Due to a court decision regarding gray wolves in the Great Lakes, the USFWS must re-consider its decision to delist the Greater Yellowstone Ecosystem's grizzly bears. The Service is accepting public comment on whether the referenced decision impacts the delisting rule and "what, if any, further evaluation the Service should consider regarding the remaining grizzly bear populations and lost historical range in light of the Service's decision regarding the GYE grizzly bear."
Public comments must be submitted electronically HERE no later than 11:59 PM EDT on January 8, 2018. We recommend composing your comments in another platform and then copying and pasting the final product into the comments section of the Federal Register. You may want to send a copy of your comment to your members of Congress as well as as a Letter to the Editor of your local paper. PLEASE DO NOT POST YOUR COMMENTS ON THIS BLOG BUT ON THE LINK TO THE FEDERAL REGISTER.
TALKING POINTS FOR YOUR PUBLIC COMMENT:
- The ruling in Humane Society v. Zinke makes clear that USFWS cannot address endangered species recovery in a piecemeal fashion. By dividing up grizzly bears in the lower 48 into several regions - Greater Yellowstone Ecosystem, Northern Continental Divide Ecosystem, Selkirk Ecosystem, etc - the Service is doing exactly that.
- USFWS did not have the authority to balkanize the grizzly bear species into Distinct Population Segments in order to delist certain segments. Such piecemeal recovery is not true recovery of a species. Either the lower 48 grizzly bears are recovered or they are not. It was not appropriate for USFWS to carve out the Greater Yellowstone Ecosystem grizzlies to remove them from the Endangered Species Act's protection.
- Lack of connectivity to other grizzly populations is a long-term genetic risk for Yellowstone grizzlies. (Haroldson, M. A., C. C. Schwartz, K. C. Kendall, K. A. Gunther, D. S. Moody, K. Frey, and D. Paetkau. 2010. Genetic analysis of individual origins supports isolation of grizzly bears in the Greater Yellowstone Ecosystem. Ursus 21:1–13. BioOne). Idaho and Wyoming’s plans both appear to strongly disfavor reintroduction or facilitating recolonization. (Peer Reviewer #4, pgs 3, 4). Idaho’s plan “clearly states that moving grizzlies into new areas (e.g., Bitterroot) is prohibited and intentions to connect GYE bear populations to these unoccupied areas is vague.” (Peer Reviewer #4, pg 2). Montana’s plan to facilitate reconnection is extremely unclear with no details other than “to manage for discretionary mortality” and having “attractant storage rules”. (Peer Reviewer #4, pg 2). The isolation of this population is problematic for long-term genetic health, evolutionary potential and resilience to catastrophic environmental change. The best available science indicates that Yellowstone ecosystems should be connected with other populations prior to being removed from the protections of the Endangered Species Act.
- The gene pool for the Yellowstone ecosystem grizzly bears is too small and is disconnected from other grizzly populations. USFWS and the state fish and game departments have provided no plans to connect the Yellowstone grizzlies with other bear populations and dispersing individuals are subject to persecution, which means that connectivity is unlikely.
- Bears attempting to disperse would be subject to trophy hunting and/or removal due to hostile state management as well as habitat loss from human population and a changing climate. As a result, connecting the Yellowstone population to other grizzly populations is very unlikely and further balkanizes the population.
- USFWS needs to design and implement a recovery program that that ensures that grizzlies from the Greater Yellowstone Ecosystem and the Northern Continental Divide Ecosystem naturally colonize the Selway-Bitterroot ecosystem and the Cabinet-Yaak ecosystem. This will not happen with states managing Yellowstone area grizzlies and permitting a trophy hunt of these bears.
- Even though there is enough potential habitat available for grizzly bears, USFWS is limiting their recovery to a a mere 3% of their historic range. Grizzly populations cannot connect within this limited range and there is not an adequate representation of ecosystems within this range. Consequently, USFWS must rethink is decision to limit the standard of recover to a loss of 97% of historic grizzly bear distribution and numbers.
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