Nov. 31, 1997
Dr. Chris ServheenUSFWSUniversity Hall, Room 309University of MontanaMissoula, Montana 59812 USAfax 406-329-3212Dear Dr. Servheen:
The International Association for Bear Research and Management (IBA) is an organization of some 650 members from around the world. Most of our members are professional biologists working on bear management and research issues, but our membership also includes non-biologists who are committed to a professional approach to bear management issues. Most of our members work for universities, state, federal, or provincial governmental agencies, or NGOs. Our Association holds a scientific conference every three years, usually with sessions in Europe as well as North America, and publishes the peer-reviewed proceedings in the series entitled Bears-Their Biology and Management.
The IBA strongly supports reintroduction of grizzly bears into the Selway-Bitterroot Wilderness areas of Idaho and western Montana. This area is the largest contiguous area of suitable habitat remaining in the lower 48 states that does not currently have grizzly bears. We believe that reintroduction of grizzly bears into this habitat would be successful from the standpoint of people who are using this area for a variety of purposes and from the standpoint of the bears. We also believe that a successful reintroduction into this area will provide a valuable model that will permit additional reintroduction efforts to proceed elsewhere.
The draft EIS includes 2 alternatives which our organization supports. Both of these alternatives have strengths and weaknesses and both have a probability of success in accomplishing the objective of reestablishing a viable population of grizzly bears in western Montana and central Idaho. Our governing Council was not unanimous in their views on which alternative offered the better probability of success.
Alternative 4, the "conservation biology" alternative, is the strongest alternative from the purely biological perspective. Bears introduced under the terms of this alternative would have full protection offered by the Endangered Species Act (ESA). If it could be implemented, our Council agrees that this protection would give the bears the best chance of successfully establishing a viable self-sustaining population and would do this in the shortest period. Two of the members of our governing Council (Harry Reynolds and Ivar Mysterud) voted for an IBA endorsement of this alternative. The remaining members of our Council believed that political and economic opposition to Alternative 4 would likely prevent it from being implemented; these members voted to endorse Alternative 1 although they had some reservations about this alternative.
Alternative 1, the "preferred alternative" in the draft EIS represents a reasonable attempt to accommodate local concerns that would likely prevent the grizzly reintroduction efforts from being implemented in the view of the majority of the members of our governing Council. Under Alternative 1, the introduced bears would be treated as an "experimental non-essential population" and would not be afforded full protection as an endangered species under ESA. This approach has been successfully used in reintroductions of other populations of endangered large carnivores such as red wolves in North Carolina and timber wolves in Yellowstone. This approach has been proven effective in reintroduction efforts for disparate species from black-footed ferrets to condors (in Arizona).
Based on the proven track record of this "experimental" approach and our recognition that compromises need to be made to overcome social and political objections to grizzly reintroductions under full protection of ESA, 8 members of our governing Council (Sterling Miller, Mike Pelton, Mike Vaughan, Kate Kendall, Djuro Huber, Helene Jolicoeur, John Beecham, and John Schoen) voted to endorse Alternative 1. However, these members have reservations about the Citizen Management Committee (CMC) approach outlined in Alternative 1.
To our knowledge the appointment of a CMC with regulatory authority to manage resident species of wildlife has not been tried before. As long as the individuals appointed to this committee by the Secretary of Interior, based on the nominations proposed by the Governors of Idaho and Montana, have a strong commitment to the success of the reintroduction effort, this approach could be effective at reducing local concerns over grizzly bear management. However, creation of another organization with mixed regulatory and advisory mandates over a very narrow range of resource management issues, will further complicate a situation where there are already frequently differing state and federal management objectives. Correspondingly, if the CMC approach turns out to be ineffective in obtaining recovery of this population, then we would urge the Secretary of Interior to speedily explore other options for grizzly management authority in the Bitterroot recovery area. These options would include both resumption of management under federal authority and transfer of management authority to a group of state and federal resource management professionals. Under these circumstances the CMC could retain a strong advisory role. Because we think the CMC should be given every opportunity to be a successful model for local involvement in issues like this, we further recommend that the Secretary be required to appoint at least 2 scientists considered experts in bear management issues to the 15 member CMC. These experts should, preferably, not be employees of federal agencies and could be drawn from lists of experts submitted by state management agencies and NGOs. Our organization would be pleased to nominate well-qualified scientists to serve in this capacity.
We further believe it is important to include as much acceptable habitat as possible in the delineated recovery area for the introduced population. Under Alternative 1 the designated area for recovery is limited to established areas designated as wilderness. Expansion of the recovery area will permit more full exploitation of the management flexibility permitted under the experimental population approach of Alternative 1. For this reason we recommend including the important habitats on public lands north of the Lochsa River in the Clearwater drainage as part of the delineated recovery area.
We believe that the grizzly is an important native species in the Bitterroot ecosystem. We will support and assist in all efforts designed to reestablish a viable population of this species in this area. We are certain that grizzly bears and humans can and should coexist in this area. As researchers and managers of bear populations we know that problems or conflicts that may arise can be managed here as they are elsewhere. The Bitterroot represents the best area south of Canada where grizzly bears could be successfully reintroduced. Our organization will be pleased to advise and assist the process of accomplishing this worthwhile objective.
Thank you for this opportunity to comment.
Sterling Miller, President
August 8, 2001
Grizzly Bear Coordinator
US Fish and Wildlife Service
PO Box 5127
Missoula, MT 59806
RE: Comments on Grizzly Bear Recovery in the Bitterroot Ecosystem
The Bear Specialists Group (BSG) is one of the specialists groups founded under the auspices of The World Conservation Union (IUCN). The BSG prepared and published the Bear Status Survey and Conservation Action Plan in 1999. The plan is the framework under which conservation and recovery efforts for the world's 8 species of bears will be conducted. One chapter in this plan deals with grizzly bear recovery in the lower 48 states of United States and this chapter identifies restoration of grizzly bears in the Bitterroot ecosystem as an important component of US grizzly bear recovery efforts.
Correspondingly, the BSG is very disappointed in the recent decision of Secretary of Interior Gale Norton, to abandon the previously adopted plan to reintroduce grizzly bears to the Bitterroot area of Idaho. The United States is viewed as the world's leading nation in democracy, wealth and influence. We believe that the United States must also take a leading role in ecological conservation. Reintroducing grizzly bears into the Bitterroot Ecosystem would have set an important international standard for restoring and maintaining the integrity of ecosystems. We hope this opportunity is not lost and that the U.S. Fish and Wildlife Service will adopt and implement the Record of Decision published in the federal register in November 2000.
The stated reasons for abandoning the plan to reintroduce grizzly bears to the Bitterroot Ecosystem are unconvincing. The cost of $2.1 million over 5 years ($420,000/year) cannot be significant for a country with the enormous wealth of the United States. We note that grizzly (brown) bear reintroduction efforts have been taken in countries like Italy and Austria that have far fewer resources and where ecological conditions are less favorable for success than exist in the Bitterroot Ecosystem. Also, this species has been successfully been re-establishing itself through natural dispersal throughout Scandinavia because of governmental actions that encourage its recovery. Certainly the United States should be able to do as much as these countries to restore this species which has been eliminated from 98% of it's habitat south of Canada and is listed as "threatened" under the US Endangered Species Act.
The stated concerns over public safety are also unconvincing. Based on extrapolations from areas with similar conditions, the frequency of human deaths or injury from grizzly bear attacks from a recovered population in the Bitterroot will be extremely rare. Overall, there is an average of about 3 human deaths caused by bear attacks per year in all of North America from polar bears, black bears, and grizzly bears. In the Bob Marshall wilderness area of Montana, which is most similar to the wilderness areas in the Bitterroots, there has not been a human mortality from grizzly attack since 1959.
I urge you to reconsider the decision to abandon the proposed reintroduction of grizzly bears into the Bitterroot Ecosystem. The United States does not have to take a back seat to nations such as Sweden, Austria, Canada, and Italy when it comes to encouraging brown bears to repopulate areas of ecologically and socially appropriate habitat such as occurs in the Bitterroot Ecosystem.
Dr. Bruce N. McLellan
IUCN, Bear Specialist Group
August 14, 2001
Grizzly Bear Recovery Coordinator
US Fish and Wildlife Service
PO Box 5127
Missoula, MT 59806
Re: Bitterroot Grizzly Reintroduction
The International Association for Bear Research and Management (IBA) strongly opposes the Secretary of Interior's recent proposal to negate a previous decision made under authority of the Endangered Species Act that would have benefited long-term health of threatened grizzly bear populations in the mountain West. The proposed action would replace the Record of Decision adopted by the US Department of Interior in November 2000 to restore grizzly bears in the Bitterroot Ecosystem with one specifying that "no action" will be taken. We urge the Secretary to reconsider, to reject the "no action" option and to proceed with implementation of the original decision.
The IBA is an international professional society of scientists and managers dedicated to science-based conservation of bears. We have over 700 members from 43 countries working on all aspects of science and management of the world's eight bear species. We hold periodic conferences in countries around the world and annually publish a volume of the peer-reviewed scientific journal, Ursus, recognized as the authoritative source for biological information on the world's bears and their conservation. Our members are well-qualified to speak on matters concerning bear biology and management, protection of human safety and property in areas occupied by bears, and reintroduction of bears into formerly occupied ranges.
All bear species have been significantly reduced in numbers and distribution due to expanding human population and developments. In North America, the grizzly bear once lived as far south as Mexico but now occupies less than 2% of its original range south of Canada. This is an unacceptably small percentage given that there are large areas of formerly occupied habitat that are both biologically and socially suitable locations for restoration efforts.
Of these currently unoccupied habitats, the wilderness area in the Bitterroot Ecosystem is the most appropriate place to restore grizzly bears. This area is remote, is primarily designated wilderness, is sufficiently large and intact to support a viable population, and the potential for significant conflict with other uses such as livestock grazing is very small. The Selway-Bitterroot and adjacent Frank Church-River-of-No-Return Wilderness Areas together constitute 15,800 km2 (6100 mi2) of designated wilderness surrounded by some 52,000 km2 (26,000 mi2) of national forest lands much of which is also suitable grizzly bear habitat. We are aware of nowhere in the world where there is a better opportunity to reestablish a significant population of grizzly bears.
Restoration of brown (grizzly) bears in Europe is now occurring in areas that are far less favorable than occur in the Bitterroot from the standpoint of amount of habitat and likelihood of significant conflicts with other uses. It should be the responsibility of the United States to set a good example to the rest of the world on restoring a depleted species like grizzly bears in an area where they were extirpated only 60 years ago. Elsewhere in the world, Italy, Austria, Sweden, and Norway are actively undertaking restoration programs for brown bears in areas from which they were eliminated. Similarly, Spain and France are taking extraordinary measures to preserve small remnant populations of brown bears under conditions far less favorable than exist in the Bitterroot Mountains.
We acknowledge that the support of local citizens is a vitally important consideration in the restoration of species like grizzly bears. The decision adopted last November recognized this and proposed a grizzly restoration plan that was unprecedented in the amount of authority and involvement provided to local citizens to manage a restored grizzly population. This innovative plan resulted in significant agreement among people with disparate opinions about grizzly restoration.
A restored grizzly bear population in the Bitterroot Ecosystem would be the third largest population south of Canada, following existing populations in the Northern Continental Divide Ecosystem and Yellowstone Ecosystem. It is situated geographically in a key position to permit the movement of bears and genetic interchange between isolated populations south of Canada. It is our opinion that the largest single step that could be taken to recover grizzly bears south of Canada would be to reestablish another significant viable population in the Bitterroots.
The Bitterroot Ecosystem is identified as a recovery area in the 1993 grizzly bear recovery plan. Correspondingly, grizzly bears must be restored to this area before the species can be delisted under the Endangered Species Act. A decision to take no action on grizzly restoration in this area will delay the time when this species can be delisted and is contrary to the Secretary's responsibility under the Endangered Species Act to recover listed species. Continuing and enhancing current recovery efforts in the other US grizzly bear populations is unquestionably important, but the gains toward overall grizzly bear recovery remaining to be made in these ecosystems are relatively small compared to the large gains that could be realized from a restored grizzly bear population in the Bitterroots.
The extremely small grizzly bear populations in northwestern Montana and northern Idaho (each with only 30-50 bears) have been found to be warranted to be listed as "endangered," although still listed as "threatened." These are the closest populations to the Bitterroots and their likelihood of persistence would be greatly enhanced by establishment of connections to a larger restored population in the Bitterroots.
Our strong opposition to the Secretary's proposed revocation is based on seven tenets:
1 The previously passed Record of Decision that provided for grizzly bear reintroduction in the Bitterroots would protect the integrity and long-term viability of threatened grizzly bear populations in the mountain West far better than the revocation and adoption of a "no action" alternative. Grizzly bears were eliminated from the area by human actions by the late 1940s. Reestablishing the ecological diversity of the wilderness area and immediately adjacent federal lands by bringing back grizzly bears is simply the right thing to do.
2 Neither prioritization among recovery efforts nor funding priorities for recovery provide adequate reasons for revocation of the Record of Decision. If the same reasoning proposed for revocation of the recovery program in the Bitterroots is followed to its logical conclusion, then recovery decisions for other grizzly bear populations of lower priority for recovery or funding would also be considered for revocation. Certainly, the Department of Interior is not contemplating such actions, but neither should it do so with the Bitterroot Record of Decision.
3 Both funding and recovery efforts for the reintroduction of grizzlies in the Bitterroots were designed to be separate from funding and recovery efforts for other grizzly bear populations, according to statements by the Department of Interior in the Final Environmental Impact Statement (FEIS: e.g., p. 5-20). Furthermore, funds for state programs associated with the reintroduction would be provided to the states (FEIS, p. 5-50). Therefore, funding and reprioritization among recovery plans should be a moot issue.
4 If the present Record of Decision cannot be implemented because of funding appropriations and budgetary constraints, it should remain as an Endangered Species Act finding that awaits adequate funding. Similar decisions, contingent upon adequate funding and prioritization, occur with other listed species.
5 It is very unlikely that any biological or social changes have occurred in the area that were not addressed in the Endangered Species Act assessment made in November 2000. Therefore the previously passed decision, made after a 5-year public process in which over 24,000 individuals provided input or participated in review and revision, should stand.
6 Safeguards for legitimate human safety concerns related to the reintroduction need to be an integral part of the programs but were adequately addressed in the Final Environmental Impact Statement and Record of Decision. There is no scientific basis for a call to reexamine the findings that human safety will carry any further risk than the assessed projection of one potential human fatality in the area every 20-30 years.
7 Funding for recovery of threatened grizzly bear populations in the region is presently inadequate and should be increased. This is a pressing need if recovery of threatened populations is to proceed. The implication that the FWS is presently conducting and funding the nine recovery activities listed in the Federal Register (p. 33620) needs clarification. Our inquiries to the Grizzly Bear Recovery Coordinator's office indicate that none of these activities have been funded as budget line items. Similarly, although examples are provided of recovery activities that may be given priority (Federal Register, p. 33624), none have been funded. In fact assigning priority to printing a conservation strategy for management of bears in the Yellowstone Ecosystem after delisting occurs seems premature since delisting has not yet been proposed.
If IBA can be of service in further deliberation of this issue, we are very willing to participate in any advisory or scientific capacity.
Again, we strongly urge the Secretary of Interior to reject the proposal to take "no action" on grizzly restoration and to implement the November 2000 decision to restore grizzly bears to the Bitterroots.
Grizzly Bear Recovery Coordinator