PUBLIC COMMENTS DUE 1/8: ReList the Yellowstone Grizzly Bear

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.

PLEASE SIGN AND SHARE:

Center for Biological Diversity
National Parks Conversation Association

PUBLIC COMMENTS DUE 12/14: Save Grizzly Habitat in Shoshone National Forest

Shoshone National Forest plans log about 2000 acres along nine miles of the scenic Chief Joseph Highway between Cody, Wyoming and Cooke City, Montana, including part of a roadless area. This is in prime grizzly bear habitat and studies have recently drive home the importance of maintaining roadless areas for grizzly bears. 

PUBLIC COMMENTS DUE BY DECEMBER 14. Please submit your comments to the following email address: otroxel@fs.fed.us

Olga Troxel, Team Leader
Wapiti Ranger District

TALKING POINTS - please re-word these as much as possible in YOUR OWN WORDS. 

- Thank you for the opportunity to submit public comment on the plan to log 2000 acres of Chief Joseph Scenic Highway between Cody, Wyoming and Cooke City, Montana.

- I oppose the proposed logging plan because I am concerned as to how it will impact grizzly bears. This is prime grizzly bear habitat yet logging in the area will require the introduction of roads. I understand that the roads will be "temporary" but certainly poachers and hunters will find and use these roads during this time period and beyond. Further, studies demonstrate the importance of roadless areas for grizzly bears. They simply do not adapt to wildlife crossings and the like. Instead, we need to maintain as much of our existing roadless habitat as possible. 

- Justification for the planned logging is to prevent a wildfire in the area, to protect some second homes in that area. Studies however demonstrate that removal of fuels more than a few hundred feet is all that is necessary to safeguard homes. I urge the Forest Service to undertake this much less drastic measure of clearing space around structures,  instead of the plan to log 2000 acres. This would have a less deleterious impact on wildlife and habitat. 

- I also object to the plan on the basis of removing dead trees. It is well established that dead trees are a critical part of a healthy ecosystem. First, dead trees are less flammable than live trees. Second, dead trees are important for the storage of carbon - increasingly important in our changing climate. Third, as many as 2/3 of all wildlife species depend on dead trees at some point in their lives. Unnecessarily clearing dead trees obliterates habitat for mammals, insects and birds. Snags are important structural components in a forest. On to the forest floor, dead trees provide habitat for everything from insects to mammals. When dead trees fall into streams, they provide important fish habitat. Removing dead trees upends the ecosystem for no good reason. 

- For the foregoing reasons I oppose the plan to log in the Chief Joseph Scenic Highway. 

FOR ADDITIONAL TALKING POINTS, please see this article. 

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