Interior, Mr. B. Babbitt, or the people he works for.@
!?The inclusion of an apparent arbitrary and trivial amount of Montana in the Recovery Plan appears to be a ruse to obtain protection for the Plan under the Interstate Commerce clause of the Constitution.@
!?Alternative 1 is a bureaucratic and political operation where those who lose are the citizens and their expectations of thoughtful government.@
!?The recovery zone under the preferred alternative has been limited for purely political reasons, violating the ESA's provision that recovery efforts be based on the best scientific information.@
!?The GSSB would be deliberately isolated from other ecosystems by failing to provide linkage corridors which is a political and legal strategy to isolate the GSSB population to maintain @experimental/non-essential? status.@
!?The suggestion that management of an experimental nonessential population be handed over to a highly politicized partisan committee of government appointees, most of whom like the Governor, the Attorney General and other of Idaho's elected officials, strongly oppose bear reintroduction. These groups are strong political allies demonstrated and self-admitted of timber, mining, ranching, grazing and other nonsustainable extractive industries.@
!?Once the anointed Management Committee is in place, even the pretense of objectivity and fairness quickly disappears as the politics of who's in and who's out rears its ugly head.@
!?We are extremely upset with the eastern establishment trying to force another of their bright ideas on us in the Northwest.@
!?I am AGAINST grizzly bear reintroduction...In talking to friends and neighbors, the overwhelming majority are against reintroduction but will not bother responding to the Draft EIS or bother writing a letter because they feel reintroduction is a 'done deal in Washington, D.C.'@
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.
!?Arbitrarily relocating Grizzly bears into the Selway-Bitterroot Wilderness, in light of the questionable quality of the habitat, and in the face of the strong objections of the Idaho Governor, the Idaho State Legislature, the Idaho State Fish & Game Commission, the Idaho Department of Fish and Game, and much of the Idaho Congressional Delegation is folly indeed!@