Public comments are due by 11:59 PM EDT on January 26, 2018. Please submit your comment HERE. Do NOT submit your comment on the blog as this is just for ideas for talking points. It needs to be submitted on the Federal Register to count.
Please re-state the following talking points, as much as possible, in your own words. We recommend composing these somewhere that they can be copied and pasted into the Federal Register. You should consider also copying and pasting them into an email to your Members of Congress, to a local newspaper for a Letter to the Editor, and anyone else who might listen.
TALKING POINTS:
Thank you for the opportunity to comment on Habitat-Based Recovery Criteria for the Northern Continental Divide Ecosystem Grizzly Bears ("HBRC").
- I strongly support NCDE grizzly bears remaining on the Endangered Species list and believe that grizzly bear habitat must be protected.
- The HBRC is outdated. It does not sufficiently address climate change. The changing climate is clearly impacting the NCDE as Glacier National Park has just 26 of its original 150 glaciers left. As the climate changes, NCDE wildlife - including the most charistmic grizzlies - will have to adapt. In addition to climate impacting food sources, we know that climate will affect grizzlies through drought and wildfires - both more prevalent. Because these risks to the NCDE grizzly population are not addressed in the HBRC, it should be revised.
- In addition, the HBRC does not sufficiently address risks to the NCDE population from human development trends in the region. "A recent federal Biological Assessment on grizzlies’ current situation in the Northern Continental Divide region (which covers wildlands stretching from the outskirts of Montana's state capital city, Helena, northward to the U.S.-Canada border) says the human population in Montana has also grown, and 'at a relatively high rate during the past few decades, and growth is expected to continue.'" (What do the Long-term Trends for Grizzlies in the Lower 48 Really Look Like?, Lance Olsen). As more people move into the region and as more people come in search of recreational opportunities we will see more habitat loss, more habitat fragmentation and more conflict between humans and grizzlies. HBRC does not account for these increased human pressures on grizzly bear habitat.
- The HBRC drops Amendment 19 habitat protect approach. Instead, it permits weaker standards that will allow more logging, roads and infrastructure developments which will fragment habitat. A recent study by Clayton Lamb, from the University of Alberta, demonstrated that more roads equals fewer grizzly bears. This makes clear that Amendment 19 must be retained and applied to national forests with grizzly bear habitat. It is not, Mr. Lamb's study proves that we will lose our grizzlies in these forests.
- Similarly, given the importance of roadless areas to grizzly bear populations, all existing roadless areas should be protected and those areas should remain free from motorized and mechanized transportation.
- Further, the NCDE ecosystem is not connected with the other lower 48 grizzly bear populations. True recovery cannot be considered complete when grizzly populations remain disconnected.
- Finally, as the decision in HSUS v. Zinke recently made clear, USFWS may not delist population segments by sub-ecosystems. Indeed, USFWS is being forced to revisit its erroneous decision to delist Yellowstone grizzlies and just finished accepting public comments on this topic earlier this month.
For the foregoing reasons, I believe that the HBRC is incomplete and outdated. It does not account for the changing climate and increasing pressure of human development and recreation on grizzly bear habitat. The HBRC needs to be revamped to sufficiently protected grizzly habitat to address these concerns and to link grizzly populations in the lower 48.
