The fact is that the delisting plan formulated by the FWS contains no habitat protections for over 3 million acres of currently occupied habitat – a landscape larger than the size of Yellowstone National Park -- not to mention additional habitat that is needed to compensate for impacts from climate change and to connect the long-isolated Yellowstone grizzlies to more robust populations to the north. Much of this habitat is open to development in current National Forest Plans, and human pressures are mounting. Further, governmental agencies are under the gun to approve development regardless of the consequences.      

 

At the heart of the problem lies a failure by the FWS to address recovery at the scale of the lands that bears use, not at a scale that is deemed to be politically convenient.  The agency’s approach to grizzly bears stands in stark contrast to that taken by the government when managing every other wildlife species in the Northern Rockies—including deer, elk, moose, mountain lions, and black bears.

 

The Problem of the Primary Conservation Area

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The FWS argued that the Primary Conservation Area (PCA), formerly known as the Recovery Area, is adequate to maintain a recovered grizzly bear population and is based on a legitimate scientific analysis. Nothing could be further from the truth. This area is the by-product of historical accident and political compromise.

 

Here is a brief history. The US Fish and Wildlife Service drew this 9,200 square mile area in 1979 and adopted it in the 1982 Grizzly Bear Recovery Plan, and then again in the 1992 revised plan, with only modest modifications. More on the changes later.

 

As the 1982 Plan admits, the original boundaries were based on a crude, inadequately informed, and disputed assessment of the current range of grizzly bears in 1979, with the desired goal of providing habitat for merely 229 bears. 

 

Claiming that any mammal population could be considered recovered at 229 individuals would not pass the scientific laugh test today. Underscoring this point, the FWS recently bragged in the media how far they have come advancing recovery from a problematic low point of 200 or fewer grizzly bears in the late 1970s (link).   

 

Ironically, the PCA boundaries were drawn just four years after the population was listed under the Endangered Species Act (ESA), when it was perhaps at its lowest ebb ever. Closure of Yellowstone Park garbage dumps just nine years before had precipitated the crisis. Officials killed hundreds of garbage-conditioned bears that sought food in campsites and residences throughout the ecosystem.

 

The line was also drawn so as to exclude private lands wherever possible, and avoid controversy, despite the fact that the ESA requires the use of the best available science and that grizzly bears cannot read maps.

 

What became the PCA boundary was sketched out at a 1979 workshop of grizzly bear scientists. But, importantly, the experts could not agree on a line. Nonetheless, the FWS used the draft area for the purposes of developing the 1982 Recovery Plan, with the idea it would be the starting point for further conversations and refinements. These never occurred in any meaningful or comprehensive way, despite enormous gains in knowledge over the intervening years about bear ecology, human-bear relations, and bear movements.  

 

A Better Approach to Recovery than the PCA

 

As soon as the PCA was drafted, scientists began pointing out the problems (link). The biggest was that with grizzly bears, the FWS was trying to recover the species within an artificial boundary that did not, even then, reflect where bears lived or wilderness habitat that bears have increasingly come to rely on (link).

 

Over time, the call by endangered species and grizzly bears experts for protection of more bears in more areas has become ever louder. In response to mounting concern about the century-long isolation of Yellowstone bears, scientists began to emphasize the importance of expanding and re-connecting grizzly bear populations in the Northern Rockies.    

 

By the 1990’s, models and maps were being published in the scientific literature that showed the connecting landscapes where this was still possible (link). Better science is available today and it all underscores the need to redefine recovery goals from a few hundred bears in isolation from each other, to a meta-population of a few thousand connected bears (link), (link), (link), (link). It shows that we can achieve a connected, recovered bear population with existing suitable habitat in the region, in combination with better coexistence practices.  

 

But in the face of still-increasing scientific evidence that bears need more, protected habitat, FWS clung with a death grip to the past. In 1995, the agency lost a lawsuit brought by environmentalists challenging the adequacy of its grizzly bear recovery plan, in part based on the FWS’s failure to provide the habitat protections needed to support numerical recovery goals in the 1992 recovery plan—notably, the only lawsuit of this nature to succeed. Then and since, FWS has had numerous opportunities to replace its obsolete and unjustified delineations of the recovery area, or PCA, with something far better. But it has not. Why?

 

FWS as Willing Hostage to the PCA line

 

Simply put, the FWS became hostage to the PCA line that it drew in 1979. More fundamentally, the agency became a willing prisoner of the state game agencies it was intended to regulate, and thus reluctant to follow its legal mandate to use the best available science. The states and industry bridled at prospects of expanding a line that they feared would be accompanied by limits on development, so the line hardly budged over the years, even though the distribution of grizzly bears expanded substantially. “We will not move the goalposts of recovery” became the FWS mantra.

 

But that did not stop the FWS from changing other goalposts to suit its purposes. It made some relatively small adjustments here and there over the years, in areas that were politically non-controversial, eventually adding 8% to the size of the PCA.

 

But then the agency more than doubled the numerical recovery goal in the 1992 Recovery Plan for the grizzly bear population from 229 to 500-600 bears, claiming these higher numbers could be maintained exclusively within the bounds of lines drawn in 1979 for a population of half this size. Huh? What kind of scientific hocus pocus is this? What happened here is that newer science prompted the FWS to support a higher numerical recovery target, but the agency refused to expand the PCA for fear of political resistance from the states and industry.  And they thought that no one would notice its little math problem, that it was trying to justify doubling the number of bears on just about the same amount of land as they said could be supported a decade before.    

 

The FWS has confused the issue of boundaries further with the recent creation of the Demographic Monitoring Area (DMA). The DMA is significantly larger than the PCA, and is meant to demark a larger boundary for counting bears, not protecting or monitoring habitat.  One big reason for this change is to track bears that have moved far outside the PCA. This change further underscores the problem of the PCA itself…

 

Why not adopt one boundary for management and monitoring that reflects the reality of where bears are ranging and what they need for long-term viability? Because that would make everyone face the bear truth, which would, in turn, require FWS to upset today’s political status quo at the very moment when the FWS’s chief bureaucrats (mostly Safari Club bedfellows) are pushing for delisting.       

 

The Bear Truth Has Changed, but the Recovery Line Has Not

 

Yellowstone grizzly bears occupy a landscape that is roughly 50% larger than the PCA.  But, the delisting plan only protect lands (feebly so) inside the PCA and otherwise ignores additional habitat that is vital to maintaining a recovered population.   

 

FWS is so desperate to appease the conservative politicians and CEOs of extractive industry (need we distinguish the two?) that is refuses to move the PCA line, require any additional habitat protections, or ensure federal oversight of decisions about development on public lands. More overtly, in the recent proposal to delist Yellowstone’s grizzly bears, the agency baldy asserts that the paltry plans recently fielded by the states are sufficient to protect bears that venture outside the PCA. But state wildlife management agencies not only lack authority over public lands, but also sport a culture that is hostile to any animal with canines.  They can only advise land managers (assuming they would want to), and see the solution to most of their management problems in terms of killing carnivores—such as grizzly bears.

 

State plans provide no assurance that Wyoming, Montana, or Idaho have any intention of allowing grizzly bears to expand very far beyond the PCA into productive secure habitat, such as the Wind River and Wyoming Ranges. In the states’ comments on the delisting proposal, the states lobbied FWS to eliminate virtually ALL post-delisting management and oversight requirements (link).

 

Furthermore, Idaho’s plan seems unlikely to welcome grizzly bears in the Snake River or Caribou Ranges, much less the south side of the Centennial Mountains, a key connecting landscape to other grizzly bear populations.  The recent track record of state officials offing grizzly bears with few offenses (link) and promising to use hunting to purposefully reduce bear numbers in some areas, indicate a fundamental hostility towards grizzly bears that will be unleashed after delisting.  

 

Meanwhile, the Forest Service has failed to step up to provide essential habitat protections.  Which gets to a still-relevant report written by Jon Langer in 2004 on threats to grizzly bear habitat managed by the Forest Service in the Yellowstone ecosystem (link). 

 

The Langer Analysis of Vulnerable Forest Lands in Grizzly Bear Habitat

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While working for the Natural Resources Defense Council (NRDC), Jon exhaustively analyzed threats to grizzly bear habitat in Greater Yellowstone National Forests using raw data provided from the US Forest Service itself.

  

Langer used a map of grizzly bear distribution circa 2000 from the Interagency Grizzly Bear Study Team showing that grizzly bears then occupied 1.8 million acres outside of the PCA (link). (Bears have moved further outside the PCA since then, as discussed below).

 

Of that 1.8-million acres, roughly 470,000 acres, or 26%, is federally protected Wilderness.  In other words, only one quarter of the land occupied by bears outside the PCA circa 2000 has secure legal protections.

 

Langer examined all National Forest lands occupied by grizzlies (circa 2000) that, according to prescriptions in existing Forest Plans, had either been and developed, or were open to road-building, energy, logging or other development.  The results do not bode well for the future of grizzly bears in the Greater Yellowstone Ecosystem.

 

Approximately 1.2 million acres of occupied habitat outside of the PCA is available for development.  Fully 65% of the fortuitously secure habitat that allowed grizzly numbers to reach their 2000 level could be lost under current Forest Plans.

 

The Forest Service did pick at some nits of the Langer report, but did not contest the basic facts. Interestingly, the recently retired FWS Grizzly Bear Recovery Coordinator, Chris Servheen, known for his mean streak, lashed out at the Forest Service employee who gave Jon the data, a predicable complaint from a man who fought for decades to keep all data related to grizzly bears out of public hands. But the report has held up as accurate and credible. 

 

It should be noted that Forest Plans have hardly changed since 2004 when Langer did his analysis. Also, as grizzly bears have continued to expand since then, partly as a result of climate change and the collapse of key foods, the amount of occupied habitat that is vulnerable to development has also grown. Without doing the kind of detailed analysis that Langer did, it is clear from the most current and accurate map of grizzly bear distribution (link) that over 3 million acres of occupied grizzly bear habitat on public lands are open to development.

 

Importantly, since forest planning rules are now "aspirational" rather than "prescriptive," nothing in plans bind the agency to pursue even a modicum of protections. Under pressure from industry, any undeveloped habitat is vulnerable to exploitation. In other words, any lands that are not officially designated Wilderness are available for the kinds of development that are known to harm bears – roads, clearcutting, oil and gas drilling, industrial scale development, mining, off road vehicle use, and grazing.

 

And the problem does not stop here. In 2003, Dr. David Mattson and Troy Merrill conducted an analysis of habitat suitable for grizzly bears in the Yellowstone ecosystem and beyond (link). These lands are increasingly important to bears as they are forced to adapt to a changing climate and as historically critical foods collapse. Using this analysis, Langer went further to show that roughly 4 million acres of suitable habitat that was not occupied (as of 2000) are available to oil and gas and other development. Domestic sheep graze on over 1.3 million acres of suitable grizzly bear habitat, and over 3 million acres are open to timber harvest and roadbuilding. 

 

And the FWS response to these threats is…

 

Sit Back and Watch the Ship Sink

 

At best, the FWS offers a corrective to these threats that entails nothing more than monitoring population size and mortality rates using biased and otherwise unreliable methods. Aside from intrinsic problems, such monitoring also debars any prospect of anticipating and reversing responses of the population to deteriorating habitat conditions, whether inside or outside of the PCA.

 

Further, scientists have shown that such responses are likely to be inherently lagged, by decades or more (link). So any response by the FWS are likely to be too little, too late —assuming the agency has the courage to intervene against states that would be undoubtedly hostile after federal authority has been turned over to the states post-delisting.

 

Moreover, the FWS’s underlying logic is fundamentally flawed. It presumes to monitor population size over the full extent of the DMA as a primary means of judging on-going recovery of Yellowstone’s grizzly bear population, while at the same time only explicitly providing for habitat protections within the much smaller PCA. 

 

Removing Endangered Species protection for the Yellowstone’s grizzly bears without any assurance that a large portion of their habitat will remain protected for them is negligent, and risks putting grizzly bears back on track for extirpation.

 

An Alternative

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And there is a better way. As scientists have long recommended, the government can start by protecting bears and their habitat where they are and where they can be expected to be. That means all occupied, suitable habitat and all lands within the DMA.

 

A few basics: protect every existing roadless area. Expand current programs that foster coexistence between bears and people. Increase law enforcement efforts, which the FWS itself has flagged as essential to reducing mortalities. Involve the tribes that own or have claims to critical habitat in efforts to co-manage and recover grizzly bears. Systematically squeeze the lessons from both successes and failures. 

 

Stop deceiving the public – they are smarter than you think. Improve the decision-making process, and make democracy work for the broader public, not a hostile, loud minority of hunters who want to kill grizzlies for crass gratification of their frail egos.  

 

The grizzly bear deserves our compassion and wisdom, not political games based on arbitrary lines. 

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