September 30, 1997 RE: Grizzly Bear Recovery in the Bitterroot Ecosystem Draft Environmental Impact Statement.
CAG Comment
Steve Mealy of all people in western United States is most qualified to make recommendations about the reintroduction and introduction of grizzly bears into areas where they are not now present.
It has been the position of the USFWS to ignore his lifetime of work just because it doesn't fit in with the direction the administration is hoping the exploitation of grizzly bears will lead this great Nation.
End CAG Comments
John Burns, Chairman
Idaho Fish and Game Commission
Box 264
Carmen, ID 83462
Dear Commissioner Bums:
Idaho Department of Fish and Game (IDFG) staff have thoroughly reviewed the Grizzly Bear Recovery in the Bitterroot Ecosystem Draft Environmental Impact Statement (DEIS), and their concerns have been forwarded to me. Please share them with Fish and Game Commissioners.
The Special Rule (Appendix 13) identified the recovery area as consisting of approximately 5,785 square miles in the Selway-Bitterroot and Frank Church-River of No Return Wilderness areas. The Special Rule (last paragraph, page 6-116) states: "The recovery goal for the Bitterroot grizzly bear population would be consistent with the habitat available in the recovery area ..." The inference is that the recovery area is both necessary and sufficient for a minimum acceptable population of grizzly bears, since bears inhabiting the area outside the designated recovery area could be eliminated if they caused problems, in accordance with the Special Rule.
This DEIS must demonstrate that the recovery area is both necessary and sufficient for a minimum acceptable population of grizzly bears, based on scientific review of habitat and management data.
However, nowhere on pages 2-15, 2-16, 3-15, and 3-16 (or elsewhere in the DEIS) is information presented to show that the recovery area, exclusively, is sufficient to sustain a minimum acceptable population of grizzly bears.
Instead, the DEIS states on pages 2-15 and 2-16 that"... forested lands within the recovery area, and adjacent public lands is approximately 15,000 square miles. Together these areas are of sufficient size to allow for grizzly bear recovery."
The DEIS fails to present data that lead to such a conclusion even for the expanded, 15,000 square mile area. Rather, the DEIS draws on data referring to habitat suitability only in the 5,500 square mile Bitterroot Grizzly Bear Evaluation Area which includes only northern portions of the recovery area (portions of the Selway Bitterroot and Frank Church-River of No Return Wilderness north of the Salmon River); i.e., only one-third or less of an undefined 15,000 square mile area was evaluated relative to grizzly bear habitat suitability.
Further, no data on habitat suitability in those portions of the recovery area that lie south of the Salmon River in the Frank Church-River of No Return Wilderness is presented. The clear implication is that the identified 5,785 square mile recovery area may be insufficient to achieve grizzly bear population objectives, and as a result the expected necessary suitability of the area for recovery of grizzly bears is highly uncertain.
This point is further strengthened by the fact that the recovery area excludes a large area north of the Lochsa River evaluated b' Davis and Butterfield (1991) as suitable grizzly bear habitat and considered by many as superior. Further, it appears that the Proposed Action compromises requirements established by the Special rule for establishment of a nonessential experimental population.
The DEIS does not demonstrate that the recovery area can meet all conditions to assure that available habitats are necessary and sufficient to assure reestablishment of a grizzly bear population (as required by Special Rule); it also fails to assess the impact of reintroduction efforts on the bears themselves, particularly relative to habitat suitability including sufficient food resources to ensure survival of a reintroduced population, and therefore may jeopardize individual grizzly bears and grizzly bear recovery efforts.
The uncertainty introduced by these considerations precludes any meaningful assessment of environmental consequences of the Proposed Action, and no reasoned distinction among alternatives or environmental consequences appears possible.
These factors lead IDFG to conclude that this DEIS, and the Proposed Action in particular, are fundamentally and fatally flawed; i.e., biological data sufficient to demonstrate the suitability of the recovery area to meet objectives is not presented; impacts on the grizzly bear population to be established is not presented, and because of the resultant uncertainty, any grizzlies reintroduced to this area would be placed at high risk and the interest of grizzly bear recovery would be uncertain at best.
IDFG believes that prior to any Record of Decision, an adequate biological assessment of the proposed recovery area must be completed and subjected to peer review, and, further, that an objective analysis of the environmental consequences of the proposed action based on this revised assessment must be presented.
Major Conclusion 1:
IDFG urges the Service to immediately withdraw this DEIS from public comment since it lacks a scientifically valid evaluation of habitat suitability of the recovery area. A reliable assessment of environmental consequences is also lacking.
No consideration is provided in the DEIS to potential conflicts with salmon and steelhead recovery programs also being conducted within the area affected by the Proposed Action. Even though the risks of reintroduced grizzly bears to listed salmon and steelhead would likely be low, some risk would exist. In light of National Marine Fisheries Service NMFS decisions to issue no "incidental take" directives to many land management and land use projects and proposals affecting recovery area and nearby land, it can be presumed that the NMFS 'zero risk' approach to listed salmon and steelhead must be taken seriously.
Major Conclusion 2:
Any consideration of grizzly bear reintroduction should be ended until this apparent conflict is resolved.
IDFG strongly supports collaborative decision-making and compliments all who pursue it. However, the '10(j) rule' (Draft EIS Appendix 13) fails to guarantee that Idaho citizens would have real authority to strongly influence all important decisions regarding grizzly bear management in Idaho. This is borne out in the DEIS (page 6-117, paragraph 2): "... the Secretary, who necessarily retains final responsibility and authority for implementation of the Act, may find that the decision, plan, or implementation of a plan are inadequate for recovery and may resume management responsibility." This raises two critical issues: (1) if the delegation of authority is NOT real, then the entire concept of citizen management as represented in the DEIS is flawed, assumptions about citizens acting in their own best interests are suspect, and as a result there is a high degree of uncertainty about whether or not the intent of the Proposed Alternative could, or would be achieved, and (2) most of the environmental consequences in Chapter 4 are based on the premise that Citizen management Committee decisions in managing a nonessential experimental population would have minimal effects on human health and safety, land use activities, private property rights and management wildlife, public access, recreation, economic, and social activities. This all assumes that delegation of authority from the Secretary of Interior would be 'real.' If delegation of 'real' management authority does not occur, it is highly uncertain that the environmental consequences as identified in the DEIS are accurate. The net effect of these twin concerns is that, with uncertain environmental consequences, it is difficult or impossible to make reasoned judgments among alternatives and the fundamental intent of NEPA cannot be met with this DEIS.
Major Conclusion 3:
IDFG believes that any Citizen Management Committee should include IDFG and Idaho citizens with a 'real' delegation of authority regarding grizzly bear-related management in the Bitterroot ecosystem.
IDFG is concerned that the Service, if it should select an action alternative, may take actions that financially obligate the State of Idaho without a commitment to provision of funds necessary to finance those actions. This concern is based on recent (and ongoing) experience with wolf reintroduction into Idaho and with other listed species.
Major Conclusion 4:
IDFG urges the Service to withdraw the DEIS from public comment until it can provide assurances that the State of Idaho would be provided with funding sufficient to conduct all necessary monitoring and all necessary management actions in both the short and long terms.
It is inappropriate that grizzly bears moved from another grizzly bear recovery area (i.e.. the Northern Continental Divide or Yellowstone Ecosystems) should be counted as 'moralities' against the recovery of grizzly bears in those ecosystems. If such bears are surplus to population recovery objectives, they should not be counted as moralities against recovery; if they are not surplus to recovery needs, they should not be subjected to the risks of trans location.
Major Conclusion 5:
IDFG opposes any proposal that would allow the Bitterroot ecosystem to be used as a depository for problem grizzly bears, or which would allow any transplant of bears from populations wherein recovery goals have not been met.
Cost benefit analyses presented in this DEIS confuse the reader by mixing real-dollar economic impacts to the region with hypothetical 'willingness to pay' welfare statistics as used by Duffield and others (DEIS, pages 4-19 through 4-23). The effect of confounding real-market economic measures with hypothetical 'willingness-to-pay' measures is to confuse real-dollar economic measures with some unfounded measure of perceived social good; i.e., offsetting real out o pocket costs against a percentage of what some sample of the population at large tells someone they are willing to pay, knowing full well that they will never, in fact, have to actually pay anything to anyone (see Table 4-5; note especially footnotes c and d). This approach yields fantastic estimates of benefits ($166,553,834 nationally; see Table 4-5) by extrapolation to a huge population. Critics have identified that 'willingness~to~pay' is not a true economic measure, since (1) no real dollars are exchanged, (2) there is no market, and (3) there is no measurable economic impact. Readers of this DEIS deserve an opportunity to estimate accurately the market-based economic impact of this proposed action on local economies.
Major Conclusion 6:
Any economic analysis must be a true analysis of the Proposed Action based on real-dollar economic impacts as measured in the marketplace; 'willingness to pay' statistics must be identified as non market indices of the social desires of only some segments of the population.
Finally, the IDFG would only support a new and different alternative. IDFG believes that grizzly bear occurrence in the Bitterroot Ecosystem should result from natural dispersal and that if it takes place, it should be in a management framework in which IDFG and Idaho citizens actively and fully participate in all important bear management decisions, and have 'real' authority to make decisions appropriate to grizzly bear recovery. Major Conclusion 7:
IDFG will support only an alternative that features natural recovery of grizzly bears in the Bitterroot ecosystem under the management of a 'real' Citizen Management Committee, thus incorporating features of Alternative 1 (without reintroduction of bears) and Alternative 2.
In closing, IDFG supports the Commission's official position on grizzly bear reintroduction, which states:
The Commission reaffirms its unequivocal opposition to reintroduction of grizzly bears into Idaho. The Department will continue to participate in the Grizzly Bear Oversight Committee process established by the Idaho Legislature, and in other grizzly bear related activities that could affect Department programs. The Commission and Department will oppose any actions that allow grizzly bear recovery to significantly interfere with hunting or fishing opportunities in Idaho. [Approved and adopted by the Idaho. Fish and Game Commission on May 8, 1997.]
Sincerely,
Stephen P. Mealey, Director
Idaho Department of Fish and Game
RETURN