PUBLIC COMMENTS: Northern Cascades Bears 2019

Comments for the North Cascades Ecosystem Grizzly Bear Restoration Program are due OCTOBER 24.  There is one thing you can do that is more powerful than calling your representatives and it is leaving a public comment!  You need to have a United States city and state to comment.

Make sure that YOUR voice is heard (and the voices of friends and family whom you will hopefully encourage to also leave a comment). 

Please REWORD the talking points below when writing your comments into your own words. Please prepare your comments in a separate document and then copy and paste them into the National Park Service comments page.

Submit your comment in favor of Alternative C HERE.

TALKING POINTS:

• I write to ask the National Park Service to implement Alternative C which would incrementally restore grizzly bears to the North Cascades.
• Alternative C best balances the needs of people with the need for grizzly bear recovery.
• In addition to the bears added under Alternative C, bears should be added as is necessary to maintain genetic diversity and positive population growth.
• There are only around 10 grizzly bears left in the North Cascades. There is not enough connectivity for the population to access other bear populations. As a result, letting grizzlies repopulate the area naturally has not been successful. 
• If no action is taken and grizzlies are not purposefully restored to the North Cascades that population, which consists of only 10 or so bears, would likely go extinct.
• In addition to supporting Alternative C, I ask that the Service protect connectivity corridors. Linkage zones are essential for species recovery.
• I also ask that the Service considers introducing MORE bears than initially proposed to ensure successful restoration. An isolated population of 200 bears will not be viable. Instead, the Service should aim for a goal of 500 bears. 
• Further, I would ask that more recovery area be considered. It is well established that the larger the recovery area - for grizzlies - the more likely recovery will be successful.
• Bringing grizzly bears back to the North Cascades would enrich the ecosystem because these bears are both umbrella species and ecosystem engineers, positively impacting the health of many of the other species with which they share the ecosystem. These bears help regulate populations of elk, deer and the like as well as help fertilize the forests.
• There is no scientific or legal justification for the use of an “experimental non-essential” classification for an North Cascades Ecosystem population.   
• Special attention should be paid to roads, which increase conflict with grizzlies as well as mortality.
• The Service needs to come up with a better plan for reducing conflict with livestock operators and rancher compensation programs. 

For more talking points, look here. #BringBackTheGriz

PUBLIC COMMENTS to oppose baiting of grizzly bears in Wyoming - DUE AUGUST 20

The Wyoming Game and Fish Department is proposing a new regulation which authorizes that a grizzly bear, as a big game trophy animal, can be killed with special Kill Permits and Depredation Hunts, essentially as a “Predator”.

The comment period for this New Regulation, Chapter 28, is now. All comments must be submitted to the WGFD by August 20. This is related to the Chapter 68 Grizzly Bear Hunting Seasons, which the Governor signed into law in recent months. In Chapter 68, the Grizzly Bear Hunting Regulations, there is a section authorizing the baiting of the Grizzly Bear for Management Objectives or due to conflict. The section does not define conflict bear or management objectives. Do our two hunters with a camera allow an increase in their grizzly bear harvest? Now with this new regulation a bear can be baited and killed for getting into bee hives, as just one example of how the harvest of the Grizzly Bear is being expanded at this pivotal time. This requires attention and comment.

Please submit your comment online HERE.

SAMPLE COMMENT: I write to oppose Chapter 28 regulation for the reasons set forth below:

1) There are not been adequate public notice nor ability to comment on this regulation.  

2) Permitting the baiting of grizzly bears is inconsistent with the North American Model of Wildlife Management which requires "fair chase". Baiting is unethical and immoral and should not be allowed. It is also dangerous as it can create fights around bait sites between animals and could endanger humans who unknowingly happen upon a bait site.

3) With regard to item (z), there should be requirements for the maintenance and storage of "stored crops" as well as beehives to prevent bears from becoming habituated to human food.

4) With regard to item (ff), I object because it makes the grizzly a "predator" subject to depredation. Dan Thompson previously represented that the grizzly would never be considered a "predator" in 2016 when discussing the "Grizzly Bear Management Plan." Labeling the grizzly as a predator would all kill permits to be issued separate and in addition to the hunting quota.

5) There should be a requirement for landowners to show efforts to deter conflicts with grizzly bears prior to the issuance of a kill permit. It is essential to promote non-lethal deterrence efforts and co-existence.

For the reasons listed above, I object to Chapter 28 regulation and ask that the issues raised above be addressed and that an appropriate period for public comment be issued.

SAMPLE COMMENT: TALKING POINTS FOR DRAFT 6-27-18 - CHAPTER 28

REGULATION GOVERNING BIG GAME OR TROPHY GAME ANIMAL OR GAME BIRD OR GRAY WOLF DAMAGE CLAIMS

I Opposed and do not approve the CHAPTER 28 REGULATION IN TOTAL FOR THE FOLLOWING REASONS (Talking Points):

1. The regulation extends the Chapter 68 Grizzly Bear Hunting Seasons without adequate or appropriate public notice to participate and comment. I oppose that it is promulgated just weeks before the Grizzly Bear Trophy Hunt Commences on September 1 and it extends and expands the scope of the hunt, which was signed into law by the Governor just weeks ago.
2. I object to this extension of the hunting season to hunt aka slaughter the Grizzly Bear as “Predator” and for many reasons which include and are not limited to:
a. Dan Thompson, WGFD Large Carnivore Director promised the public at a full house in the Virginian Hotel in 2016 when discussing the “Grizzly Bear Management Plan” that the grizzly bear would never be hunted as “Predator”.
b. This new regulation expanding the hunt aka slaughter of the Grizzly Bear is too much too late. The lawsuits opposing de-listing the Grizzly Bear from ESA protections were on a briefing deadline which did not allow for a thorough examination of this newly proposed regulation published on July 9, 2018, the briefs due August 8, 2018. This was difficult if not impossible for the lawyers to address.
3. I object to this new regulation because item (k)- Damage is not clearly defined and vague on any legal meaning. And in particular as it related to Bee Hives. How, are the Bee Hives ordered to be maintained, to prevent depredation by a Grizzly Bear? I see no required electric fencing. This allows Bee Hives to serve as bait for a depredation hunt or special kill permit. I object to this proposed regulation in total an in particular Item (s)- “Want to kill a grizzly bear get a bee hive”. No.
4. I object to (q) and the definitions of improvements. The definition of structure is vague and it allows for a “kill permit” or “depredation hunt” of a Grizzly Bear and now with BAIT, with no real loss of any value to property! “Erect a shack, store grain carelessly and kill a grizzly bear”. No.
5. I further object to item (s)- I object to any kill permits for the Grizzly Bear. Chapter 68 has been passed and signed by the Governor into regulation to hunt the Grizzly Bear. This extension of the hunt is now illegal and in violation of your own Grizzly Bear Management Plan, the Wyoming Public Records Act, and your promises to the Public.
6. I object that this Kill Permit an include baiting a grizzly bear to be shot does not comport with the North American Model of Wildlife Management which Dan Thompson told us all at the Virginian guides is management. The North American Model requires “Fair Chase” as do most “hunters”. Montana does not allow bear baiting because it defies the requirement of “fair chase” in hunting practice. The Kill Permit is slaughter of the Grizzly Bear and for little cause. I object to this regulation.
7. I object to item (z) for the reason stated above in terms of bees and beehives and “stored crops”. What are the regulations for maintenance and storage so no bear is chummed to human contact and food rewards?
8. I object to item (dd) – “Accepted Agricultural Practices” is a meaningless term in Wyoming. Agricultural and ranchers can do whatever they choose and with the blessing of the WGFD. You admitted at the late spring public meeting on the increased wolf quota regulation than ranchers can bait wolves to be shot with dead cattle, even when adjacent to neighborhoods and with little regard what food reward that attracts the grizzly bear to eat. I object to item (dd).
9. I object to item (ff) because it makes the Grizzly Bear a predator subject to depredation and “kill permits” separate and in addition to the kill quotas in the hunting seasons.
10.

Section 4 (a):

I object to this section. This is a very vague and nebulous change from landowner to claimant. Define “Claimant”. If claimant and not landowner is only required for a depredation hunt an private land what business is that of the WGFD to make deals behind a land owners back or without the knowing consent of the land-owner. I object to this tactic as illegal and it expands the hunt of the Grizzly Bear by an unknown! Who is the “Claimant”?

Section 4 (b):

Same objection, I know of at least two ranches at issue in this regard for different reasons. The landowner approval for hunting on his/her land is legally responsible as they are liable for the actions and potential injuries on their land. You WGFD cannot be complicit with back dooring the landowner for your own gain or purpose.
Section 5:

Item (11)- Again Beehives are an issue as raised above and I object to this regulation

Section 7:

I object that a landowner must consent to a depredation hunt on his/her land in order to be compensated for legitimate loss due to depredation. This extends hunts illegally and manipulates the landowner unfairly. The public trust in management of our Natural Resources requires a fund which we the public shall fund and finance to reimburse landowners and not the forced agreement to hunting on their land.

There is no requirement in this regulation for deterrence first before a “kill permit” or Depredation hunt this is unconscionable for an agency first endowed with the privileged of managing the iconic grizzly bear and effective deterrence first is required in the Public Trust.

For all of this reasons I object to regulation 28 and I require the management of our natural resources in the Public Trust.

Public Comments: Oppose Road in Selkirk Mountains DUE JULY 16

Photo courtesy of USDA Forest Service

The US Forest Service is considering building a road for "national security" purposes through prime grizzly bear habitat in the Selkirk Mountains of northern Idaho. The road will be located approximately two miles from the Canadian border. 

Submit your public comments via email to SPWBogCreekEIS@cbp.dhs.gov no later than midnight EDT on July 16. 

WHAT TO SAY:

   - I oppose the plan to build the Bog Creek road. This road will be located in prime grizzly bear habitat. 

- Studies have repeated shown that building roads in grizzly bear habitat is extremely detrimental to grizzly bear population. A recent study by Clayton Lamb, from the University of Alberta, demonstrated that more roads equals fewer grizzly bears. Bears also tend to avoid habitats with roads through them.  Further, roads invite poachers into habitat, putting the recovering grizzly bear population and other wildlife at risk. 

- For these reasons, I oppose the construction of a national security road at Bog Creek. The construction and use would be too disruptive to the grizzly bears in the region.

PUBLIC COMMENTS: Oppose the IDAHO Trophy Hunt of Yellowstone Grizzlies by MAY 3

Please submit your public comments on Idaho through this form. Comments must be in by the close of business on May 3, 2018. 

What to say:

- Although Idaho was allocated less than one male bear, it has no safeguards in effect to ensure that a male bear is targeted - versus a female bear. Rather, there is 50/50 likelihood that a female bear will be killed. If this happens, Idaho will violate mortality limits in the hunting agreement between the three states in the region.

-  Idaho grizzly bears are especially important in establishing connections between the Greater Yellowstone ecosystem population and the bears of northern Montana and Idaho. Killing these bears in a trophy hunt would lead to further isolation and flat population growth of the Yellowstone population.

- Idaho should follow Montana's example and not trophy hunt its grizzly bears. Rather, Idaho should wait to gain the trust of the public and prove that it can manage its bears so soon after they have been removed from the federal Endangered Species list.

- Mortality due to human causes has been at an all time high and, as a result, the Yellowstone ecosystem population has not grown since the early 2000s. This, combined with the fact that grizzlies have a very slow reproductive rate means that killing bears, particularly females, can have a rapid, detrimental impact on the overall population. A trophy hunt this soon after removing the bears from the Endangered Species list would be reckless and threaten years of slow recovery.

HOW TO ANSWER THE QUESTIONS IN THE FORM:

The proposal is clear and understandable: select neutral or disagree
The proposal does not conflict with other hunting, fishing or trapping opportunities: select neutral or disagree
I support the proposal: select disagree
I would support the proposal if it met my concerns: select disagree

* There are a series of other questions at the very bottom of the form. Select neutral for all of those.


PETITION: Please sign and share.

Greater Yellowstone Coalition
One Protest

TWITTER: If you are on Twitter, please retweet:

https://twitter.com/dontdelistgrizz/status/990246878070521856

PUBLIC COMMENTS: Oppose the Wyoming Trophy Hunt of Yellowstone Grizzlies by APRIL 30

Public comments are due by 5pm Mountain Time on April 30, 2018 and may be submitted electronically. Submit an online comment here.  Please personalize your public comments using these talking points from Center for Biological Diversity.

CALL TO ACTION: Contact Wyoming Governor Mead to Oppose Grizzly Bear Trophy Hunt

Wyoming plans to allow the trophy hunting of 24 Yellowstone area grizzly bears this fall. Just a year ago, these bears were protected under the Endangered Species Act. The American people spent millions of dollars to bring this species back from the brink of extinction and now the state of Wyoming will earn a mere $46,800 to allow rich trophy hunters to kill them for fun. National Park bears can be killed as soon as they leave the safety of Yellowstone or Grand Teton National Parks.*

This is not a done deal, however. A recent study has indicated that wildlife watchers contributed greatly to the Wyoming economy. Indeed, wildlife watchers contribute 1.8 times the amount of hunters. The governor has shown that he is aware of the importance of wildlife watchers to the Wyoming economy through recent comments. Let us remind him of our contribution to the economy and how much wildlife watchers abhor the brutality of a trophy hunt of grizzly bears.

Please email, tweet, call, leave Facebook comments and share this post. Be heard. Stand up for grizzly bears.

EMAIL:

Use THIS FORM to email the Governor and let him know that you oppose a grizzly bear trophy hunt.  Please use your own (civil words), personalize the proposed comments below or copy and paste one of the comments below.

I write to oppose Wyoming's plans for a trophy sport hunt of grizzly bears. I have visited Yellowstone and Grand Teton National Parks. I visit primarily to view wildlife - especially grizzly bears! When I visited your state, I spent my tourism dollars at local businesses. I am so upset that Wyoming is not following Montana's lead and abstaining from a grizzly hunt. These majestic animals bring in millions of dollars to the tourism economy. They are important to wildlife watchers who, like me, come from all over the world to view them. Please re-think the planned hunt and cancel it! If not, I will make sure that the next time I visit the Yellowstone region, I stay in Montana. 

OR

I strongly oppose a trophy sport hunt of Yellowstone ecosystem grizzly bears. Bears that leave the national park and are the pillars of a billion dollar a year tourism industry could be shot and killed. This would negatively impact the tourism industry and reflect very poorly on Wyoming. The state of Montana has opted to refrain from such a hunt to gain the trust of the public after de-listing of this iconic species. Please consider doing the same and canceling plans for a hunt. 

PHONE CALLS:

Please call the Governor at 307-777-7434 and tell him that you oppose the planned grizzly bear hunt and you will spend your tourism dollars elsewhere if such a hunt goes forward.


TWITTER: 

.@GovMattMead Please call off Wyoming trophy hunt of Yellowstone grizzlies that leave safety of our national parks. 24 bears to be killed this fall! Wildlife watchers contribute 1.8x more to Wyoming's economy than hunters! Hear our voices! #NoGrizHunt pic.twitter.com/RbDdi5cBSh

Wildlife watching tourists contribute 1.8x as much as hunters to #Wyoming economy yet their voices are ignored as state preps for #TrophyHunting of grizzlies outside of #Yellowstone and #GrandTetons National Parks. #NoGrizHunt #ThatsWY @GovMattMead pic.twitter.com/sjkqVazmHU

#Wyoming to allow #TrophyHunting of grizzly bears that leave National Parks this fall! Even though wildlife watching tourists contribute 1.8x as much as hunters! 🐻💔 #ThatsWY #NoGrizHunt #Yellowstone #GrandTetons @GovMattMead pic.twitter.com/Khe9rGFnOW

FACEBOOK:

Leave a comment on Governor Matt Mead's Facebook page HERE asking that he call off the Fall grizzly bear trophy hunt. Leave a personalized comment as a reply to an existing post or copy and paste one of the following:

I have visited to Yellowstone and Grand Teton National Parks. I visit to view wildlife - especially grizzly bears! I am so upset that Wyoming is not following Montana's lead and abstaining from a trophy sport hunt of grizzly bears. These majestic animals bring in millions of dollars to the tourism economy. They are important to wildlife watchers who, like me, come from all over the world to view them. Please re-think the planned hunt and cancel it! 

OR

I strongly oppose a trophy sport hunt of Yellowstone ecosystem grizzly bears. Bears that leave the national park and are the pillars of a billion dollar a year tourism industry could be shot and killed. This would negatively impact the tourism industry and reflect very poorly on Wyoming. The state of Montana opted to refrain from such a hunt to gain the trust of the public after de-listing of this iconic species. Please consider doing the same and canceling plans for a hunt. 

* There is a small buffer zone on the East of Grand Teton national park and within a half mile of a highway.

PUBLIC COMMENTS DUE 1/26: NCDE Grizzly Habitat Conservation Plan

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.

PUBLIC COMMENTS DUE 1/8: Object to Cattle Grazing in Upper Green

Photo courtesy of US Forest Service

Oppose the plan to extend cattle grazing in the Bridger Teton National Forest. EMAIL COMMENTS TO: dbooth@fs.fed.us and objections-intermtn-regional-office@fs.fed.us prior to the close of business on January 8, 2018.

TALKING POINTS:

- I object to extend cattle grazing in a place where a national forest where wolves and grizzlies live and that native predators should be given priority. 

- Further, with so many cattle on the land, native prey are driven out. This means that native carnivores invariably turn to cattle for food.

- In particular, Upper Green is a hotspot for grizzly mortality. For instance, between 2011 and 2015, seventeen grizzlies were killed in response to livestock conflicts or 81% of all livestock-related lethal conflicts in the region. 

- Cattle grazing has a detrimental impact on riparian zones and native vegetation.

- As a result, I oppose extending grazing in Upper Green. 

- If grazing is extended, livestock operators must agree to employ a full panoply of non-lethal methods for deterring predators including but not limited to hiring range riders, using fox lights and cleaning up carcasses. Livestock operators should also be required to learn to use and carry bear pepper spray. 

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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