The letter below was written by Dr. Larry Irwin, a noted wildlife ecologist with 25+ years of experience.
On March 1, 1999 CAG talked to Dr. Irwin and asked the question; "Given the information that has been made available since you wrote this letter to Chris Servheen; are you of the opinion the proposed EIS has established there is quality grizzly bear habitat in the Bitterroot Selway Frank Church Wilderness?"
His response was,
This quote is taken from a letter written at about the same time by Dr. Irwin to Governor Racicot, "...I respectfully caution you not to place your faith in any conservation strategy based upon remotely-sensed maps. Such maps do not contain measures of the important resources discussed above..."
Senator Conrad Burns of Montana and Senator Larry Craig of Idaho were so concerned they made available $75,000 to either confirm or disprove the statement that ..remotely-sensed maps..provide a measure of "quality grizzly bear habitat."
The Grizzly Bear Reintroduction Committee (GBRC) used the money to hire a noted wildlife Biologist from Wisconsin to prove that remotely sensed map are a measure of "quality grizzly bear habitat."
While we do not profess to be scientists, it is beyond logic to use "remotely sensed maps" and their data to prove that "remotely sensed maps" and their data are valid. It is just beyond comprehension! Or is this arrogance on the part of the IGBRC?
If you wish to explore this issue further and you have access to the internet use the URL href=http://www.bitterroot.COM/grizzly"
End CAG Comments
Dear Chris:
Clearly, you and others who constructed the Grizzly Bear reintroduction strategy expended a great deal of effort and stoically withstood a great deal of verbal battering. I applaud your efforts and professionalism. My purpose herein is to provide some thoughts and suggestions that, if incorporated, could significantly strengthen the final EIS. As a professional wildlife ecologist for 25 years, I ask that you consider the attached technical comments regarding the possible reintroduction of Grizzly Bears into the Bitterroot Mountains of Idaho and Montana. I encourage those involved to weigh prudently the available scientific and technical information, as there are several topics at stake: important natural resources, socio-economic concerns, and the credibility of our profession.
COMMENTS ON THE DEIS FOR GRIZZLY BEAR RECOVERY IN THE BITTERROOT SELWAY FRANK CHURCH WILDERNESS
Hypothesis : The Bitterroot system contains high-quality habitat for Grizzly Bears.
If this premise were true, then the following predictions should also be true:
a. Black bears should be abundant throughout.
b. Grizzlies should not have been completely extirpated.
c. Grizzly Bear food supplies should be abundant and productive
Black bear as indicator--.
In the northern part of the Bitterroot Ecosystem, black bears are indeed common, and in fact, considered a nuisance in some quarters because they prey upon elk calves in spring. As one moves south from perhaps the mid-Selway River in Idaho, both the abundance and perhaps body size of black bears decline rapidly (Note: However, I have not seen data on age-specific body weights-the body size point is based only on observations and anecdotes). Such a cline is counter to the premise that the recovery area would also support good populations of Grizzlies, at least in the southern portions. It might strengthen the final EIS to provide a discussion of the likely interactions between black bears and grizzly bears.
Grizzlies should not have been extirpated completely--.
The comment is made in the DEIS that the Bitterroot Ecosystem is equally as good as similar environments in the intermountain region that currently contain Grizzly Bears. Perhaps that is so, but one should be cautious about the comparison because it cannot be stated that the populations in those adjacent areas are faring all that well.
Grizzly Bear food supplies should be abundant and productive.
The DEIS does not provide comfort that this is true. Recognize that, as a scientist, I was looking for data on this point. However, in fact, the DEIS is quite deficient on quantification of food supplies, indicating only that the appropriate vegetation types and known Grizzly Bear food plants are present in the BE. Short and Hestbeck (1995, Bioscience 45:535-539) pointed out that vegetation types, in particular, should not be so used to predict wildlife habitat quality-only the possibility that a species might be present. Likelihood of presence speaks nothing about habitat quality, and it's time that we quit doing this in wildlife management, in my opinion.
Similarly, the fact that Grizzly Bear foods are present says nothing about abundance and nutritional value, two topics for which the DEIS offers no information. It would be most helpful if the final EIS contains some quantification of food supplies that relate to habitat quality. My doctoral dissertation (1978) involved productivity of understory vegetation, among other topics, in an extensive study area that included much of the Bitterroot Ecosystem (BE). Clearly, the vegetation communities in the BE have changed significantly from the early seral communities that formerly produced large volumes of Grizzly Bear food plants-particularly berry-producing shrubs. Although it is true the appropriate plants still are present, the DEIS presents no information on the productivity of those plants-the latter is key to whether or not Grizzly Bears would increase in numbers to the goal if re-introduced. However, one could easily predict that food-plant productivity is low due to two points not mentioned in the DEIS.
First, advancing natural succession has caused forest vegetation to crowd out much of the understory shrubs. The DEIS should acknowledge the enormous changes that have occurred with succession following the great fire of 1910, and other fires in 1919 and 1931. The changes are manifest, in part, by the reduced calf productivity among Rocky Mountain elk in much of the proposed recovery area. Secondly, the dense ungulate population very likely has been equally or even more significant than succession in reducing Grizzly Bear food plant productivity in the Bitterroot Ecosystem, by eating important shrubs. Only recently have wildlife ecologists demonstrated that chronic disturbances such as herbivory by elk and other ungulates can have substantial, cascading effects on ecosystem productivity-effects that are larger over the long run, in fact, than episodic disturbances such as fire or logging. For example, the most recent issue of The Wildlife Society Bulletin was entirely devoted to the topic as it relates to overabundance of white-tailed deer, and Riggs et al. ("Modification of disturbance-adapted forests by ruminant herbivores in the Blue Mountains Ecological Province: implications for ecosystem management", submitted to Ecological Monographs) developed a similar perspective for herbivory by elk in intermountain forest ecosystems.
Further, the DEIS ignores the widespread invasion by noxious weeds into the Bitterroot Ecosystem. These plants have seriously reduced the quality of habitat for Grizzlies as well as other wildlife in parts of the recovery area. The EIS could mention the potential value of weed management strategies by the U.S. Forest Service.
Moreover, the DEIS acknowledges that anadromous fish are not expected to provide significant sources of food, if Grizzlies are reintroduced, but softens the significance by suggesting that interior populations of Grizzlies occur in a variety of areas where anadromous fish are not important food sources. In my opinion, the DEIS too readily dismisses the significance of a formerly abundant high-protein source that is functionally missing from an ecosystem that is inherently not very productive.
The final EIS should mention that much of the parent soil material in the Bitterroot Ecosystem derives from the granite dome known as the Idaho Batholith, which is known to be generally low in nutrients. Thus, the area is much less productive than the Bob Marshall, with its siltstone and limestone-based soils. Fish ecologists make the point that productivity of some interior systems is upheld by the anadromous fish that bring nutrients from the Pacific Ocean. How soon will the salmon recovery strategy begin to benefit Grizzlies? The DEIS devotes some space to another valuable Grizzly Bear food source, Whitebark pine nuts, acknowledging the widespread reductions in Whitebark pine due to blister rust, pine beetles, and fire preclusion. The DEIS notes the presence of Whitebark pine, but one wonders if the young pines produce significant cone crops. Are there any data on production of pine nuts? One wonders also about other foods, such as the huge colonies of army cutworm moths and ladybugs that Grizzlies are attracted to in sub-alpine boulder fields in places like the Mission Mountains. The DEIS makes no mention of these other food items, which might be affected significantly by pesticide applications in the valleys adjacent to the BE. One wonders if the 1997 black bear problems in the Flathead Valley (not to mention the news story of a Grizzly breaking into a vehicle this week) are related to relatively poor quality food supplies. Do these problems portend unhappy events for Grizzlies in the future?
Taken together, the points discussed above about habitat quality are quite distressing. More distressing to me is the attitude in the DEIS that, as long as large amounts of wild, isolated space are provided, the Grizzly Bear will do okay. Thus, because the DEIS fails to evaluate the quality of Grizzly Bear habitat, it therefore does not describe plans for any habitat management activities. Prescribed fire, vegetation manipulation, and yes, even judicious logging can improve Grizzly Bear habitat. Aldo Leopold in 1933 made it a point that the same factors that previously were used to destroy wildlife and their habitats can be used to produce them-ax, cow, plow, gun, and fire. Therefore, I challenge the notion that proper Grizzly Bear management should be predicated upon only two points: control of land use and control of mortality. The late Les Pengelly at the University of Montana often wrote a simple formula for wildlife population abundance on the blackboard: N = BP - ER, where N is population size, BP is biotic potential--the relative ability of populations to reproduce, and ER is environmental resistance-factors that decimate populations. The DEIS emphasizes only the ER part of the equation, the negative factors that keep populations low. I strongly encourage upgrading the final EIS by discussing the positive management factors that increase populations. This perspective also encourages the Service to consider sample-based estimates of habitat quality as opposed to map-based estimates of habitat quantity. I realize that the former cannot be undertaken before the final; for my tax dollars, I respectfully suggest that it be done if the decision is made to re-introduce Grizzly Bears into the Bitterroot Ecosystem. Toward that end, Page 1-16 suggests that monitoring movements and diets of Grizzlies would provide a more definitive answer to carrying capacity. Never in the history of wildlife management has such information provided a definitive, unequivocal answer, so why not do it right?