Grizzly bear recovery plan

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Grizzly Bear

Recovery Plan

rTKTE DOCUMCTTS C9UECTKW

JUL 2 5 1983

MONTANA STATE LIBRARY

1515 E. 6th AVE.
HELENA, MONTANA 59620

This is an animal that cannot compromise or adjust its way
of liie to ours. Could not by its very nature, could not
even if we allowed it the opportunity , which we did not.
For the grizzly bear there is no freedom but that of unbounded
space, no life except its own. Without meekness, without a
sign of humility, it has refused to accept our idea of what
the world should be like. If we succeed in preserving the
wild remnant that still survives , the glory will rest primarily
on this bear whose stubborn vigor has kept it alive in the face
of increasing and seemingly hopeless odds.

-adapted from Robert Porter Allen

GRIZZLY BEAR
RECOVERY PLAN

Prepared by the

U.S. Fish and Wildlife Service in cooperation with the Recovery
Plan Leader, Don L. Brown, Montana Department of Fish, Wildlife,
and Parks.

APPROVED

DATE: JAN 29 1982

U.S. Fish and Wildlife Service:

This is the completed grizzly Bear Recovery Plan. It has been approved
by the U.S. Fish and Wildlife Service. It does not necessarily represent
official positions or approvals of cooperating agencies (and it does not
necessarily represent the views of all individuals) involved in preparing
this plan. This plan is subject to modification as dictated by new findings
and changes in species status and completion of tasks described in the plan.
Goals and objectives will be attained and funds expended contingent upon
appropriations, priorities, and other budgetary constraints.

Acknowledgements should read as follows:

The Grizzly Bear Recovery Plan, dated January 29, 1982, prepared by the U.S.
Fish and Wildlife Service in cooperation with the Recovery Plan Leader,
Don L. Brown, Montana Department of Fish, Wildlife, and Parks, under Coop-
erative Agreement No. 14-16-0006-80-923.

Additional copies may be obtained from:

Fish and Wildlife Reference Service
Unit i

3840 York Street
Denver, Colorado 80205
Telephone: 303/571-4656

Copies of the "Guidelines for Management Involving Grizzly Bears
in the Greater Yellowstone Area" referenced in this plan may be
obtained from:

Fish and Wildlife Reference Service
Unit i

3840 York Street
Denver, Colorado 80205
Telephone: 303/571-4656

or

U.S. Forest Service
Rocky Mountain Region
Box 25127

Denver, Colorado 80225
Telephone: 303/234-4011

DOCUMENT PREPARATION

This plan is the result of the efforts of many individuals and agencies
with expertise and responsibilities related to grizzly bears and their
mangaement. Planning and conduct of workshops, editing and writing, and
collation of data and other information were done by Don L. Brown, Grizzly
Bear Recovery Plan Leader, Montana Department of Fish, Wildlife and Parks
who, through an Interagency Personnel Assignment, was funded by and
responsible to the U.S. Fish and Wildlife Service. Principal planning
support was provided by Stephen P. Mealey, U.S. Forest Service, Rocky
Mountain Region, who contributed 20 working days to the effort. Major
contributions were in the areas of conceptual design and organization,
grizzly bear ecology and grizzly bear management guidelines. Primary
support, also in the areas of plan design and formulation, was provided by
John Weaver, U.S. Forest Service, and Wayne G. Brewster, U.S. Fish and
Wildlife Service. Other individuals and agencies making significant
contributions were John and Frank Craighead, Richard Knight, Charles
Jonkel, the Interagency Grizzly Bear Study Team and members of the Border
Grizzly Project. Substantial assistance and support was also provided by
Regions 1 and 4 of the U.S. Forest Service, the National Park Service, the
U.S. Fish and Wildlife Service, the Bureau of Land Management, the state
wildlife agencies of Idaho, Montana, Wyoming and Washington, and personnel
of the Canadian Wildlife Service and British Columbia Wildlife Division.

PREFACE

The grizzly bear is a symbolic and living embodiment of
wild nature uncontrolled by man. Entering into grizzly
country presents a unigue opportunity - to be part of an
ecosystem in which man is not necessarily the dominant species
(Herrero 1970).

Under authority of the Endangered Species Act (ESA) , the grizzly bear
(Ursus arctos horribilis) was listed as a threatened species by the United
States Fish and Wildlife Service in 1975. In 1979 a decision was made to
prepare a Grizzly Bear Recovery Plan (GBRP) and a plan leader was
appointed. The charge was to devise a plan that would provide
recommendations and actions necessary for the maintenance, enhancement and
recovery of this species in the conterminous 48 states.

The recovery plan leader met with persons interested in or working on
grizzlies through a series of nine general meetings and a multitude of
personal contacts and telephone conversations. The information contained
in this plan is the result of those meetings. It attempts to present a
biologically sound program that will result in the recovery of the species
and its habitat to a level that will no longer require protection under the
Endangered Species Act.

TABLE OF CONTENTS

PAGE

Document Preparation • -ii-

Preface -iii-
PART I

Introduction 1

Perspective 2

History 7

Pysical Characteristics 7

Social Organization and Behavior 8

Past Distribution 9

Current Distribution/Status 10

Corridors 13

Population Characteristics 15

Density 15

Home Ranges 16

Age and Sex Structure 18

Natality 19

Mortality 21

Natural Mortality 21

Man Caused Mortality 22

Habitat Conditions 24

Food 24

Cover 26

Denning 27

Legal Status 28

PART II

Recovery Plan Outline 31

Abbreviated Step-down Outline 33

Recovery Plan (Yellowstone) 36

Footnotes (Yellowstone) 55

Recovery Plan (Northern Continental Divide) 59

Footnotes (Northern Continental Divide) 80

Recovery Plan (Cabinet-Yaak) 82

Recovery Plan (Selkirk Mountains, Selway-

Bitterroot, North Cascades) 102

LITERATURE CITED 105

PART III

Job Implementation and Budget and Agency 117

Abbreviations 118
Summarized by Job and Priority For:

YGBE 120

NCDGBE 135

CYGBE 152

SM, SB, and NCGBE's 164

- iv -

APPENDIX A

Computer Modeling

APPENDIX B

Comments by Agency on Review Draft

APPENDIX C

Responses to Agencies on Review Draft

LIST OF TABLES AND FIGURES
Tables

1 Estimated Densities

2 Stratification and Management YGBE

3 Stratification and Management NCDGBE

4 Stratification and Management CYGBE
Figures

1 Past Distribution

2 Present Grizzly Bear Ecosystem

3 YGBE Map

4 NCDGBE and CYGBE Map

5 SMGBE

6 SBGBE

7 NCGBE

8 Grizzly Bear Distribution Map
(Canada)

PAGE
166
168
189

17
48
74
94

11
14
35
58
99
100
101
104

- v -

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in 2013

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PART I

INTRODUCTION

The goal of the recovery plan is to identify actions necessary
for the conservation and recovery of the grizzly bear. The species
was listed as "threatened" in 1975 purusant to the Endangered Species
Act of 1973 (ESA 1973) (87 stat 884, 16 U.S.C. 1531-1543). A threatened
species is defined as one which is likely to become an endangered species
within the foreseeable future throughout all or a significant portion of
its range (ESA 1973).

The Endangered Species Act (ESA) clearly states the purposes of the Act
are to provide a means whereby the ecosystems upon which endangered and
threatened species depend may be conserved. Conserve, conserving, and
conservation are defined within the act as — to use and the use of all
methods and procedures which are necessary to bring any endangered or
threatened species to a point at which the measures pursuant to this
act are no longer necessary. "Such methods and procedures include, but
are not limited to, all activities associated with scientific resources
management such as research, census, law enforcement, habitat acquisition
and maintenance, propagation, live trapping, and transplantation, and in
the extraordinary case where population pressures within a given ecosystem
cannot be otherwise relieved, may include regulated taking (ESA 1973)."

Therefore, this plan attempts to provide a sequence of actions
necessary for the conservation and recovery of the grizzly bear in
selected areas of the conterminous 48 states.

Objectives are: 1) Identify grizzly bear population goals that
represent species recovery in measurable and quantifiable terms for
the several regions that were determined to have suitable habitat for
such populations, and to provide a data base that will allow informed
decisions. 2) Identify population and habitat limiting factors that
account for current populations existing at levels requiring threatened
status under ESA. 3) Identify specific management measures needed to
remove population limiting factors that will allow the populations to
increase or sustain themselves at levels identified in the recovery
goals. 4) Establish recovery of at least three populations in three
distinct grizzly bear ecosystems in order to delist the species in
the conterminous 48 states.

The plan addresses six areas in the conterminous 48 states where
grizzly bears are known to have been present during the past decade.
These six grizzly bear ecosystems appear to presently have adequate
space and suitable habitat to offer the potential for securing and
restoring this species as a viable self-sustaining member of each
ecosystem.

-1-

The question of how many grizzly populations are needed for
recovery of the species was debated repeatedly at the various meetings
and workshops. No one would recommend a single population in a single
ecosystem as being adequate to provide a reasonable margin of safety
against what Shaffer (1978) described as "systematic pressures and
stochastic perturbations." Several persons thought all known areas
containing grizzlies were necessary for recovery and believed the ESA
mandated such action. However, a majority of those in attendance
shared the opinion that it was impractical to assume that all six
identified populations could be recovered and they believe the
recovery plan should concentrate primarily on only three populations;
those in the Yellowstone Grizzly Bear Ecoystem (YGBE) , the Northern
Continental Divide Grizzly Bear Ecosystem (NCDGBE) and the
Cabinet-Yaak Grizzly Bear Ecosystem (CYGBE).

The YGBE was chosen because of the research data collected over
the past two decades, a current ongoing program and an estimated
population of several hundred grizzly bears.

The NCDGBE was selected because the Border Grizzly Project is
currently collecting data in this ecosystem and it too has a
substantial bear population.

The CYGBE was chosen because it ranked third in areas where data
had been collected and currently has^research projects planned and
funded .

Bear biologists and land managers believe these three major areas
should be selected as areas of first priority a^nd funding sought to
provide for the tenets of the recovery plan. If additional funding is
available, preliminary surveys in the Selkirk Mountains Grizzly Bear
Ecosystem (SMGBE) , the Selway-Bitterroot Grizzly Bear Ecosystem
(SBGBE) and the North Cascades Grizzly Bear Ecosystem (NCGBE) are
recommended in that order.

This plan is not intended to be an optimum grizzly bear
management plan, but rather outlines steps necessary to ensure
recovery of the species in the lower 48 states. The conservation and
recovery of three populations, as opposed to only one or two
populations, is believed necessary to assure perpetuation of the
species to a point that no longer requires the protection of the ESA.
During the recovery process the protective provisions afforded a
listed species apply to grizzly bears wherever they occur in the
conterminous states.

PERSPECTIVE

Recovery of the grizzly bear will be a long-term proposition.
Ultimately it should provide viable, self-sustaining populations in
perpetuity. Researchers have realized reasonable successes in
determining food habits, general habitat use, movements, mortality,
etc. for this species. Less success has been achieved in developing

-2-

techniques to determine densities or total numbers of bears in these
large ecosystems.

Population parameters or their biological equivalents necessary
for recovery have been identified for the YGBE, NCDGBE and CYGBE .
Recovery actions are defined for each of these populations. Population
parameters or their biological equivalents for grizzly bear recovery
in the SMGBE , SBGBE and NCGBE are undetermined. The plan outlines
management options for each of these populations and the initial steps
that will be required to effect recovery.

The general priority for effort should be YGBE, NCDGBE, CYGBE,
SMGBE, SBGBE and NCGBE. The first three areas have the largest data
base, ongoing research and management. They appear at present to hold
the greatest opportunity for positive management direction. With
limited resources available for the total effort, the monetary and
manpower expenditures necessary to bring the base line data up to par
in the latter three areas--that would allow reasonably informed
decision making—would be extremely costly. Therefore, we have
identified recovery goals and occupied habitat for the first three
areas and believe they present the greatest opportunity for providing
a recovered population of grizzly bears in the lower 48 states.

Management of grizzly bears in the SMGBE, SBGBE and NCGBE should
be aimed at maintaining current populations and providing legal
protection under applicable federal (FLPMA, ESA, NEPA) and state
authorities until base line data regarding populations and habitat are
obtained to allow informed management decisions.

Craighead et al. (1974) were successful in determining population
dynamics for grizzly bears in the YGBE. Their data, however, revolved
mainly around bears congregating on garbage dumps. The extrapolation
of these parameters to more widely dispersed populations did not meet
with unanimous approval among bear experts. It is fortunate this
research was conducted as the Yellowstone population is the only one
for which substantial population data exists.

^Results and conclusions vary . with the treatment and
interpretation of these data, but it is generally concluded that the
grizzly population in the YGBE was viable and self-sustaining during
the 1959-67 period of the Craigheads' research, and that the space and
habitat occupied by those bears was adequate to serve the needs of
that population. It is for this reason that the population parameters
documented by the Craigheads for the YGBE during the period of 1959-67
were selected as the preliminary goal to define recovery. Attempts to
define other population parameters or habitat requirements that would
constitute recovery would require a set of assumptions, very few of
which would have basis or justification in the scientific literature
comparable to the term and extent of the Craighead studies.

-3-

It is fully recognized that current distribution and behavioral
patterns of grizzly bears may be fundamentally different from those of
the 1959-67 period and that these differences may well dictate
different population parameters. However, there is presently
insufficient evidence to assume current or future population
characteristics could not resemble those of the population occurring
from 1959-67.

Ongoing research and future intensive monitoring and research
will document the extent of differences or similarity with past
populations. These data will then be the basis for determining
population parameters that document recovery. Specific parameters may
be similar or different, but in combination they should constitute the
biological equivalents that would lead to the conclusion that the
population is recovered.

Objective number one stated previously is to identify grizzly
bear population goals that represent species recovery in measurable
and quantifiable terms... how many bears constitute a recovered
population! However, it is most difficult to determine the total
population of a secretive, wide ranging species such as the grizzly
bear which occupies rugged, mountainous terrain. Given this
constraint it is believed that appropriate and monitorable population
parameters which indicate the overall population status can serve as
an alternative to a total population census.

It is recognized that observation techniques, management
conditions and grizzly behavior are different now than when the
Craigheads were conducting their research which focused primarily on
bears feeding at garbage dumps. Presently the dumps are closed, the
bear jams along the highways no longer occur and the grizzly bear
population in the Yellowstone area is more dispersed and free ranging.
However, Craighead et al. (1974) represents the only long-term source
of data on Yellowstone grizzlies that contains quantified population
parameters relating to a population level estimated from a calibrated
sample. Furthermore, it is the most extensive data base available on
a grizzly bear population that is assumed to have been a viable and
self-sustaining population, i.e., a recovered population.

The consensus of opinion of persons attending the grizzly bear
workshops was that the NCDGBE must be managed as a single grizzly bear
ecosystem. They recognized that study efforts approaching the
magnitude of those for the YGBE have not been achieved. While the
Border Grizzly Project (BGP) has been doing research since 1975 in
this ecosytem, limited funds have relegated their work to relatively
small areas on its periphery. Research on study areas in the Mission
Mountains (1977-79), North Fork of the Flathead River (1975-80),
Hungry Horse Reservoir (1976-80) and along the Rocky Mountain Front
(1976-80) is continuing through the efforts of the Border Grizzly
Team. Grizzly bear research in Glacier National Park under the
direction of Cliff Martinka has been ongoing since 1967. John

-4-

Craighead conducted a limited grizzly bear research project in the
Lincoln-Scapegoat Wilderness area from 1975 to 1978. Unfortunately,
intensive research in the four wilderness areas that constitute a
major portion of this ecosystem has not been achieved. This is due to
limited funds and the high cost of research in roadless areas.
Therefore, the value of wilderness areas to grizzly bears in this
ecosystem is presently undocumented. They may contain habitat values
superior, inferior or equal to those in peripheral areas. It is known
that portions of these wilderness areas are included in the home
ranges of many radio-tagged bears. However, until the data are
collected directly from within these large wilderness areas conjecture
will prevail as to their value to grizzly bears.

While data for the NCDGBE , which includes Glacier National Park
(Fig 4), are less extensive than for the YGBE , they are believed to be
adequate to make an initial estimate of bear population
characteristics that represent a viable, self-sustaining population,
and to judge the space and habitat that population would occupy. (See
pages 59-60.)

The Cabinet-Yaak Grizzly Bear Ecosystem is the third area chosen
for recovery action. Only limited data are available but limited
research is either ongoing or scheduled for this area. The quantity
and quality of the habitat appear to be adequate to sustain a minimum
viable population (MVP). Because there are substantial numbers of
sightings and grizzly sign reported annually, this has led us to
believe that a breeding population does exist. If this population can
be brought to a viable and self-sustaining level, it would have a
strong influence on working toward a more comprehensive recovery plan
for the remaining three areas (SMGBE, SBGBE , NCGBE) .

Recovery goals for the CYGBE were established by delineating an
area which appeared capable of supporting grizzly bears based on
habitat components, present land uses, and historic and current
grizzly bear observations. Its adequacy for spacial requirements and
population size were tested by applying Shaffer's (1978) work on MVP
sizes and areas and comparing the resulting bear density to other
grizzly bear densities from other study areas. Mark L. Shaffer (1978)
used a computer model and data primarily from the Yellowstone grizzly
bear population (Craighead et al., 1974) to conclude that a MVP for
grizzly bears would be 30-70 bears (depending upon population charac-
teristics). Lesser numbers of bears would have less than a 95% chance
of surviving for even 100 years according to Shaffer. He further con-
cludes ^.hat the ^minimum area required to support a MVP varies fro^
1050 km 2^05 mi ) in some areas of the Northern Rockies to 7400 km
(2850 mi ) in the Brooks Range of Alaska. The delineated occupied
habitat of 1,818 square miles in the CYGBE is within the minimum area
(965-2850 square miles) required to support a MVP (30-70 animals)
calculated by Shaffer. A population of 70 animals in the CYGBE equates
to a density of one bear per 26 square miles which is equivalent to
densities of bears in other ecosystems having similar habitat features

-5-

Thus, a population of 70 bears within an occupied area of 1,818 square
miles was selected as a recovery goal for the CYGBE.

Simulation analysis determining MVP's and the minimum area
required to support a MVP were useful for indicating threshold limits
but were not used to determine final objectives in the Yellowstone and
Northern Continental Divide Grizzly Bear Ecosystem. In these
ecosystems, physical limitations of habitat size are not as
restrictive as in the CYGBE.

These simulation models assume sufficient secure habitat
throughout the projection period and no man-induced mortality. There
is little evidence to support either assumption. The minimum area
designated to support a MVP would have to be a bear refuge with other
uses permitted only to the extent that they aided grizzly bear manage-
ment. An MVP objective would mean maintaining grizzly bears on the
threshold, which, if violated and undetected, could plunge that
population over the brink to extirpation. Catastrophe, either
biological or physical, can seldom be predicted; and our knowledge of
bear biology is inadequate to attempt management within this limited
zone .

Data available on other grizzly bear ecosystems (Selkirks,
Selway-Bitterroot , North Cascades or Colorado) are insufficient to
estimate the present status of these populations or to determine the
full extent of grizzly range.

The test of time will determine the validity of the techniques
employed in determining populations necessary for viability. This
plan is intended to be a dynamic plan that will provide for changes
which research indicates are prudent and for periodic reviews.

This recovery plan is not a final plan on behalf of grizzly
bears. The best information and knowledge available are used as an
initial starting point to promote an increase in the present numbers
of bears, to effect recovery and to preserve the ecosystems upon which
this species depends.

The human impacts on grizzly bears over the past 200 years and
their cumulative effects are history. The fact that these bears still
survive speaks of their tenacity. The numbers of grizzlies the
remaining habitat will support is finite. More people, more and
varied impacts from mineral and energy development, recreation,
grazing, logging, subdivisions, etc., if unchecked and without long
range planning, will reduce the habitats' carrying capacity for
grizzly bears. If grizzly bears and people are to coexist in the
lower 48 states, an immediate effort to minimize the effect of these
adverse impacts is imperative.

-6-

HISTORY

Katherine L. McArthur (1979) presents an excellent history on
grizzly bears. Many of the following excerpts are from her paper.

The ancestor of all present day bears was the Etruscan bear
(Ursus etruscus) which lived in the forests of Asia about two million
years before present (BP) (Herrero 1972, 1978; Henry and Herrero
1974) . During the warm interglacial periods of the Ice Age,
retreating ice left vast areas of tundra-type, treeless vegetation.
The evolution of some bear populations using this extensive new
resource gave rise to the cave bear (U. spelaeus) in Europe and the
brown bear (U. arctos) in Asia.

Ursus etruscus was the ancestor of both the Asiatic black bear
(U. thibetanus) and the American black bear (U. americanus). Members
of this black bear line wandered into North America more than 500,000
BP (Kurten 1968). Isolated from their ancestors, the North American
population adapted to the resources of the continent, eventually
evolving into the American black bear (Herrero 1972) .

Much later, about 50,000 BP, brown bears crossed the treeless
Bering Land Bridge and spread into North American (Churcher and Morgan
1976). Two subspecies of brown bears occupy North America: the
grizzly bear (U. a. horribilis) on the mainland, and the Kodiak bear
(U. a. middendorf f i) , on Kodiak, Shuyak and Afognak Islands (Rausch
1963) .

For brown bears to exploit the rich periglacial habitats, their
ancestral forest adaptations had to be modified. Away from the
protection of forest cover, morphological and behavioral changes were
necessary for the bears to protect their young from other bears,
wolves and several now extinct Pleistocene carnivores. A sudden burst
of violence or an effective threat by the mother toward any perceived
threat is important to the survival of her cubs. This behavioral
adaptation of greater aggressiveness to successfully care for cubs in
this new habitat (Herrero 1970b, 1972, 1978) is quite likely to have
subsequently earned this subspecies of brown bear the name
"horribilis . "

PHYSICAL CHARACTERISTICS

Grizzly bears are generally larger than black bears and can be
distinguished by longer curved claws, humped shoulders and a face
that appears to be concave. A wide range of coloration from light
brown to nearly black is common. Guard hairs are often paled at the
tips; hence the name "grizzly." Spring shedding, new growth,
nutrition and climate all affect coloration.

An occasional male may exceed 1,000 pounds but the average weight
is closer to 500-600 pounds (Greer 1980). Females are generally
smaller. Adults stand 3^-4% feet at the hump when on all fours, and
may rear up on their hind legs to over eight feet.

-7-

The muscle structure in grizzly bears is developed for massive
strength, quickness and running speeds up to 25 miles per hour.
Movement includes the normal position on all fours and an upright
position on the hind legs which improves the opportunity to see and
smell .

Grizzly bears are relatively long-lived with individuals known to
have lived 40 years (Storer and Tevis 1955); a captive bear lived 47
years (Curry-Lindahl 1972). Pearson (1975) listed the oldest age
classes as 28 years for males and 23 years for females; and Craighead
et al. (1974), working in Yellowstone, found the oldest age was 25.5
years for both sexes.

SOCIAL ORGANIZATION AND BEHAVIOR

Adult bears are individualistic in behavior and normally are
solitary wanderers. Except when caring for young or breeding, grizzly
bears have individual patterns of behavior. Individuals probably react
from learned experiences. Two individual bears may respond in
opposite ways to the same situation (Scott 1964, Riegelhuth 1966, in
McArthur 1979).

Mace and Jonkel, (1980a) documented movements on three
radio-marked bears during the summer and fall of 1979. A limited
tolerance appeared to exist as two male grizzly bears followed a
marked female (in estrous), during late June--at least there were no
recent wounds on either male at the time of capture. Bear No. 363
(female) moved westward in August and was followed by male No. 114.
Throughout August and September the two bears were in the same general
area and fed periodically on Vaccinium globulare in a small shrubfield
but they were never known to use the shrubfield simultaneously. A
third male No. 395 moved into the same general area but frequented the
shrubfield only when No. 363 or No. 114 were not present. Grizzly No.
395 spent approximately 40 days in a natural burn, with short term
movements to the ridgetops . On 17 September male grizzly No. 114
moved through the burn and two days later bear No. 395 was located 13
air miles to the north. Was this the result of a typical
confrontation or the/ coincidental action of a single bear? Continued
research may resolve the question. Apparently strict territoriality
is limited and spacing may involve either time or location. If both
are violated, confrontation may occur with the dominant bear
prevailing .

Each bear appears to have a minimum distance within which another
bear or person cannot enter; any intrusion of this distance may evoke
a threat or an attack (Herrero 1970b, Mundy and Flook 1973 in McArthur
1979). Surprise is an important factor in many confrontations
involving bears and humans. A female with young exhibits an almost
reflexive response to any surprise intrusion or perceived threat to
her "individual distance" (Mundy and Flook 1973, Herrero 1976, in
McArthur 1979). While females with young comprise less than 20% of
the total grizzly population, they caused at least 79% of the injuries
to people during 1970-1973 period (McArthur 1979).

-8-

Defense of a food supply is another cause of confrontation
between man and bear. The bear generally defending his kill or
carrion out of a perceived need and roan defending his supplies and
property for human reasons.

If back-country hikers would actively make noise (bells, singing,
talking) to avoid suddenly surprising bears while traveling through
grizzly bear habitat; and if campers would take reasonable care of
their garbage and food supplies, most grizzly bears would flee in
response to human intrusions (Herrero 1976 in McArthur 1978) .

Grizzly bears of all ages will readily congregate at plentiful
food sources and then form a social hierarchy unique to that grouping
of bears (Hornocker 1962, Craighead 1979). However, the mating season
is the only time that adult males and females tolerate one another and
then it is only during the estrous period. Other social affiliations
are generally restricted to family groups of mother and offspring,
siblings that may stay together for several years after being weaned
and an occasional alliance of subadults or several females and their
offspring (Murie 1944, 1963; Jonkel and Cowan 1971; Craighead 1976;
Egbert and Stokes 1976"; Glenn et al., 1976; Herrero 1978).

PAST DISTRIBUTION

Historically, the range of the brown bear included almost the
entire coniferous and deciduous forest zones of Europe (Curry-Lindahl
1972). Brown bears still occur near both their northern and southern
extremes of original distribution in Eurasia, although their numbers
are greatly reduced. They have been extirpated throughout vast areas.
Though still numerous in the USSR, the brown bear has disappeared from
most of its range west of the USSR due to destruction of habitat and
heavy hunting pressure. The North African subspecies was exterminated
a century ago. About 13-20 local populations persist in Europe. Some
are surprisingly abundant (Poland, Hungary) but others are very small
and their future is far from bright (Cowan 1972, Curry-Lindahl 1972).

In North America, the grizzly's historic range extended from
Ontario westward to the California coast (Herrero 1972) and south into
Texas and Mexico (Storer and Tevis 1955). The development of
unfavorable environmental conditions in the wake of westward expansion
and development caused a rapid distributional recession (Guilday
1968). Populations were present throughout most of western North
America during the 18th century (Storer and Tevis 1955), but the
rapidity of local extinctions suggests that many of these were also of
marginal status (Martinka 1974a).

Between 1800 and 1975, grizzly populations receded from estimates
of over 100,000 to less than 1,000 grizzly bears. Livestock
depredation control, habitat deterioration, protection of human life,
commercial trapping and sport hunting (Stebler 1972, Martinkc 1976)
were leading causes. Conflicts between bears and livestock were
common during the settling of the west and is characterized by the

-9-

attitude of early American stockmen as expressed by Bailey (1931):
"The destruction of these grizzlies is absolutely necessary before the
stock business ... could be maintained on a profitable basis." The
scene is less common today but still persists when man, livestock and
grizzly bears compete for space. Several ranchers raised in the
foothill areas along the east and south borders of the NCDGBE have
commented that present populations appear to be greater in recent
years than they were during the 1920 's and 1930' s.

Howard Copenhaver, a rancher and outfitter living on the southern
boundary of the NCDGBE for over 60 years, believes grizzly bear pop-
ulations were at their lowest ebb during the early part of the century
and extending into the 1920' s and 1930' s. He related that sheepmen
were running their bands of sheep far into the mountains and, out of
necessity, hired hunters and trappers in addition to herders to
protect them. "Seeing a track of a grizzly or black bear during the
1920' s was something to write home about," states Copenhaver. He also
stated that it is his opinion that grizzly bears have increased
markedly over the past thirty years in areas he is familiar with.

As fur trapping, mining, ranching and farming pushed westward,
the grizzly was extirpated from much of the Great Plains where it had
flourished at the time of the Lewis and Clark expedition (Wright
1909). Logging and recreational development added to the man-induced
mortality of grizzly bears as the mountainous areas were settled. In
most cases, bears which threatened or appeared to threaten man's early
tenuous existence were eliminated.

Grizzly bears disappeared from Texas about 1890 and by 1922 the
last of the California grizzly bears were gone (Storer and Tevis
1955). They were last reported in Utah in 1923, Oregon 1931, New
Mexico 1933 and Arizona 1935. By 1970 only the present populations,
referred to by some as remnant populations, occurred in mountainous
regions, national parks and wilderness areas of Washington, Idaho,
Montana and Wyoming (Hoak et al., 1980). The Sierra del Nido in
Mexico may also have a remnant population (Leopold 1967, Koford 1969)
and the status of the grizzly bear in the San Juan National Forest in
Colorado is still in doubt.

Throughout history grizzly bears in marginal habitat have been
particularly susceptible to over-kill because of their opportunistic
feeding habits and consequent attraction to carrion, weakened domestic
animals, garbage and other food sources often associated with people
(Hamer 1974). However, many bear hunters and field research personnel
would disagree on their susceptibility in their present habitat as
they have found them difficult to even fleetingly observe.

CUPJAENT DISTRIBUTION/STATUS

In the conterminous 48 states, only six areas were found to
contain either self-perpetuating or remnant populations. A grizzly

-10-

Map of the distribution of grizzly bear by C.H. Merriam in 1922 (from Outdoor Life,
Dec. 1922; reprinted with permission from The Popular Science Publishing Company),
in Earle F. Layser 1978. -11-

bear killed in the early fall of 1979 near the Continental Divide in a
remote section of the San Juan National Forest in Colorado casts doubt
on whether or not the species is extant in Colorado and the southern
Rockies. This adult grizzly was killed by an archer while hunting on
the headwaters of the Navajo River (Hess 1980 pers. com.)- The
remoteness of the area, its proximity to wilderness areas and the
existence of a very large and well protected Spanish land grant,
Tierra Amarilla, all lend credibility to the possible existence of a
relic population. This plan does not address recovery in Colorado
beyond expressing hope that a search for grizzlies will continue.

Grizzly bears presently occupy over 5.5 million acres of
mountainous terrain in and surrounding Yellowstone National Park (Fig
3) . The Yellowstone Grizzly Bear Ecosystem (YGBE) includes
Yellowstone National Park, Grand Teton National Park, John D.
Rockefeller Memorial Parkway, significant contiguous portions of the
Shoshone, Bridger-Teton , Targhee, Gallatin and Custer National
Forests, Bureau of Land Management lands and over 55,000 acres of
state and private lands in Montana, Wyoming and Idaho. Population
estimates for this ecosystem vary from 200-350 grizzlies.

The Northern Continental Divide Grizzly Bear Ecosystem (NCDGBE)
contains 5.7 million acres of occupied grizzly bear habitat. It
includes Glacier National Park, parts of the Flathead and Blackfeet
Indian Reservations, parts of five national forests (Flathead, Helena,
Kootenai, Lewis & Clark and Lolo) , Bureau of Land Management parcels,
and a significant amount of state and private lands. Four wilderness
areas (Bob Marshall, Mission Mountains, Great Bear and Scapegoat) and
one wilderness study area (Deep Creek North) are included. Population
estimates for this ecosystem vary from 440-680 bears. The area is
contiguous to Canadian grizzly bear populations and an interchange of
bears is assumed (Fig 4) . There is no evidence to indicate the
numbers of grizzly bears in the NCDGBE are increasing. When the added
stress of increasing habitat encroachment by increasing numbers of
people is considered, the trend may be a decreasing population and the
need for action is obvious.

One very important aspect of this ecosystem is that it embraces a
narrow strip of the Great Plains and grizzly bears can still be found
there. Descendants of the plains grizzly bears, noted by Lewis and
Clark in the early 1800 's and painted by Charles Russell 100 years
later, have been reduced to this last narrow strip of plains habitat
bordering the eastern slopes of the Rocky Mountains, commonly called
the Rocky Mountain Front.

The CYGBE in northwestern Montana and northeastern Idaho has over
a million acres of forested and mountain habitat occupied by grizzly
bears (Fig 4). The status of that population is presently
undetermined. Biologists are able, however, to observe grizzly bears
in this ecosystem when a reasonably intense effort is made. It is not
uncommon to receive 40-50 unsubstantiated reports of observations

-12-

annually (Christensen 1980 pers. com.)- Low densities of grizzly
bears are found in the Yaak and contiguous areas in Canada and inter-
changes of bears have been documented. The retention of functional
movement corridors, with adequate cover, between the Cabinet Mountains
population and population centers in the Yaak, Whitefish Range and
Canada, are essential to the welfare and survival of the bears in this
grizzly bear ecosystem.

The SMGBE (Fig 5) of northeastern Washington and northwestern
Idaho is not well defined. An area on the Panhandle National Forest
(Idaho) has been designated by state and forest service biologists as
occupied by grizzly bears. Forest service personnel recognize that
grizzly bears may occur beyond this boundary, especially during the
spring season. The size of the occupied range may be expanded as new
information is gathered. Personnel of the Colville National Forest
(Washington) have reports and first-hand knowledge of the presence of
grizzly bears in an area adjacent to the Panhandle National Forest
(Fig 5) but do not believe they have adequate data to designate the
extent of occupied habitat. Canada has a population of grizzly bears
contiguous to this area and an interchange of the species is believed
likely .

The NCGBE (Fig 6) is also contiguous to an area of low grizzly
density in Canada. In this ecosystem, bears are rarely observed and
there are insufficient data to designate occupied range or to estimate
the density or population. Whether this is a factor of low numbers of
bears or the heavy cover they occupy is subject to debate.

The SBGBE (Fig 7) is centered in the Selway-Bitterroot Wilderness
Area. Credible grizzly bear observations are relatively few. Historic
ranges of the grizzly bear include National Forest lands surrounding
this wilderness and the proposed River of No Return Wilderness on both
sides of the Salmon River. Several biologists and Forest Service
personnel questioned whether grizzly bears in this area are permanent
residents or transients. Others adamantly maintain they are permanent
residents of the area. Recent reports (Oldenburg 1980 pers. com.)
include one grizzly bear sighting (unconfirmed) on Moose Creek and
several sightings and reports of tracks on the upper Lochsa-Clearwater
Divide (Oldenburg 1981 pers. com.).

CORRIDORS

It is highly unlikely that adequate corridors of cover to provide
for an interchange of grizzly bears between the YGBE and other grizzly
bear ecosystems presently exist. The distance exceeds 150 miles
(airline) and a much greater distance if mountainous terrain were
followed. Interchanges between all other populations are feasible,
and consideration to protect these travel corridors is a necessary
part of future land planning. Intervening areas of developed or
tilled agricultural lands are unlikely to be crossed by grizzly
bears--at least without the chance of a confrontation that may lead to
the demise of the bear.

-13-

"One of the most profound developments in the application of
ecology to biological conservation has been the recognition that
virtually all natural habitats or reserves are destined to resemble
islands, in that they will eventually become small, isolated fragments
(isolates) of formerly much larger continuous habitat. Typically, the
term isolate is used to connote any discrete ecological unit which is
insulated from other similar units" (Wilcox 1980). They have
definable physical and biological properties and are of "...primary
interest to conservation biologists since they are affected by habitat
loss and insularization. Reduction in total amount of area encompassed
by natural habitat and fragmentation into disjunct insular parcels
obviously have negative effects on natural ecosystems" (Wilcox 1980) .
Larger areas have more habitat and greater habitat diversity to offer
all species or any particular species. Loss and fragmentation of
natural habitat is particularly relevant to the management and
survival of grizzly bears. They are large animals with great metabolic
demands requiring extensive home ranges. Their low densities, low
reproductive potential, individualistic behavior, large home ranges
and their invasion of the riparian habitat (also used extensively by
man) , cause them to be more vulnerable to extirpation than many other
species .

The necessity of developing or maintaining corridors for
inter-isolate dispersal between populations may prove to be very
important. "...individuals dispersing from adjacent or contiguous
habitat can shore up a faltering population." (Wilcox 1980).

POPULATION CHARACTERISTICS

Density

The mean density of grizzly bears in the Yellowstone Ecosystem
was computed to be 1 bear per 34 square miles by Craighead et al.
(1974); in Glacier National Park the mean density was estimated by
Martinka (1974a) to be 1 bear per 8 square miles on a 290-square mile
study area; on Kodiak Island, Troyer and Hensel (1964) found a density
of bear greater than 1 per .75 square miles and in Mt. McKinley
National Park, a mean density of 1 bear per 11 square miles was found
(Dean 1976).

The mean density of grizzly bears in the NCDGBE can only be
estimated at this time as large segments of remote, unroaded
wilderness habitat have not been sampled. Servheen and Lee (1979)
estimated the mean density of the grizzly bears in the Mission
Mountains study area to be 1 bear per 15 square miles; and they have
extrapolated these data to estimated 1 bear per 19 square miles for
the entire Mission range. BGP studies, conducted in the Whitefish
range, estimated a density of 1 bear per 15 square miles on that
220-square mile study area (Thier 1979 pers. com.). Richard Mace,
working with the BGP in the South Fork of the Flathead River drrinage
south of the Jewel Basin, estimated a density of 1 bear per 9.8 square
miles on a study area of 128 square miles (Mace 1980 pers. com.).

-15-

Schallenberger (1980) stated he could not estimate the total
population or density for study areas on the Rocky Mountain Front.
Jonkel (1980 pers. com.) stated daily grizzly bear densities on some
key seasonal use areas along the Front were as high as 1 bear per
square mile. Servheen (1980a) combined and averaged several density
estimates determined from study areas to establish a range of
population estimates for the NCDGBE. Additional information gleaned
from biologists and game managers familiar with the area has hopefully
refined these density estimates; but the fact remains that population
data for this ecosystem, especially the wilderness portions of it, are
less than adequate.

No estimates of density or total population are made for the
remaining grizzly bear ecosystems in the conterminous 48 states.
Densities of areas for comparison are shown in Table 1.

Home Ranges

"Space is a species' communal home range; the size is determined
by the cruising radius of that species. This home range must contain
all of the species' requirements--f ood , cover and water--for both
sexes and all age classes, for all seasons and for all of the species'
activities." (King 1938).

In theory, territoriality is the optimal mechanism to space
individuals where resources are plentiful and predictable (Giest
1974). To defend a territory of low food availability by overt
aggression would not be beneficial to the bear. The energy cost of
defending the area would outweigh the return in resources (Bunnell and
Tait 1978). Territoriality, if it occurs in grizzly bear behavior,
also serves as a population regulating mechanism by spacing individual
bears and thereby limiting population density (Etkin 1964). It also
serves to dampen the total population by limiting their ability to
exploit locally abundant resources.

While there is little evidence that grizzly bears exhibit terri-
toriality, a solitary grizzly bear appears to maintain an individual
spacing between itself and other bears. The distance maintained may
jyary with circumstance and season. Females with cubs may enforce a
distance of several hundred meters" (Herrero 1970b, Cole 1972, Pearson

1975, in McArthur 1979).

The home ranges of adults frequently overlap. The home range of
adult males is generally two to four times larger than that of females
(Jonkel and Cowan 1971, Kemp 1972, Pearson 1975, Amstrup and Beecham

1976, Craighead 1976, Rogers 1977, Herrero 1978, Servheen and Lee
1979, and Mace 1980 pers. com.). Home ranges of adult males are too
large to be defended. The home range of females appear to be smaller
during the period they are with cubs, but they expand when the young
are yearlings in order to meet increased foraging demands (Kemp 1972,
Pearson 1975, Herrero 1978, Russell et al., 1978 in McArthur 1979).

-16-

Table 1. Estimated densities of U. arctos in various areas.

2 2

Location km /bear mi /bear" Source

Eurasia

Abruzzo Nat. Park

(Italy) 5.41

Northeast Siberia 10.00

Upper Kolyma Basin 150.00

Kamchatka Pensula 16.00

North America

Kodiak Island 1.60

Mt. McKinley Nat. Park 30.00

Brooks Range 148.00

Northwest Territories 147.50

Northern Yukon 48.0

Southwest Yukon 25.0

Glacier Prov. Park 23.30

Glacier Nat. Park 21.20

Yellowstone Nat. Park 88.4

2.1 Zunio and Herrero 1971
3.9 Kistchinskii 1972

57.9 Kistchinskii 1972

6.4 Ostroumov (1968) as cited
in Kistchinskii 1972

0.62 Troyer and Hensel 1964

11.6 Dean 1976

57.0 Curatolo and Reynolds,
in press

57.0 Harding, in press
18.5 Pearson 1976

9.7 Pearson 1975

9.0 Mundy and Flook 1973

8.2 Martinka 1974

34.1 Craighead et al. 1974

Shaffer, M.L. (1978) Determining Viable Population Sizes:

A Case Study of the Grizzly Bear

"'Column added

Editor's Note: Differences in densities between areas may
actually result from differences in study
methods, length and depth of study, seasonality,
etc. but they are indications of the productivity
of the respective areas.

-17-

The fact that grizzly bears disperse as subadults is assumed;
however, their pattern of dispersal is not well documented. Dispersing
young males apparently leave their mothers' home range and may
disperse directionally , constantly moved on by the avoidance of the
home ranges of established adults. This increases their
susceptibility to mortality and human/bear conflict by finding and
utilizing unnatural sources. Young females may establish a home range
soon after family breakup, often within the vicinity of their mothers'
home range. Grizzly bear mothers may tolerate female offspring and may
shift their home range to accommodate them (McArthur 1979). Lentfer,
Servheen, and Beecham (1981 pers. com.) have stated this behavioral
strategy has been described for black bears but cannot be supported
for grizzly bears in the literature.

Home range sizes vary in relation to food availability, weather
conditions and interactions with other bears. In addition, an
individual bear may later extend its range seasonally or change from
one year to the next (Jonkel and Cowan 1971, Greer 1972, Craighead
1976, Rogers 1977, Russell et al., 1978).

In, the YGBE the average home range size was, 179 mi fp^r males and
105 mi for females. Extremes varied from 3 mi to 672 mi during the
1974-80 period of study (Blanchard 1980 pers. com.). A decade earlier
home r,ange sizes o£ bears in the YGBE were described as ranging from
40 mi to 1000 mi . Grizzly bears whose home ranges extended beyond
the park boundaries were including garbage areas within the park in
their home ranges during the summer period (Craighead, 1976,
Craighead and Craighead 1972a, Craighead 1980, Craighead 1981.

Average home range size for adult grizzly bears was computed fro^
several study areas in the NCDGBE. For males, an average of 189
was determined; extremes varied from 64 mi to a maximum of 543 mi
(Rockwell et al., 1977, Servheen and Lee 1979, Schallenberger and
Jonkel 198CJ) . One highly mobile radio-marked bear ranged throughout
an 1165 mi area and was excluded from the averages (Servheeg and Lee
1979). For females in the, same area, the average was^72 mi , with a
minimum range of 39.5 mi and a maximum of 190 mi (Thier 1979,
Servheen and Lee 1979, Schallenberger and Jonkel 1980, Mace 1980 pers.
com. ) .

The Kodiak Island ^tudy found the average home range of grizly
bears to be only 5.5 mi , as influenced by abundant food and denning
sites being closely grouped (Berns and Hensel 1972).

Age and Sex Structure
"The average unhunted grizzly bear population is composed of 17%
cubs, 13% yearlings, 11% subadults, 19% females with young and 40%
unclassified adults (Hornocker 1962, Egbert and Stokes 1976, Martinka
1974b, 1976; and Dean 1976 in McArthur 1979)." Age and sex structures
are dynamic variables influenced by so many factors such as habitat
conditions, time of the year observations are made, hunting,

-18-

etc., that trying to determine an average population may not be
appropriate. Pearson (1972), working with a hunted population in the
Yukon, found 24% cubs and yearlings, 32% subadults (2-6 years) and 44%
adults. The population structure of grizzly bears on Kodiak Island
(hunted) was 26% cubs, 22% yearlings, 27% subadults and 25% adults
(Troyer and Hensel 1964 in Shaffer 1978).

Craighead et al. (1974) recorded an average age composition 18.6%
cubs, 13.0% yearlings, 24.9% subadults (2-4 years) and 43.7% adults
during the period 1959 through 1967 in the YGBE. Blanchard and Knight
(1980) recorded 6.5% cubs, 16.1% yearlings, 37.1% subadults and 40.3%
adults for the area in 1980.

Age and sex classifications for small study areas may not reflect
the true composition because of the home range size differences
between sexes and overlapping ranges (Dean 1976 in McArthur 1979).
Sex ratios are usually even, although the larger ranges and mobility
of males may bias samples toward males (Hornocker 1962, Troyer and
Hensel 1964, Jonkel and Cowan 1971, Kemp 1972, Egbert and Stokes
1976). Higher male vulnerability throughout their life span results
in a sex ratio in favor of females in adult age classes (Jonkel and
Servheen 1980 pers. com.). Reynolds (1978) working on the North Slope
in Alaska, where grizzly bears are more readily observable, found the
adult male/female ratio to be 27:50.

Natality

The most comprehensive information on breeding biology in the
YGBE comes from the Craighead's studies. Much of the following is
from their reports. It must be noted, however, that the reproductive
biology of bears is influenced by habitat quality, quantity and its
spatial and temporal distribution. Therefore subsequent data by the
Interagency Grizzly Bear Study Team should document a difference
(lower) in reproductive performance because the dumps, a lucrative
artificial food source, have been removed (Beecham, 1980 pers. com.).
On the other hand, Picton (1978) suggests that the depression in the
reproductive rate of grizzly bears in this ecosystem during the
1972-76 period was due to influences related to climate, and that the
closure of garbage dumps has had little effect.

Mating appears to occur from late May through mid-July, with a
peak in mid-June and estrous lasting from a few days to over a month
(Craighead et al., 1969, Herrero and Hamer 1977). Females in estrous
are receptive to practically all adult males (Hornocker 1962) . A male
may isolate and defend a female in areas of low bear density; but in
areas of high density, males and females may both be promiscuous
(Craighead at al., 1969)

Age of first reproduction and litter size varies and may be
related to nutritional state (Herrero 1978, Russell et al., 1978).

-19-

Litter sizes range from 1 to 4, with the mean about 2 (Craighead
and Craighead 1972, Curry-Lindahl 1972, Pearson 1972, 1975, Zunino and
Herrero 1972, Mundy and Flook 1973, Martinka 1974a; Craighead et al.,
1976; Glenn et al. 1976; Bunnell and Tait 1978; Herrero 1978 in
McArthur 1979). Litter size averages 1.7 in Glacier National Park
(Martinka 1974a). Age of the mother is not correlated with litter
size (Craighead et al., 1976). Lack (1954) theorized that litter size
is adjusted to the most young for which the parents can, on the
average, find sufficient food. Litter sizes of bears tend to be
largest in the best fed populations (Stringham 1980). Lord (1960) has
theorized that the higher survival rates of hibernators favor smaller
litter sizes than in non-hibernators . First-year mortality of grizzly
cubs, during the period of intensive maternal care, seems to be low
(Mundy and Flook 1973, Martinka 1974a, Dean 1976, Glenn et al. , 1976);
although it may be higher than is apparent, particularly if the losses
involve singletons, which may have selective advantage, or entire
litters" (Tait 1980). The Craighead team (1969) determined that
females in the YGBE reach sexual maturity at 4.5 years of age, but
only 69% conceived at this age (Craighead et al., 1974). Evidence of
estrous and conception in grizzly bears at 3.5 years has been noted in
three areas in North- America (Erickson et al., 1968, Nagy and Russell
1978, Jonkel and Servheen 1980 pers. com.), but seldom do female
grizzlies conceive until 4.5 years of age. Data from the NCDGBE and
reports from Canada indicate 5.5 years of age and 6.5 years,
respectively, may be more common for age of first conception in those
areas. Two instances of bears conceiving at 4.5 years of age in the
NCDGBE have been recorded recently (Servheen 1981 pers. com.).
Reynolds (1978) found that grizzly bears in the Brooks Range of Alaska
do not usually produce young before 8 years of age. The oldest known
female giving birth in YGBE was 22.5 years of age (Craighead et al.
(1974). Females are probably capable of reproducing throughout their
lifetimes after reaching maturity (Jonkel and Cowan 1971, Craighead
and Craighead 1972, Pearson 1975, Craighead et al., 1976, Nagy and
Russell 1978). The average reproductive cycle, the period between
giving birth to young, for the Yellowstone population, was determined
to be 3.4 years with a range of 2-7 years (Craighead et al., 1974).

The limited reporductive capacity of grizzly bears precludes any
rapid increase in the population. Grizzly bears have one of the
lowest reproductive rates among terrestrial mammals, resulting
primarily from the late age of first reproduction, small average
litter size" and the long interval between litters (Jonkel and Cowan
1971, Bunnell and Tait 1978). Females must first survive the rigors of
being a cub, a yearling and several years of sub-adulthood before
reaching the age of first estrous, generally at 4.5 or 5.5 years of
age. Prior to first estrous, a female grizzly may be more likely to
be dispatched for food

* Litter sizes 2.24 (Craighead et al., 1976), 1.6 (Pearson 1975), 1.78
(Reynolds 1976).

-20-

by an adult male than to enter into a social agreement for mating.
Male grizzly bears killing adult females has been documented (Pearson
1975, Craighead 1980 pers . com.); Jonkel (1980 pers. com.) reports a
similar case for polar bears.

In the event mating occurred, and assuming she conceived at 4.5
years, a female grizzly bear would add her first recruitment to the
population when she was 5.5 years. The following summer, at 6.5
years, she is normally still lactating, and this is believed to
inhibit receptivity to males (Jonkel and Cowan 1971). Thus, the age
of second breeding would not likely occur until she is 7.5.
Therefore, during the first 10 years of her life, a female grizzly
bear is capable of adding only 2 litters to the total population. If
there are litters of 2 cubs with a 50:50 sex ratio, she can at best,
replace herself with one breeding age female in the first decade of
her life. Unfortunately, this situation is achieved only if her
female cub survives from birth to breeding age. In some populations,
only 20 to 50 percent of the cubs might be expected to survive that
period (Metzgar 1980 pers. com.).

Assuming optimum conditions, no mortality, equal sex ratio, and
using the oldest documented female weaning her last litter at age 24.5
years (Craighead et al., 1974), a single female would have the
potential capability of adding only 7 females to the population during
her lifetime. Given a normal rate of mortality for all age classes, a
protracted reproductive cycle of 3.4 years to 7 years, and the
increasing stresses of habitat encroachment by humans, a reproductive
expectancy of far less than the maximum cited would be expected.
Obviously, the need to provide maximum protection for females is
essential to recovery.

Males are believed to mature sexually at 4.5 years, but larger,
dominant males may preclude young adult males from siring many
offspring (Hornocker 1962).

The time lapse from conception to birth of cubs is between 229
and 266 days (Banfield 1974). A delay in blastocyst implantation
postpones embryonic development (following a mating season that
extends from late May to mid-July) until late November or December,
and is believed to be approximately 0-30 days after denning (Craighead
et al., 1969) with birth occurring near February 1.

MORTALITY

Natural Mortality
The causes of natural mortality for grizzly bears or other bears
are not well known. Bears do kill each other. It is known that adult
males kill juveniles and that adults also kill other adults.
Parasites and disease do not appear to be significant causes of
natural mortality (Jonkel and Cowan 1971, Kistchinskii 1972, Mundy and

-21-

Flook 1973, Rogers and Rogers 1976) but they may very well hasten the
demise of weakened bears (Jonkel 1980 pers. com.).

There are insufficient data to fully assess the degree of
mortality in the younger age classes of bears as a result of predation
by adult bears. However, Pearson (1975), Egbert and Stokes (1976), and
Nagy and Russell (1978) in McArthur (1978) indicate that it may be an
important factor. If young bears are not killed directly by
aggressive adults, as dispersing subadults they may be forced to
choose submarginal home ranges or areas near human habitation equally
dangerous to their survival.

Natural mortality during the denning period is not well doc-
umented. Several authors believe some bears die during denning,
especially following periods of food shortages. However, few such
deaths have been recorded.

Shaffer (1978) cites several references on mortality of denning
bears. Jonkel and Cowan (1971) report no mortality in dens; Craighead
and Craighead (1972b) suspect old bears may die in their dens and they
report that several old color-marked bears were observed in the fall
and never seen again. One older bear died soon after emerging from
hibernation.

Beecham (1980) working with black bears in Idaho indicated that
the physical condition of denned bears remained good, and that the
period of physical stress was most acute when fat reserves were at
their lowest in early July.

Upon emergence from the den, it is critical to the bears' welfare
to find sources of high quality, protein-rich food. With den sites at
higher, snow-covered elevations, movements of considerable distances
to lower elevations are necessary to reach palatable, emerging
vegetation rich in protein or to reach the foothill winter ranges of
ungulates in order to feed on the winter-killed or weakened animals.
This movement of bears to the lower elevations often takes them near
areas of human habitation and greatly increases the incidence of
human/bear conflicts. "A similar movement can often occur in the fall
due to ripening of fruit and berries at lower elevations. The west
front of the Mission Mountains is a case in point" (Servheen and Lee
1979). Not all residents of these foothills communities are willing to
assist in protecting the grizzly, especially if the bear commits an
act of depredation. Fortunately, the majority favor the survival of
the species. Those who still adhere to the axiom of the early west,
"...the only good grizzly is a dead one," are often either steeped in
tradition that all predators are a threat to their livelihood, or they
have had recent negative grizzly bear encounters.

Man-Caused Mortality
Man-related mortality can be categorized into six major areas:
(1) direct human/bear conflicts or confrontations in wilderness areas

-22-

and parks (hikers, backpackers, photographers, hunters, etc.; (2)
attraction of grizzly bears to improperly stored food and garbage
associated with towns, subdivisions, farms, hunter camps, campers,
loggers, fishermen, backpackers, etc.; (3) careless livestock
husbandry, including the failure to dispose of dead livestock in a
manner that minimizes grizzly interactions; (4) opportunistic or pure
chance interactions between livestock and bears as they wander into
close proximity; (5) the eroding of grizzly bear habitat for economic
values that reduces space, increases interactions and stress; and, (6)
hunting .

Subdivisions, power line corridors, logging roads, recreational
development, trails, sight-seeing gondolas, energy and mineral
exploration or development and simply more people everywhere are
degrading grizzly bear habitat by co-locating grizzly bears and
people; neither species will long endure the other in close proximity.
These actions are increasing and compounding the adverse effects of
human encroachment in so many ways that it is impossible to stay
current in the evaluation of all of them.

Grizzly bear habitat has steadily decreased since the initial
westward movement of settlers. Bears were conditioned to avoid
conflict with humans by the actions of those early settlers. In later
years bears have been attracted to carrion, waste products of
construction camps, recreational camps and the sprawling residential
areas that have invaded their habitat. The result has been "problem
bears" that have learned to cause damage to property, to prey on
livestock and to become a threat to human lives. This often leads to
illegal shooting or becomes a cause for the removal of the bear,
ultimately leading to a decline in the total grizzly bear population
and the eventual confinement of bears to ever-decreasing fragments of
their former range.

Conversely, sanctuaries that provide for high levels of human/
bear contact which result in little or no negative experiences for the
bear, may remove any barrier of fear or uncertainty the grizzly bear
would normally exhibit towards man. The effect could be neutrally
conditioned bears that may easily be followed by aggressive bear
behavior; especially if they associate people with a food source (camp
food, horse feed pellets, garbage, etc.). This learned behavior is
passed from females to cubs or is learned by dispersing subadults
finding a food source left by careless people. The end result of this
learned behavioral pattern is usually the loss of the bear (Jonkel and
Servheen 1977). Left unchecked, this learned behavior could lead to a
shift or trend in the behavior of entire bear populations.

National parks provide a set of circumstances conducive to con-
flicts between humans and grizzly bears. As park visitors increase
and invade the habitat of the grizzly bear, especially in small
parties of one, two or three persons, the number of confrontations can
be expected to increase proportionately. How this pattern can be

-23-

reversed is at present not clear. Some biologists advocate a
retraining program for problem bears to instill a fear of man and food
sources associated with people, but to date research in this field is
lacking .

There are numerous examples of man and grizzly bear coexisting
compatibly through a relationship that can be expressed as tolerant
but firm. These people, ranchers, outfitters, loggers, field
personnel of wildlife agencies, forest service and BLM personnel, and
many others, collectively spend tens of thousands of days and nights
in grizzly bear habitat with relatively few problems. Most bears
outside of national parks have apparently retained their fear of man.
Perhaps it is because they are hunted occasionally, legally and
illegally, or because those bears that become too bold are eliminated,
again legally or illegally, or it may be because the ratio of bears to
humans is lower than it is in parks (Jonkel and Servheen 1977). In
any event, the behavioral makeup of the grizzly bear population must
be given serious consideration. People who impair the bears' respect
for man by providing unnatural food sources, whether it be
accidentally, foolishly, or intentionally, share a moral
responsibility for any future acts of damage or violence committed by
these grizzly bears.

HABITAT CONDITIONS

Food

The broad historic distribution of grizzly bears suggests
adaptive flexibility in food habits of different populations.
Although the digestive system of bears is essentially that of a
carnivore, bears are successful omnivores, and in some areas may be
almost entirely herbivorous. Morphological adaptations include
crushing molars and the greatest intestinal length relative to body
length of any carnivore (Mealey 1975). Although grizzly bears in many
areas are almost entirely herbivorous, they are lacking in multiple
stomachs and a caecum and are therefore unable to digest cellulose.
Bears feed on animal matter or vegetable matter that is highly
digestible and high in starch, sugars, protein and stored fat (Stebler
1972, Mealey 1975, Hamer et al., 1977).

Grizzly bears must avail themselves of foods rich in protein or
carbohydrates in excess of maintenance requirements in order to
survive denning and post-denning periods. Therefore, protein
availability may be the limiting factor in grizzly bear densities.
Herbaceous plants are eaten as they emerge, when crude protein levels
are highest. These levels decline rapidly as the plants mature
(Mealey 1975, Hamer et al., 1977, Herrero 1978).

Grizzly bears are opportunistic feeders and will prey or scavenge
on almost any available food including ground squirrels, ungulates,
carrion and garbage (Murie 1944, Hamer 1974). In areas where animal
matter is less available, roots, bulbs, tubers, fungi and tree cambium
may be important in meeting protein requirements (Hamer 1974, Pearson

-24-

1975, Singer 1978). High quality foods such as berries, nuts and fish
are important in some areas for food sources (Cole 1972, Martinka
1972, Hamer et al. , 1977) .

Much of the following is excerpted from the Method for
Determining Grizzly Bear Habitat Quality and Estimating
Consequences of Impacts on Grizzly Habitat Quality (Mealey 1977).

Grizzly bear habitat in the YGBE and in that portion of the
NCDGBE east of the Continental Divide is open and xeric with
continental climate (Mealey 1979). Grizzly bears in these areas
derive most of their energy from protein in succulent, herbaceous
vegetation, primarily grasses and sedges, and secondarily, the aerial
parts of western spring beauty (Claytonia lanceolata), elk thistle
(Cirsium foliosum) and clover (Trifolium spp . ) (Mealey 1977,
Schallenberger and Jonkel 1978-1979). The underground parts of spring
beauty (Claytonia spp.) and biscuitroot (Lomatium spp.) are also used
in significant amounts for starch (Sumner and Craighead 1973, Mealey
1977, Schallenberger and Jonkel 1978-1979). Moist, fertile grasslands,
herblands, streambottom , ridgetops , talus slopes, wet avalanche chutes
and swamps, interspersed with timbered areas (for cover), are primary
feeding sites. The abundance and location of these habitat components
appear to influence grizzly bear distribution. These components are
usually found between 5,000 and 10,000 feet elevation, with their use
and relative importance depending upon season and phenology.

Grizzly bear range on the west side of the Continental Divide of
the NCDGBE and the other four grizzly bear ecosystems in northwestern
Montana, northern Idaho and Washington are influenced primarily by
maritime climate. Grizzly bears here appear to derive most of their
energy from sugar occurring in the fruits of huckleberry (Vaccinium
spp.), mountain ash (Sorbus spp.), buffaloberry (Shepherdia
canadensis) and serviceberry (Amelanchner alnifolia); burns producing
these fruiting shrubs are primary feeding areas (Tisch 1961, Shaffer
1971, Martinka 1972, Hamlin and Frisina 1974, Husby et al., 1977,
Mealey et al., 1977, Servheen and Lee 1979). Prior to the
availability of fruit, the grizzly bear diet consists largely of
succulent forbs and graminoids, starchy bulbs, tubers and roots
occurring in moist parks, avalanche chutes, wet meadows and riparian
zones (Mealey 1975, Husby et al., 1977, Mealey et al., 1977, Servheen
and Lee 1979). In years of berry crop failure, these components are
the major energy sources for grizzly bears. In all areas, small
mammals, especially ground squirrels, mice, insects, carrion and
occasionally a larger ungulate are utilized as available.

This search for food is a prime influence on movements. Upon
emergence from the den they seek the lower elevations, drainage
bottoms, avalanche chutes and ungulate winter ranges, where their food
requirements can be met. Throughout late spring and early summer they
follow plant phenology back to the higher elevations. In late summer
and fall, there is a transition to the fruit and nut sources, as well
as herbaceous materials. This is a generalized pattern, however, and

-25-

it should be kept in mind that bears are individuals trying to survive
and will go where they can best meet their requirements.

Some silvicultural practices to increase production of grizzly
bear food species and food producing openings in dense timber are
discussed in "Guidelines for Management Involving Grizzly Bears
in the Greater Yellowstone Area," (USFS and NPS,1979)

Cover

The relative importance of cover to grizzly bears has been
documented by Blanchard (1979) in a 4-year study in the YGBE. Ninety
percent of 2,261 aerial radio relocations of 46 instrumented grizzly
bears were in cover too dense to observe the bear. Whether grizzly
bears use timber (cover) because of an innate preference or in
avoidance of contact with humans is unknown (Blanchard 1979). The
importance of an interspersion of open parks as feeding sites
associated with cover is also recorded in Blanchard' s study: "Only 1%
of the relocations were in dense timber more than a kilometer from an
opening . "

She further records that bears observed in the open were less
than 100 meters from cover and most of those were less than 30 meters
from cover (Blanchard 1980) .

Seventy-nine percent of the feeding activities recorded were in
timber over three meters tall (Class 1 timber) , 4% in timber of less
than three and 17% in open habitats. Bear activities, other than
feeding, were most frequently recorded in Class 1 timber (70%), as
opposed to cover of lesser heights (Blanchard 1979). The values of
timber or brush for cover for grizzly bears has also been documented
by Craighead and Craighead (1972a), Craighead and Sumner (1973),
Ruediger and Mealey (1978), and Knight et al. (1977).

Timber cover was found to be very important to grizzly bears for
use as day beds. Most day beds were found less than a yard or two
from a tree (Servheen and Lee 1979, Blanchard 1979). Blanchard
further records only 16 of 233 day beds observed (6.7%) were without
immediate cover. Schallenberger and Jonkel (1980) found grizzly bears
preferring timber in over 80% of their radio relocations.

Ruediger and Mealey (1978) recommend that at least 30% of grizzly
bear habitat be managed as cover. Blanchard states, "Despite the
preponderance of observations in the timber, the importance of
interspersion of timber and open habitats is apparent." Additional
data on the importance of habitat interspersion to grizzly bears has
been documented by Craighead and Craighead (1972a), Jonkel and Mealey
(1975), Schallenberger (1976), Knight et al. (1978). Jonkel (1980
pers. com.) points out that cover is a relative term and isolation and
darkness in themselves constitute "cover". No distinction has been
made between the requirements for thermal cover and hiding cover.

-26-

Timber management programs can affect grizzly bears by (1)
vegetative manipulation (e.g., tree removal, riparian management,
prescribed burning); (2) displacement during the logging period; and,
(3) changes in human/grizzly bear confrontation potential or
perturbation factors as a result of road building and management
(e.g., new roads and road closures) which may cause the bears to
abandon the area.

Timber harvesting, according to Ruediger and Mealey (1978), is
most beneficial as a grizzly bear habitat management tool in forested
terrain where natural or prescribed burning will not or cannot be
used. Conversely, Blanchard (1979) states, "Logging negatively
affects bears through reduction of shelter and increases in human
activity." Elgmork (1978) discussed the disturbance on brown bears
in Norway and summarized the European literature on the effects of
clearcutting timber. His data show a significant negative correlation
between bear observations and the number of roads and increased human
activity, especially the networks of roads and resulting secondary
traffic (Elgmork 1976). Claar and Klaver (1980 pers. com.) found a
similar relationship between roads and grizzly bears on the Flathead
Indian Reservation.

Zager (1980) found that grizzly bears generally avoid cutting
units in northwestern Montana. Those that were utilized were located
along secondary or closed roads where the likelihood of human
disturbance was low. Grizzly bear use was generally restricted to the
margins of the cuts within 50 meters of timber cover. Comprehensive
and effective management of logging roads is important to grizzly bear
conservation. The isolation and security afforded bears by
obliterating or closing roads immediately following logging operations
in grizzly bear habitat is essential to assure that the bears will
return and use the affected areas.

Denning

The unavailability of food, deep snow and low ambient air
temperatures appear to make winter sleep essential to bears' survival
(Craighead and Craighead 1972a, 1972b). When rodents and bats
hibernate, they become periodically poikilothermic (Stringham 1980).
Hock (1960) defines hibernation: "...a periodic phenomenon in which
body temperature falls to a low level approximating ambient; heart
rate, metabolic rate and physiologic functions fall to a correspond-
ingly minimum level..." By contrast, bears are homeo-hypothermic
hibernators whose body temperature drops no more than 5°C and is
maintained there indefinitely (Stringham 1980). With normal fat
reserves, bears are capable of fasting for six months with only slight
reductions in body temperature. They do exhibit a "...marked
depression in heart rate and respiratory frequency, but a relatively
slight drop in body temperature" (Craighead and Craighead 1972a) .
Day length and inclement weather have been documented as influencing
the onset of winter sleep or hibernation by a number of authors.
However, Hocks (1960) deems it likely that hibernation is triggered

-27-

when the energetic cost of remaining active exceeds the benefit
derived from food intake. Miller (1972) found bears at abundant food
sources denning at later dates. Intrinsic factors are also involved
as some bears in captivity continue to simulate hibernation (Kayser
1965 in McArthur 1979) .

Digging of dens is probably instinctive. It starts as early as
September or may take place just prior to entry in late November.
Dens are usually dug on steep slopes where wind and topography cause
an accumulation of deep snow and where the snow is unlikely to melt
during warm periods. Elevations of dens vary geographically, but
generally they are found at higher elevations well away from any
development or activity by humans. Denning habitat descriptions and
activity have been described for grizzly bears in the Mission
Mountains of Montana by Servheen and Klaver (1981). Finding an
isolated area that will be well covered with a blanket of snow to
minimize the escape of body-warmed air and one that will provide a
secure environment for a five-month sleep, appears to be a factor
favoring survival of the species (Craighead and Craighead 1972b).
Grizzly bears seem very sensitive to disturbance or alteration of
habitat during the . pre-denning period. Denning habitat may be a
population limiting factor in some areas (Craighead and Craighead
1972b, Pearson 1975). Once denning areas are located, they must be
given prime consideration by land management agencies. Craighead and
Craighead (1972b) and others have recorded pre-hibernation lethargy in
bears that may start several weeks prior to denning. Bears exhibit no
overt defense of their dens and several have been reported to abandon
them because of human disturbance .

Pre-hibernation lethargy, the consequences of disturbance factors
to denning bears and bear vulnerability during the pre-denning and
denning period will necessarily be a consideration in planning any
land use activities in identified denning habitat.

In summary, it should be remembered that all species existing in
the wilds need adequate habitat. Maintaining present habitat
conditions is a difficult task. Making limited gains in the quality
and quantity of grizzly bear habitat is even more difficult. In sum
total, grizzly bear habitat is losing ground throughout the range of
the species (Jonkel 1980 pers. com.).

LEGAL STATUS

Protection afforded grizzly bears under the Endangered Species
Act is extensive. The possession, transportation, taking, sale and
receipt of grizzly bears or parts thereof are covered under special
regulation Part 17.40 of Title 50, Code of Federal Regulations (CFR).
The term "take" includes, harrass, harm, pursue, hunt, shoot, wound,
kill, trap, capture, collect or attempt to engage in any such conduct.

-28-

Title 50 CFR, Part 17.40 authorized certain exceptions to the
act. The regulations allow taking of a grizzly bear in defense of
human life, removal of nuisance bears by authorized federal or state
employees, federal or state research activities conducted under the
authority of permits issued by the Director of the Fish and Wildlife
Service and limited hunting in specific areas of northwestern Montana.
Any grizzly bear taken under the above situations must be reported to
the Fish and Wildlife Service, Division of Law Enforcement and
appropriate state officials, within five days.

Violation of the provisions of the Endangered Species Act can
result in a fine of $20,000 and one year in prison for a criminal
conviction and up to $10,000 in civil penalties. Criminal conviction
also carries provisions for: 1) modification, suspension or revocation
of any lease, license, permit or other agreement authorizing the use
of federal land, including the grazing of domestic livestock; 2)
revocation of federal hunting and fishing permits; and, 3) forfeiture
of all guns, traps, other equipment, vehicles, aircraft and other
means of transportation used in taking, possessing, selling,
purchasing, offering for sale or purchase, transporting, delivery,
receiving, carrying, shipping—in violation of the act. This
regulation currently prohibits the sale of any unlawfully taken
grizzly bear, hide, claws, or parts thereof, and supersedes wildlife
treaty rights relative to hunting, possession or selling of grizzly
bears except in accordance with federal or state regulations. Rewards
equal to one-half of the criminal or civil penalty or fine paid, not
to exceed $2,500 from the fine or penalty, may be authorized to any
person furnishing information which leads to a finding of civil
violations or criminal convictions of any provision of the Endangered
Species Act.

Subject to the provisions of the laws and regulations of the
State of Montana, licensed hunters may hunt grizzly bears in the area
referred to as the NCDGBE exclusive of Glacier National Park. Hunting
of grizzly bears in Montana is subject to a limitation of 25 grizzly
bears killed from all known man-induced causes in northwestern Montana
in any calendar year. This limit is to include those bears that have
been taken illegally, nuisance bears killed in control actions, bears
killed accidentally, in fact, any grizzly bear death that is
man-caused. The season will close when that number is reached or will
fail to open if 25 bears are known to have been killed before the
season is due to open.

Goals and objectives of this recovery plan will be attained and
funds expended contingent upon appropriations , priorities and
budgetary constraints; but the most important ingredient will be the
degree of commitment exhibited by individuals in supervisory
capacities toward saving the grizzly bear. Half-hearted attempts to
comply with the provisions of the Endangered Species Act, or the
recovery plan, may slow the bears rate of decline, but it will
certainly not reverse the trend. Inadequate funding or lack of full
cooperation by individuals, groups or agencies will only waste dollars

-29-

and eventually increase the cost of recovery or increase the costs of
tasks that will be necessary to prevent extinction at a later date.
An all-out concerted effort, with federal and state agencies and a
concerned public coordinating their resources, appears necessary to be
assured that the future will include grizzly bears.

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PART II

GRIZZLY BEAR RECOVERY PLAN OUTLINE

Primary Goal: To remove the grizzly bear from threatened
status in the 48 conterminous United States

In the wake of the human force spreading across the land, grizzly
bears have survived in certain refugia - primarily the national parks
and wilderness areas - in western North America. That this is true,
is altogether fitting with the purpose of these areas: to conserve,
perpetuate and portray as a composite whole, the indigenous flora and
fauna .

As relatively pristine environments, the national parks and
wilderness areas can fulfill the crucial role of providing a standard
of environmental health, the concept of which Aldo Leopold stated
years ago: "A person (or a society) cannot know what sickness is
without some criterion of health." UNESCO has embraced this idea
through its "Man and the Biosphere" program.

Hence, we may look toward national parks and similar refugia as
our best benchmarks, indicative of healthy communities of plants and
animals. It is with this rationale that we have selected available
grizzly bear population data from Yellowstone and Glacier National
Park to establish our recovery objectives for the species.

To be healthy, however, means to be whole. Since the national
parks may not constitute complete ecosystems for a wide ranging
species such as the grizzly bear, it is only proper and necessary to
delineate such intact ecosystems. It is within these areas that we
must apply systematic management to conserve habitats for healthy
grizzly bear populations.

Exploration and development of resources and increasing numbers
of people within the range of grizzly bears are rapidly dwindling the
space and habitat necessary for the bear's survival. All ecosystems
are being adversely affected and the time for decisions to reverse
this trend is now.

This plan addresses six areas in the conterminous 48 states where
grizzly bears are known to have been present during the past decade.
These six grizzly bear ecosystems appear to presently have adequate
space and suitable habitat to offer the potential for securing and
restoring this species as a viable, self-sustaining member of each
ecosystem .

The population parameters or their biological equivalents
necessary for recovery of the grizzly bear population in the Yellow-

-31-

stone Grizzly Bear Ecosystem (YGBE) , the Northern Continental Divide
Grizzly Bear Ecosystem (NCDGBE) , and the Cabinet-Yaak Grizzly Bear
Ecosystem (CYGBE) have been determined or estimated. Recovery levels
are defined for each of the populations.

Population parameters necessary for recovery of the species in
the Selkirk Mountains Grizzly Bear Ecosystem (SMGBE), Selway-
Bitterroot Grizzly Bear Ecosystem (SBGBE) and North Cascades Grizzly
Bear Ecosystem (NCGBE) are undetermined. This plan outlines some
management options for these populations and steps that will be
required to maintain the present population or to initiate actions to
effect recovery. r

The plan has been structured in a step down outline form
addressing each ecosystem. It is recognized that there is much
duplication between the sections addressing each ecosystem. However,
the initial data base on populations and habitat are significantly
different; the specific limiting factors are of varying magnitude
between ecosystems; the current management direction is different
between ecosystems; and the agencies and groups that have management
jurisdiction over the bulk of the grizzly bear habitat in each
ecosystem are different. It is for these reasons that we have
organized the plan in this manner. The agencies, groups, or
individuals that are involved or interested in each ecosystem have a
complete chapter addressing not only the elements all ecosystems have
in common, but also the elements specific to each ecosystem.

Management guidelines for National Forest and National Park lands
have been formulated for the YGBE but stratification of all Forest
lands has not been accomplished. Guidelines for the other five
ecosystems have not been formulated nor has any stratification of the
habitat been accomplished by any state or federal agency. Only the
Flathead Reservation within the NCDGBE has taken these steps and only
within the reservation boundaries.

-32-

ABBREVIATED STEP-DOWN OUTLINE

Objective: Describe methods and actions needed to
bring grizzly bear populations to
recovered status

1. State or establish the population objective and identify limiting
factors .

11. State or determine population conditions at which the species
is viable and self-sustaining.

12. State, estimate or determine current population conditions.

13. Identify the man-related population limiting factors if
present populations differ from desired.

131. Identify sources of direct mortality.

132. Identify sources of indirect mortality.

2. Redress population-limiting factors.

21. Identify and reduce sources of direct mortality.

22. Identify and reduce sources of indirect mortality.

23. Monitor compliance with recovery plan.

3. State or determine the extent and quality of habitat and
space appropriate to the achievement of the population goal.

31. Identify or state occupied space and habitat.

32. Identify or state agency management stratification and
direction within occupied habitat.

33. Identify or state the differences between total acres with
agency stratification and management direction and total
acres in occupied space and habitat.

34. Recommend critical habitat.

35. Identify travel corridors connecting islands of habitat or
grizzly bear ecosystems.

4. Resolve differences between occupied space and habitat and
agency management stratifications and direction.

5. Monitor populations and habitats.

51. Monitor populations before and during recovery.

52. Monitor populations after recovery.

53. Monitor habitats before and during recovery.

54. Monitor habitats after recovery.

6. Manage populations and habitats.

61. Manage populations and habitats prior to recovery on
Federal lands.

62. Manage populations and habitats prior to recovery on
private and state lands.

63. Manage populations and habitats after recovery on all lands.

-33-

7. Monitor public attitudes.

71. Sample public viewpoint.

72. Formulate and implement plans for public acceptance.

8. Implementation of the plan.

9. Revise appropriate federal and state regulations and initiate
international cooperation.

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Figure 3. Yellowstone Grizzly Bear Ecosystem (occupied
territory) 1979.

RECOVERY PLAN

YELLOWSTONE GRIZZLY BEAR ECOSYSTEM

Subgoal: Secure and maintain a viable, self-sustaining
grizzly bear population in the Yellowstone
Grizzly Bear Ecosystem (Figure 3)

State or establish a population goal in reference to present
population conditions and limiting factors.

Yll. State or determine the level at which the grizzly
bear population is considered to be viable and
self-sustaining .

Ylll. The grizzly bear population in the Yellowstone Grizzly
Bear Ecosystem will be viable and self-sustaining when
monitoring efforts indicate that recruitment, natality
and mortality are at levels supporting a stable or
increasing population. The population will be judged
recovered (eligible for delisting) when it is
determined to be viable at a population size equal to
or greater than the population size documented by
Craighead et al. They documented a population consist-
ing of 229 bears based on a census efficiency of 77.3
percent, that was recomputed by Cowan (1975) to 301
bears based upon a census efficiency of 58.8 percent.
Due to undetermined recruitment and natural mortality
rates under free ranging conditions, the higher number
is recommended. Due to annual variations in the
environment, population characteristics will be judged
on a running six year average. During the 1959-67
period, a self-sustaining population associated with a
supplemental food source was documented by Craighead et
al. (1974) and is represented by the following
statistics :

Reproductive rate

0

651

(Craighead et al.
1974)

Females with cubs of
the year

14

889

(av. pop. 177)
(Craighead et
al. 1974)

19

2

(av. pop. 229)
(extrapolated from

Craighead et al.

1974)

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Females with cubs of
the year (cont'd)

25.2 (av. pop. 301)
(extrapolated
Craighead et al
1974 and Cowan,
1975)

Cubs/Females

2.209 (Craighead et al
1974)

Reproductive cycle

3.400 (Craighead et al
1974)

Estimated total avg.
annual mortality

33.2" bears

(Craighead et al
1974

RATE

18.65% (Craighead et al
1974)

17.10% (Shaffer 1978)

Avg. annual known
mortality

18.889 bears

(Craighead et al
1974)

Y112. Re-evaluate population criteria (Ylll) as new information
becomes available.

Y12. Determine or state present population characteristics.

Y121. The present grizzly bear population in the Yellowstone Grizzly
Bear Ecoysystem, which does not have a significant supplemental
food source, is described by the following population charac-
teristics computed as running 6-year averages (Blanchard and
Knight 1980) :

Reproductive rate 0.555** (Knight et al. 1979)

Females with cubs of

the year 12.000 (Knight et al. 1979)

(av. pop.
unspecified)

*1967 Mortality included an unusually high number of grizzly bears
that were killed after it was advertised that 1967 would be the
last year of hunting in Wyoming (Craighead, J. 1980 pers. com.)
**A higher rate of cub survival will lower the reproductive rate
needed for a stable population (Blanchard and Knight 1980).

-37-

Cubs/female
Reproductive cycle

1.900 (Knight et al.
3.000 -^(Knight et al.

1979)
1979)

Avg. annual known man-
caused mortality 11.000 (Knight et al. 1979)

The statistics in Y121 are based on a small sample at this time.
Continued research is needed to establish the parameters that
describe a viable self-sustaining population existing without a
significant supplementary food source.

Y122. Re-evaluate population data (Y121) as new information
is made available.

Y13. Identify or state the man-related population limiting

factors if present population characteristics are less than
those judged necessary to sustain a viable population.

Y131. Identify or state sources of direct mortality

Y1311. Illegal hunting

Y13111. Poaching, vandalism, malicious killing

Y13112. Accidental losses resulting from mistaken
identity by black bear hunters.

Y13113. Private citizen control by livestock

operators, apiarists, outfitters, resort
operators in protection of property.

Y1312. Accidental deaths

Y13121. Road kills (highway, train, etc.)

Y13122. Scientific error

Y1313. Control measures

Y13131. Agency (State, NPS or USFWS) control

Y131311. Livestock conflicts

Y131312. Other property damage

Y131313. Life threatening situations

Y13132. Private citizen control

Y131321. Self-defense

-38-

Y132. Identify or state activities which can indirectly
limit grizzly bear populations through adverse habitat
changes, human encroachment on grizzly bear habitat
and displacement, grizzly/human conflicts, or
adverse conflict resolution.

Y1321. Grazing operations

Y1322. Timber operations (including road construction)

Y1323. Mining, water development, and energy
exploration/ development

Y1324. Recreation operations

Y1325. Human development of conflicting enterprises,
(subdivisions, dog kennels, fish farms,
boneyards, garbage dumps, etc.)

Y1326. Cumulative impacts

Redress population limiting factors

Y21. Reduce the numbers of bears lost to the population
through direct man-caused mortality.

Recommended annual man-induced grizzly bear mortality goal
for expediting species recovery is zero . Since this
mortality level will not likely be achieved, reaching the
recovery goal will be expedited if all man-caused mortality
does not exceed the currently documented man-caused
mortality of 11 bears per year (Knight et al. 1979),
calculated as a running 6-year average. This level of
man-caused mortality is within the theoretical tolerance
limits of 5 to 6% man-caused mortality suggested by Cowan
(1972) .

Y211. Illegal hunting

Y2111. Provide a concerted law enforcement effort
by designating a specially trained law
enforcement team coordinated by the U.S. Fish
and Wildlife Service to minimize the illegal
kill of grizzly bears. One or more persons
representing the U.S. Fish and Wildlife
Service, National Park Service, U.S. Forest
Service, State of Montana, State of Wyoming
and State of Idaho will be appointed. Each
member will receive specialized training to
work on illegal kills of grizzly bears. The

-39-

team will be trained initially by the
Interagency Grizzly Bear Study Team (IAGBST)
and other biologists in such matters as
distribution, home ranges of identifiable
bears, movements by season, mating habits,
current location of radio-marked bears and
other biological information that may be
helpful to the team. Representatives from the
Forest Service and Bureau of Land Management
will be encouraged to attend in order to more
ably assist in gathering field evidence.

All incidents of grizzly bear kills,
suspected illegal activities, and rumors of
kills will be communicated between the
enforcement team, their respective agencies
and the IAGBST on a daily basis or as often
as is practical.

The Enforcement Team Leader will keep all
members of the enforcement team and the
IAGBST informed and will organize
coordination meetings as needed.

Special emphasis will be directed at covert
operations which may be operating
commercially .

The Enforcement Team will operate through an
interstate, interagency agreement under the
direction of the U.S. Fish & Wildlife
Service .

It is imperative that the group leader

establish a line of communications and

rapport with all field personnel, field

office staff and local law enforcement

agencies in order that he may be notified
immediately on a violation or threat of a
violation .

Public assistance will be solicted in
reporting suspected or known illegal kills.
Persons furnishing information which leads to
a finding of civil violation or a conviction
of a criminal violation of 50 CFR, Part 17.40
regarding grizzly bears, can be rewarded up
to one half of the fine or civil penalty not
to exceed $2,500.

-40-

States having toll free numbers for reporting
violations or for information should
publicize their numbers as a means of
reporting grizzly problems and grizzly bear
deaths .

Y2112. Reduce accidental losses resulting from mistaken iden-
tity by black bear hunters.

Y21121. The state conservation agencies will make
information available to all black bear
hunters to assist them in distinguishing
between black and grizzly bears.

Y21122. State agencies will issue special warnings to
black bear hunters using areas frequented
by grizzly bears.

Y21123. Black bear hunting regulations will be modi-
fied as appropriate to reduce or eliminate
areas of significant conflicts or time
periods of conflict.

Y21124. The special enforcement team will investigate
accidental grizzly bear kills and recommend
prosecution when appropriate.

Y2113. Reduce accidental deaths from other causes

Y21131. All agencies will increase warning signs
along highways and roads in high-use grizzly
bear areas.

Y21132. All agencies will increase efforts to clean
up carrion and other attractants along
highways and other routes within occupied
grizzly bear range. See "Guidelines" -
pages 15, 30 and 36.

Y21133. State and federal agencies will seek coopera-
tion of railroad train crews regarding the
reporting of all collisions resulting in
death of large animals that could attract
grizzly bears. Removal or burial of such
animals will be arranged.

Y21134. Reduce losses due to mishandling of bears,
e.g., an overdose of immobilizing drugs or by
improper post-handling. Only ex-periem ed
personnel that are certified by a sponsoring
unit having the required permits

-41-

and knowledgeable in the application of
capture techniques, immobilizing drugs,
transportation of drugged animals, scientific
data collecting, etc. will handle grizzly
bears. The safest effective drugs available
will be used.

Y21135. Prepare detailed guidelines for trapping,
immobilizing, transporting and handling
grizzly bears.

Y21136. Agencies responsible for licensing, con-
ducting, or in anyway overseeing rodent
damage control programs, using toxic
substances in occupied grizzly bear habitat,
should use the most selective (but effective)
rodenticide available, and use it in lowest
effective dosage. Poison bait will only be
used under the on-site supervision of a
certified applicator. Disturbances on the
treatment site should be created for a
minimum of three nights following application
of any rodenticide in order to discourage
scavenging by grizzly bears. Poisoning
within grizzly bear habitat should be delayed
as long as possible into July to minimize the
potential for grizzly bears to consume
poisoned rodents or bait (O'Gara 1980 pers.
com. ) .

Y2114. Agency control on federal lands will be in
accordance with 50 CFR 17.40.

Y21141. For grizzly bears involved in livestock
conflicts, animal damage control officers
will follow the "Guidelines" pages 11, 27, 35
and 59-64 and other appropriate interagency
agreements .

Y21142. All other agency control related to grizzly
bears should be governed by "Guidelines"
directions starting on page 59 and other
interagency agreements.

Y2115. Private citizen control. The only legal citizen
control of a grizzly bear is that related to self
defense. The law enforcement team should
carefully investigate every case of grizzly bear
mortality alleged to be self defense.

-42-

Y2116. Agency control on state and private lands. Follow
"Guidelines" direction, pages 61 and 62 related to
management situation 2 and other procedures
developed by the Fish and Wildlife Service and
wildlife agencies in accordance with applicable
federal or state laws and regulations.

Y212. Necessary removal of problem bears can be accomplished
by a state licensed hunter supervised by a qualified
employee of state conservation agencies. Sport hunting
on national forest, BLM, state and private lands is
recognized as a legitimate tool for managing grizzly
bear populations once recovery has been achieved and
for controlling nuisance grizzly bears. Species
managers must develop regulations to reduce mortality
of female grizzly bears.

Y213. The U.S. Fish and Wildlife Service will appoint a
grizzly bear mortality coordinator to tabulate annual
bear mortality for all grizzly bear ecosystems and
assure that all cooperating agencies and the public
have current mortality data. The coordinator will
maintain key contacts with all agencies and keep
detailed records of all conditions surrounding each
grizzly bear death. A standard form, meeting the needs
of all agencies will be prepared.

Y22. Reduce or eliminate activities identified in Y132 which
indirectly limit grizzly bear populations through adverse
habitat changes, human displacement of bears, grizzly/human
conflicts or conflict resolutions adverse to conservation of
grizzly bears.

Y221. Grazing operations

Y2211. On federal lands apply "Guidelines" to make

grazing operations compatible with grizzly bear
spacial and seasonal habitat requirements.
Management direction is currently given in
"Guidelines" pages 11, 27, 35 & 45 .

Y2212. On state and private lands, agencies and field
personnel of agencies involved in grizzly bear
management will communicate the intent of the
"Guidelines" as described above (Y2211) as a
cooperative extension effort.

Y222. Timber operations and fire management

-43-

Y2221. On federal lands apply "Guidelines" to make timber
operations compatible with grizzly bear spacial
and habitat requirements. Management direction is
currently given in "Guidelines", pages 6, 21, 34 &
40.

Y2222. On state and private lands, agencies and field
personnel of agencies involved in grizzly bear
management will communicate the intent of the
"Guidelines" as described above (Y2221) as a
cooperative extension effort.

Y223. Mining and energy operations

Y2231. On federal lands or lands where sub-surface rights
are under federal jurisdiction apply "Guidelines"
to make mining and energy operations compatible
with grizzly bear spacial and habitat
requirements. Management direction is currently
given in "Guidelines", pages 17, 32, 38 & 48.

Y2232. On state and private lands, agencies and field
personnel of agencies involved in grizzly bear
management will communicate the intent of the
"Guidelines" as described above (Y2231) as a
cooperative extension effort.

Y224. Recreation activities

Y2241. On federal lands apply "Guidelines" to make recrea-
tion activites compatible with grizzly bear
spacial and habitat requirements. Management
direction is currently given in "Guidelines",
pages 14, 28, 36 & 46.

Y2242. On state and private lands, agencies and field
personnel of agencies involved in grizzly bear
management will communicate the intent of the
"Guidelines" as described above (Y2241) as a
cooperative extension effect.

Y225. Human development. Land management agencies, state
regulatory agencies, county commissioners and county
zoning boards should give consideration to the needs of
grizzly bears in any actions requiring their approval.
When homes, summer homes, cabins, camps, farm
operations, etc., with attendant dog kennels, pig
farms, garbage dumps and boneyards are allowed to
invade the habitat occupied by

-44-

grizzly bears, they will directly or indirectly, but
effectively reduce the space and habitat necessary for
the bears survival. For private lands not subject to
the above restrictions, wildlife managers should give
consideration to purchase, lease or easement if habitat
components are necessary to survival of the species.

Y226. Monitor and determine the cumulative impact of past
project actions. Determine the cumulative effects of
all, or any combination, of the actions described above
(Y221-Y225) that may adversely impact grizzly bears.
Past adverse impacts on the bears, and their habitat,
must be a major consideration in the evaluation of any
new action (Jonkel 1979). New actions must be
evaluated on a regional basis to avoid the cumulative
effects of several well planned individual actions
impacting bears from too many directions
simultaneously. History records that at some point in
time, probably associated with the degree of stress,
grizzly bears no longer use certain portions of their
former range. Therefore, each new action has the
potential of being "the last straw," from the
standpoint of the bear, and every effort must be made
to evaluate each new action with respect to former and
future actions.

Y23. Coordinate, monitor and report on activiites relating to
redressing population limiting factors and monitor
compliance with recovery plan.

Determine the habitat and space required for the achievement of
the grizzly bear population goal.

Y31. State or determine occupied space and habitat where
management gonsiderations for grizzly bears are
necessary. -

Y311. Identify or state occupied grizzly bear space and
habitat by land ownership and administrative unit.
Occupied space and habitat were delineated by workshop
members participating in a grizzly bear recovery
planning workshop December 6 and 7, 1979, Missoula,
Montana (Fig 3 and Table 2) . Present occupied habitat
boundaries will be corrected as new data become
available .

-45-

Y312. Identify or state Forest Service, Bureau of Land
Management, state and National Park Service management
stratifications within occupied space and habitat (See
Table 2).

Y32. Compare agency management stratifications by administrative
unit with occupied space and habitat delineations and
identify areas where additional management stratification or
management direction is necessary (See Table 2).

Y33. Correct data in Table 2 as new information is
available .

Y34. Recommend critical habitat

Resolve differences between occupied space and habitat versus
agency stratifications within occupied habitat (Table 2), and/or
adjust presently delineated stratifications.

Assumptions :

The November 5, 1979 biological opinion of the Fish and Wildlife
Service issued to the Forest Service is that "Implementation of
the Guidelines for Management Involving Grizzly Bears in the
Greater Yellowstone Area will promote the conservation of the
grizzly bear." Regions 2 and 4 of the forest service have fully
implemented the "Guidelines" including stratification of all
occupied grizzly bear range in terms of appropriate management
situations and managment direction. Forest Service Region 1 has
implemented the "Guidelines" only to the extent that Management
Situation 1 has been applied to "essential habitat" designated by
USFS in 1977. The remainder of Region 1 occupied habitat is
unstratified and without the interim management direction
outlined in the "Guidelines." Forest Service Region 1 states
they will address this subject through forest planning. The Fish
and Wildlife Service, states of Montana, Wyoming and Idaho, and a
majority of participants attending the grizzly bear recovery
planning workshops agreed in principle with the "Guidelines";
specifically that occupied habitat and space should be stratified
in terms of management direction that reflects the differing
intensities and importance of grizzly bear use.

This plan recognizes that Management Situations 1, 2 and 3, which
are most frequently applied, adequately provide for grizzly bear
survival and recovery if fully applied with a commitment to
recover the species. The plan specifically recognizes that areas
designated as Management Situation 1 provide adequate and
necessary conservation measures for grizzly bears, and also

-46-

recognizes that provisions are made for reclassification of other
areas to Management Situaton 1 if use representing need is
documented .

NOTE: Persons attending the workshops were not all in full agree-
ment with acreages designated for occupied habitat, habitat
stratification or areas for resolution. Numerous calls suggest-
ing boundary changes were received during plan formulation, some
with apparent justification and some for reasons unknown.
Further, there appeared to be a variance in the interpretation of
the Criteria for Grizzly Bear Critical Habitat Identification
(USFS, 1975) used in the delineation of essential habitat, be-
tween forests and between forest districts; and, almost no data
on state or private lands. Reconvening the workshops to review
each suggested change seemed impractical. Therefore, the
acreages presented will have to suffice for a beginning (see
Footnote 5), the refinement of occupied habitat and habitat
stratification is a plan element.

Y41. Areas for resolution and/or adjustment within the Shoshone
National Forest which includes 9,000 acres of state and
private land.

Y42 . Areas for resolution and/or adjustment within the Targhee
National Forest.

Y421. 7,025 acres of state and private land

Y422. 38,000 acres of MS2 to be re-evaluated for possible
adjustment to MSI" Fish Creek area (most was originally
in MSI in 1977)

Y43. Areas for resolution and/or adjustment within the Bridger-
Teton National Forest.

Y431. 3,820 acres of state and private land

Y432. 9,300 acres of MS2 to be re-evaluated for adjustment to
MSI- Rosie's Ridge

Y44. Areas for resolution within the Gallatin National Forest

Y441. 176,000 acres of unstratified lands (forest, private
and state) within the occupied space and habitat that
are in need of management stratification and
direction .''""

"Habitat components and sightings over last several years
(Knight 1980 pers. com.).
""USFS lands are being stratified (4-8-81).

-47-

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-48-

Y442. Review 20,000 acres of area between Taylor Fork and
Muddy Creek along the divide and including the
Taylor-Hilgard Range for inclusion in occupied grizzly
bear range in light of the comments regarding occupied
habitat in the Buck Creek-Yellow Mules final environ-
mental statement.

Y443. Re-evaluate 20,000 acres for possible inclusion in MSI
Horse Butte, Red Canyon and south of Taylor's Fork

Y444. 33,000 acres of state and private land

Y45 . Areas for resolution within the Custer National Forest
which include 2,000 acres of state and private land.

Y46. Areas for resolution within Grand Teton National Park and
the John D. Rockefeller, Jr. Memorial Parkway, none.

Y47 . Areas for resolution within Yellowstone National Park, none.

Y48. Areas for resolution within lands administered by the Bureau
of Land Management.

Y481. 2,800 acres of land within occupied space and habitat
in Idaho that are in need of stratification and
management direction relative to grizzly bears.

Y482. Unknown acres of land within occupied space and habitat
in Montana that are in need of stratification and
management direction relative to grizzly bears.

Y49 . Approximately 55,000 acres of state and private land are
within the occupied space and habitat of this grizzly bear
ecosystem. These lands, both within or adjacent to USFS and
BLM lands, are not stratified for grizzly bear management
relating to direct grizzly mortality and grizzly/human
conflicts potential. Agencies should encourage landowners
to eliminate conditions related to problems. Management
direction described in "Guidelines" would be appropriate in
principle as solutions Long-range solutions include
purchases, easements or leases, if warranted and other
solutions are unavailable. All agencies should identify
parcels representing actual or potential problems.

-49-

Y49A. Coordinate, monitor, and report activities related to
resolving differences between occupied space and
habitat and agency stratification and management
direction and monitor compliance with recovery plan.

Monitor grizzly bear population and habitats.

Y51. Monitor grizzly bear population prior to recovery.

Y511. Develop and conduct an intensive monitoring system to
measure the selected population parameters by using an
appropriate experimental design with sufficient
sampling effort to permit valid comparisons with the
benchmark statistics in Ylll.

Y512. Collate, analyze and compare current research data with
with benchmark statistics to determine recovery
progress and plan compliance. Coordinate population
analysis to assure a common understanding of techniques
used in on-going studies.

Y513. Standardize observation report forms and encourage all
agencies to require field personnel to use them;
develop procedures for verification of reports on
grizzly bears and submit copies of all observations,
reports of sightings, verifications and other relevant
information to the Grizzly Bear Recovery Coordinator.
He in turn will submit monthly reports to effected
personnel and agencies. Report forms 4 and 5 found on
pages 124-125 of the "Guidelines" are examples.

Y52. Monitor grizzly bear population following recovery.

Y521. Develop and conduct an extensive monitoring system to
index one or more of the selected population parameters
and to provide information on the geographical and
ecological distribution. This should be a systematic
sampling method to allow valid assessments of
population trends by managers.

Y522. Standardize the monitoring procedures and reports and
deposit all reports with the Grizzly Bear Recovery
Coordinator, who will submit monthly reports to
relevant agencies and personnel.

Y53. Monitor grizzly bear habitat prior to recovery.

Y531. Continue habitat surveys to refine current habitat
delineations and habitat stratifications. Use a mapping
scale appropriate for valid assessments of trends

-50-

(changes in quality, loss or gain) in habitat
components. Standardize terminology (see BGP Special
Report No. 41).

Y532. Within the context of current habitat delineations and
stratification, develop a more refined grizzly bear
habitat classification management system to determine
more precisely the nature and extent of habitat.

Y5321. Refine classification and map habitat components,
giving non-wilderness areas first priority.

Y5322. Establish a quality index for the extent of the
habitat components in the ecosystem.

Y5323. Establish a benchmark of present habitat values to
measure the cumulative effects of all actions over
time that have impacted grizzly bear habitat.

Y5324. Monitor changes in grizzly bear use of habitat
components under various types and degree of human
use (i.e., logging, mineral or energy
exploration/development, recreation, etc.).

Y5325. Report management activities used successfully to
improve habitat.

Y54. Monitor grizzly bear habitat following recovery.

Y541. Inventory and map changes in extent of habitat
components every 5 years.

Y542. Continue evaluation of present habitat changes to
measure cumulative effects of all actions over time
that have impacted grizzly bear habitat.

Y543. Coordinate and review agency action plans, report
periodically on status of recommended action programs
necessary for plan compliance and advise appropriate
agencies on actions necessary to avoid relisting of
the species.

Y6. Manage grizzly bear population and habitats.

Y6l. Manage populations and habitats on Federal lands by applying
management guidelines developed to maintain or enhance
habitats, to make land use activities compatible with
grizzly bears spacial and habitat requirements; to minimize
the potential for human/bear conflicts.

-51-

Y611. Develop and refine procedures for relocating grizzly
bears: Refine "Guidelines" relative to relocation of
bears as needs dictate and research indicates.

Y6111. Develop and coordinate procedures to expedite the
relocation of nuisance bears, review and update
interagency agreements (NPS , FS , WGSJ7, IF&G,
MFW&P, FWS) see pages 57-64 "Guidelines," make a
determined effort to relocate bears within 24
hours and continue search for new release areas.

Y6112. Research and develop methods to rehabilitate
problem bears and develop an aversive conditioning
of the bear that will cause the bear to avoid
repeating the behavioral pattern that led to the
human/bear confrontation. The track record on
relocated bears staying out of trouble is less
than good. The learned behavior of the original
experience that caused them to be a problem bear
appears to persist; after several similar
encounters the grizzly bear is usually dispatched.

Y6113. Develop and coordinate interagency agreements and
procedures for the introduction of grizzly bears
into areas of former habitat or to bolster low
level populations outside the YGBE . Note: Strong
leadership will be necessary to reach agreements
between all state and federal agencies and a
thorough investigation conducted prior to
transplanting bears to areas of low populations or
for the introduction of new populations. Using
nuisance bears for this purpose should be
discouraged unless rehabilitation training is
proven to be successful.

Y612. Control or remove documented nuisance grizzly bears on
all lands within recommended mortality levels per
criteria and steps on pp. 59-62 of the Guidelines (see
Y21)-.

Y62. Manage populations and habitats on private and state lands
by developing and applying management guidelines prior to
recovery that maintain or enhance habitats and recommend
land use activities compatible with grizzly bear
requirements for space and habitat; minimize potential for
human/bear conflicts. See Y611 and Y612.

"Removal of nuisance bears by a state licensed hunter, supervised
by a qualified representative of a state wildlife agency, is an
acceptable option.

-52-

Y63 . Continue to manage habitats and populations on all lands
upon recovery of the grizzly bear population in the
ecosystem. Refine control methods, establish harvest quotas
and develop a coordinated system for sport hunting of
grizzly bears on non-park lands.

Y631. Intensify management activities and monitoring of
grizzly bears in areas of sheep allotments to reduce
losses of both bears and sheep.

Y632. Establish baseline data on grizzly bears for at least
two years prior to issuance of any permit for major
construction activities that may create a disturbance
for grizzly bears that may cause them to abandon the
area .

Y633. Monitor radio-tagged grizzly bears in the areas where
special permits or unusual activities that may impact
grizzly bears are being conducted.

Develop and initiate appropriate information and education
programs .

Reducing man-induced mortalities is a major factor in
effecting the recovery of the grizzly bear. Therefore, it is
crucial to the recovery effort that people understand
reasons for actions in order to have a favorable attitude
toward the bear. Private conservation organizations
interested in the recovery of grizzly bears could be of
assistance if they would disseminate appropriate information
in their publications and news releases.

Y71. Sample, quantify and evaluate public attitudes toward

grizzly bears, grizzly habitat protection and maintenance,
land use restrictions, mitigating measures, relocation of
bears, hunting, nuisance bear control actions and habitat
acquisition or easement.

Y711. Sample and evaluate attitudes of people residing in or
adjacent to grizzly bear management areas.

Y712. Sample and evaluate attitudes of people geographically
removed from grizzly bear management areas.

Y72. Formulate ways to improve public attitudes and acceptance of
habitat maintenance and protection, research and management.
Agencies having the authority and responsibility for control
actions will institute and carry out information and
education programs to inform citizens having problems with
grizzly bears of the appropriate procedures and contacts for
assistance .

-53-

Y73. Develop means to extend public attitudes to actions plans
and/or funding.

Y8. Implementation of plan by jobs, priority and cost. To facilitate
implementation the Fish and Wildlife Service will appoint a
Grizzly Bear Recovery Coordinator to collate all relevant
information on grizzly bears, coordinate and stimulate compliance
and action to implement recovery plan. He will submit progress
reports and conduct workshops and meetings as necessary. This is
a particularly important position that will provide a central
focal point for the accumulation, exchange, and dissemination of
information, and a central point for multi-agency coordination
that will greatly aid in the judicious use of resources and
materially enhance the recovery effort. The Fish and Wildlife
Service should expeditiously establish this position.

Y9 . Revise appropriate federal and state regulations to reflect
current situations and facilitate implementation of actions
necessary for species recovery.

-54-

YGBE FOOTNOTES

1/ It is difficult to determine the total population of a
secretive, wide-ranging species such as the grizzly bear which
occupies rugged, wilderness areas. Appropriate and monitorable
population parameters which indicate population status can serve as an
alternative to a total population figure. The parameters selected as
benchmark indicators are based upon Craighead et al. (1974) which
represent :

(1) the Yellowstone grizzly bear population from 1959-67; (2) a census
efficiency computed to be 77.3%"'; and, (3) a population which was
increasing at a computed rate up to 2.4% annually with an age
structure of 18.6% cubs, 13% yearlings, 24.9% subadults , 43.7% adults
(N=177) (Craighead et al., 1974).

The following assumptions relate to the population parameters,
habitat and space judged necessary to grizzly bears:

a. Craighead et al. (1974) represents the only long-term
source of data on Yellowstone grizzly bears that contains
quantified population parameters relating to a population
level estimated from a calibrated sample.

b. The estimated population occurring between 1959-67 is
assumed to represent a population that would not require
the protection of ESA; i.e., a recovered population

(see pp. 2 of Introduction).

c. The space and habitat occupied at the present time (Fig 3),
under appropriate management, is adequate to serve the needs
of a population indicated by the above statistics.

d. The population parameters for comparison will be computed as
a running 6-year average to assure a real population
response up to a recovery level, rather than simply
population stability at a lesser level that may be
inadequate .

e. Current distribution and behavioral patterns of grizzly
bears are probably fundamentally different from those of the
1959-67 period. However, there is insufficient evidence
in grizzly bear literature to assume current or future
population characteristics could not resemble those of
the earlier population. Beecham (1980) found a strong

"58.8% census efficiency computed by Cowan et al. (1975 pers.
com . to Cole) .

-55-

correlation between nutrition and productivity of two Idaho
black bear populations; any major vegetative change
or removal of arificial food sources would affect growth
rates and therefore the reproductive potential of the
population. Intensive monitoring will document the ex-
tent of difference or similarity.

Blanchard and Knight (1980) qualify the present population
indicators as follows:

2/ "Accurate estimates of the number of grizzly bears
inhabiting the YGBE have eluded us for several^ reasons. The study
areas covers over 7700 square miles (20,000 km ) of rugged isolated
terrain which is 70 to 75% timber covered. Even our most optimistic
estimate of 350 bear places^ the density of grizzly bears at only one
per 20 square miles (50 km ) . The most pessimistic estimate of 84 or
less (Craighead et al . 1974) places the density at one bear per 95

square miles (245 km ). Given these natural low densities, nocturnal
habits of Yellowstone grizzly bears and the physiography of the study
area, accurate estimation of the entire population is difficult."
Present population indicators in the YGBE are based on data from the
Blanchard and Knight (1980) (1) for the 1974 to 1979 period; (2) an

unknown census efficiency, " although observability of instrumented

bears indicates that it is significantly less then 77%", (Blanchard
and Knight 1980); (3) a population of unknown stability with an age
structure of 6.5% cubs, 16% yearlings, 37% subadults, 40.3% adults,
(N=62), (Blanchard and Knight 1980).

3/ The reproductive cycle of 3.0 from Knight et al. (1979) is
believed to be from an insufficient sample size (N = 5).
Consequently, the reproductive cycle of 3.4 (N=68) (Craighead et al.
1974) was used to compute the current reproductive rate.

4/ Guidelines for Management Involving Grizzly Bears in the
Greater Yellowstone Area (1979). U.S. Forest Service and National
Park Service personnel, with the support of the state wildlife
agencies of Montana, Wyoming, and Idaho, cooperatively developed
guidelines for grizzly protection and management in the national
forests and national parks of the Greater Yellowstone Area. The
"Guidelines" received a favorable biological opinion from the U.S.
Fish and Wildlife Service following a request for consultation by the
U.S. Forest Service. Recognizing the "Guidelines" were written with
terms primarily applicable to the Forest Service and Park Service, we
believe the concept is sound for other federal agencies, state
agencies and for lands administered by private enterprise to minimize
human/grizzly conflicts causing adverse impacts to the bear or its
habitat .

5/ The occupied space and habitat for each grizzly bear
ecosystem was estimated by qualified personnel in attendance at each

-56-

of six workshops. The precision of the designation of occupied
habitat was a function of the amount of formal research conducted in
the respective areas and the degree of familiarity various qualified
personnel had with specific areas or regions. Species occurrence and
presence of habitat components were major considerations.
Consideration was given to what is biologically and ecologically
practical and feasible for grizzly bears. Delineated areas are those
where management considerations for grizzly bears are deemed
necessary. The boundaries include areas which have different relative
values to grizzly bears. Some areas may be necessary to species needs
and survival, while others may be used but not needed. Boundaries will
be adjusted as new data become available.

-57-

-58-

RECOVERY PLAN

NORTHERN CONTINENTAL DIVIDE GRIZZLY BEAR ECOSYSTEM

Subgoal: Secure and/or maintain a viable, self-sustaining

grizzly bear population in the Northern Continental
Divide Grizzly Bear Ecosystem (NCDGBE) (Fig 4)

Nl . Establish a population goal in reference to the present
population conditions and limiting factors.

The grizzly population parameters for the NCDGBE are not as
well documented as those for the Yellowstone Grizzly Bear
Ecosystem. However, Martinka has population data for
Glacier National Park from 1967 through 1976. Based on
population parameters computed for a 290 square mile census
area, and an assumed census efficiency of 100%, a stable
population at K (carrying capacity) is presumed (Martinka
1980 pers. com.). From a density of 1 bear per 8.2 square
miles in the study area, Martinka has extrapolated these
data to a total average Park population of 201 grizzly bears
during the study period. Natality and immigration were
assumed to equal mortality and emigration. Thus, the
average annual mortality rate is computed to be 17.8%
(Martinka 1974).

An age structure of 17.0% cubs, 18.5% yearlings", and 64.5%
subadults and adults is indicated from these data. When
consideration is given to the difference in study
conditions, and an assumed reduction in cub and subadult
mortality and breeding failures on a dispersed population,
the age structure for the GNP population is not
significantly different from that of the more intensively
studied 1959-67 population in the YGBE . That population was
18% cubs, 13% yearlings and 68.6% subadults and adults
(Craighead et al. 1974).

The data indicated that an average of 10% of the total Park
population were females with cubs in any given year, and
that there were an equal number of females with yearlings.
In addition, 10% (or more) are assumed to be breeding
females each year at 4.5 years of age and older. This
assumes that a minimum of 60 adult female grizzly bears are
present in the Glacier National Park population. Shaffer

Includes an undetermined number of litters with young of age
two or older (Martinka 1980 pers. com.).

-59-

(1978) computed that 32.07% of the total numbers of females
over 4.5 years of age in the Yellowstone population were
productive in any given year. Therefore, 62-64 females of
breeding age may be a more accurate estimate for the Glacier
National Park population. The GNP data are used as a benchmark
in determining a population goal for the entire NCDGBE.

Nil. State or determine the level at which the grizzly bear population
is considered to be viable and self-sustaining.

Nlll. The grizzly bear population in the NCDGBE will be viable and

self-sustaining when monitoring efforts indicate that recruitment,
natality, and mortality are at levels supporting a stable or
increasing population. The population will be judged recovered
(eligible for delisting) when it is determined to be viable at
a population size of 440-680 bears (current estimated levels)
or above and/or monitoring efforts document the following
statistics or their biological equivalents computed as a running
six year average:

Reproductive rate

Females with cubs
of the year

0.593

56.0

(Martinka
1974a)

(Martinka
1974a)

(10% of total
population)

Cubs/females

Reproductive cycle

Avg. annual known man-
caused mortality

Avg. annual total
mortality as % of
total population

1.78

(Martinka
1974a)

3.0 years
25.0 bears Legal limit

(Martinka 1980
Pers. comm.)

18.65

17.10
17.80

(Craighead et

al. 1974)
(Shaffer 1978)
(Martinka

1974a)

'^Population estimates varied from 440 to 680 bears and were
extrapolated from known densities in five study areas and
knowledge of the extent of similar habitat within the 5.7
million acres of occupied habitat. 1_/ (Jonkel, Servheen,
Craighead, J., 1980 all pers. com.). The mean (560) was
used to establish a goal.

-60-

N112. Re-evaluate population criteria (Nlll) as new
information becomes available.

N12. Determine or state present population characteristics

N121. The grizzly bear population in the Northern Continental
Divide Ecosystem can currently be described in terms of
the following statistics based on best estimates:

Reproductive rate 0.524 to

0.676

Females with cubs

of the year - low est.

high est.

Cubs /female

Reproductive cycle:

Avg. annual known man-
caused mortality

2/

38.0
58. 0±-'

1.78
2.3

3.4

18.2*

(Cub/female ratio
below divided by
repro. cycle)

(Servheen (1980)
(Servheen 1980)

(Martinka 1974)
(Servheen 1980
pers. comm.)

(Craighead et
al. 1974)

(Greer 1979
pers. com.)

For further reference on population parameters see pages
at end of this chapter and appendix A.

N13. Identify or state the man-related population limiting factors
if present population characteristics are less than those
judged necessary to sustain a viable population.

N31. Identify or state source of direct mortality.

N1311. Hunting

N13111. Illegal hunting

N131111. Poaching, vandalism, malicious killing

N131112. Accidntal losses resulting from mistaken
identity by black bear hunters.

*9.4 deaths from hunting and 8.8 deaths from control actions and
illegal kills (Greer 1975-79).

-61-

Nl 3 1 1 1 3 . Private citizens, control by livestock

operators, apiarists, outfitters and
resort operators in protection of
property.

N13112. Legal hunting. Losses in the female segment
N1312. Accidental deaths

N13121. Road kills (highway, trains, etc.)

N13122. Scientific errors
N1313. Control measures

N13131. Agency (State, NPS, BIA, or USFWS) control
N131311. Livestock conflicts
N131312. Other property damage
N131313. Life threatening situations

N13132. Private citizen control--self-def ense

N132. Identify or state activites which can indirectly limit
grizzly bear population through adverse habitat
changes, human encroachment on grizzly bear habitat,
grizzly/human conflicts or adverse conflict resolution.

N1321. Grazing, bee keeping operations, etc.

N1322. Timber operations (including road

construction)

N1323.

Mining, water impoundments and
energy exploration/development

N1324.

Recreation operations

N1325.

Human development of conflicting

enterprises; subdivisions dog kennels, pig farms,
fish farms, boneyards, garbage dumps, etc.

N1326.

Cumulative impacts.

Redress population limiting factors

N21. Reduce the numbers of female grizzly bears lost to the
population through direct man-caused mortality.

-62-

The recommended annual man-caused female mortality goal
for expediting species recovery is zero. Since this
zero mortality goal will not likely be achieved,
recovery is dependent upon reduced man-caused mortality
of females. The Recovery Plan Group recommends that
man-caused mortality be reduced to less than 9 females
per year within occupied habitat (See Fig A) to
expedite recovery. (Average mortality for 1967 to 1979
was 9 females per year (Greer 1979 pers. com.).

N211. Hunting

N2111. Illegal hunting

N21111. Develop a specially trained law

enforcement team coordinated by the U.S.
Fish and Wildlife Service to minimize
the illegal kill of grizzly bears. One
or more persons representing the U.S.
Fish and Wildlife Service, U.S. Forest
Service, National Park Service, State of
Montana and enforcement personnel from
the Blackfeet and Flathead Indian
reservations will be appointed. Each
member will receive specialized training
to work on illegal kills of grizzly
bears. The team would be trained
initially by personnel of the Border
Grizzly Project (BGP) in bear biology,
home ranges of identifiable bears,
current locations of radio-marked bears,
and any other biological information
that would be helpful to the team. All
incidents of grizzly bear kills,
suspected illegal activities, and rumors
would be communicated between the
enforcement team, their respective
agencies and the BGP on a daily basis or
as often as is practical.

Representatives from the forest service
and Bureau of Land Management will be
encouraged to attend in order to more
ably assist in gathering field evidence.

The Enforcement Team Leader would keep
all members of the Enforcement Team and
the BGP informed and will organize
coordinaion meetings as needed. Special
emphasis would be directed at covert
operations which may be conducted
commercially. It is imperative that
the Group Leader establish a line of

-63-

communication and a rapport with all
field personnel, field office staff, and
local law enforcement agencies in order
that he may be notified quickly in case
of a violation, threat of a violation,
or to assist in preventing a violation.

Public assistance will be solicited in
reporting suspected or known illegal
kills. Persons furnishing information
which leads to a finding of civil
violation or a conviction of a criminal
violation of 50 CFR, Part 17.40 regarding
grizzly bears, can be rewarded up to
one-half of the fine not to exceed
$2,500.

States having toll free numbers for
reporting violations or for information
should publicize their number as a means
of reporting grizzly bear problems and
grizzly bear deaths.

The enforcement team will operate
through an interstate, interagency
agreement under the direction of the
U.S. Fish and Wildlife Service.

N21112. State conservation agencies will make
information available to all black
bear hunters to assist them in
distinguishing between black and grizzly
bears .

N21113. The special enforcement team will

investigate accidental grizzly bear
kills and recommend prosecution when
appropriate .

N2112. Legal hunting

N21121. State agencies will issue special

warnings to black bear hunters using
areas frequented by grizzly bears.

N21122. Purposeful hunting losses of females
will be reduced.

Examine the current grizzly bear hunting
program annually in terms of its
impacts on achieving the population goal

-64-

and develop alternatives which assure
compat ability between sport hunting and
goal attainment. The alternatives could
include regulations which (1) reduce
mortality in the female segment by
prohibiting the shooting of bears in
groups of two or more (only 33% of the
adult females would be vulnerable) , or
consider spring hunting when females are
less vulnerable; (2) spread the hunter
density by use of special permits; (3)
set quota on man induced female
mortality; and, (4) eliminate the
hunting of grizzly bears.

N2113. Reduce accidental deaths from other causes.

N21131. All agencies will increase warning signs
along highways and roads in high grizzly
bear use areas.

N21132. All agencies will increase efforts to
clean up carrion and other attractants
along highways and roads under their
jurisdiction. Suggested methods to
address this problem can be found in
"Guidelines for Management Involving
Grizzly Bears in the Greater Yellowstone
Area: .(December, 1979, pp. 15, 30 and
36). (See Footnote 4 YGBE)

N21133. State and federal agencies will seek

cooperation of railroad crews in reporting
all collisions resulting in deaths of large
animals that could attract grizzly bears.
Removal or distribution of such animals will
be arranged.

N21134. Agencies responsible for licensing,

conducting, or in anyway overseeing rodent
damage control programs using toxic
substances in occupied grizzly bear habitat
should use the most selective (but effective)
rodenticide available and use it in the
lowest effective dosage. Poison bait will
only be used under the on-site supervision of
a certified applicator. Disturbances on the
treatment site should be created for a
minimum of three nights following application
of any rodenticide in order to discourage
scavenging by grizzly bears. Poisoning

-65-

within grizzly bear habitat should be delayed
as long as possible into July to minimize the
potential for grizzly bears to consume
poisoned rodents or bait (O'Gara 1980 pers .
com. ) .

N21135. Reduce losses due to mishandling of bears,
overdoses of immobilizing drugs, or improper
post-handling care. Only experienced personnel
that are working under an Endangered
Species Act permit and are certified by
a sponsoring unit as knowledgeable in
the application of capture techniques,
immobilizing drugs, transportation of
drugged animals, scientific data col-
lecting, etc. will handle grizzly bears.
The safest most effective drugs avail-
able will be used.

N21136. Prepare detailed guidelines for trapping,
immobilizing, transporting, and handling
grizzly bears.

N2114. Agency control on federal lands will be in
accordance with 50 CFR, 17.40.

N21141. Animal damage control officers or agency
personnel will take actions similar to those
found in the "Guidelines" pages 11, 27, 35
and 59-64, and will follow appropriate
interagency agreements when controlling
grizzly bears involved in livestock
conflicts .

N21142. All other agency control related to grizzly
bears should be guided by the "Guidelines"
directions starting on page 59 and other
appropriate interagency agreements.

N2115. Control by private citizens. The only legal
citizen control of a grizzly bear is that related
to self defense. The law enforcement team should
carefully investigate each case of grizzly bear
mortality alleged to be self defense.

N2116. Agency control on private and state lands. Follow
principle described in the "Guidelines"
procedures, pages 61 and 62 related to Management
Situation 2, or other procedures developed by the
FWS, MFWP and BIA/Tribes in accordance with
federal and state laws and regulations.

-66-

N212. The Fish and Wildlife Service will appoint a Grizzly
Bear Mortality Coordinator to tabulate annual bear
mortality for all grizzly bear ecosystems and assure
that all cooperating agencies and the public have
current mortality data. The coordinator will maintain
key contacts with all agencies and keep detailed
records of all conditions surrounding each grizzly bear
death. A standard form meeting the needs of all
agencies will be prepared.

N22. Reduce or eliminate activites identified in N132 which
indirectly limit grizzly bear populations through adverse
habitat changes, human displacement of grizzly bears,
changes in bear behavior induced by human intrusion,
adverse grizzly/human conflict or adverse conflict
resolution .

N221. Grazing, bee keeping operations, etc.

N2211. Develop and apply systematic management guidelines
on federal lands to make grazing, bee keeping,
etc. operations compatible with grizzly bear
special, and seasonal habitat requirements.
Management direction is currently described in
"Guidelines," pages 11, 27, 35 & 45.

N2212. On state and private lands, agencies and field
personnel of agencies involved in grizzly bear
management will communicate intent of the
"Guidelines" as described in above (N2211) as a
cooperative extension effort.

N222. Timber operations (including road construction,
reforestation, etc.)

N2221. Develop and apply systematic management guidelines
on Federal lands to make timber operations
compatible with grizzly bear spacial and habitat
requirements. Management direction is currently
described in "Guidelines," pages 17, 32, 34 & 40.

N2222. On state and private lands, agencies and field
personnel of agencies involved in grizzly bear
management will communicate intent of "Guidelines"
as described above (N221) as a cooperative
extension effort.

-67-

N223. Mining and energy operations

N2231. Develop and apply systematic management guidelines
on Federal lands to make water development and
mining and energy operations compatible with
grizzly bear spacial and habitat requirements.
Management direction is currently described in
"Guidelines," pages 17, 32, 38 & 48.

N2232. On state and private lands, agencies and field
personnel of agencies involved in grizzly bear
management will communicate intent of "Guidelines"
as described above (N2231) as a cooperative
extension effort.

N224. Recreation activities

N2241. Develop and apply systematic management guidelines
on Federal lands to make recreation operations
compatible with grizzly bear spacial' and habitat
requirements. Management direction is currently
described in "Guidelines," pages 14, 28, 36 and 46
and in the Glacier Bear Management Plan.

N2242. On state and private lands, agencies and field
personnel of agencies involved in grizzly bear
management will communicate intent of "Guidelines"
as described above (N2241) as a cooperative
extension effort.

N225. Human development. Land management agencies, state
agencies, county commissioners and county zoning boards
responsible for regulating homes, summer homes, cabins,
camps, farm operations, etc., that may have attendant
dog kennels, pig or goat farms, garbage dumps, and
boneyards, should give consideration to the needs of
grizzly bears in any actions requiring their approval
when these activities invade the occupied habitat of
the grizzly bear. For private lands not subject to the
above restrictions, wildlife managers should give
consideration to purchase, lease, or easement if
habitat components are necessary to survival of the
species and other solutions are unavailable.

N226. Monitor and determine the cumulative impact of past
project actions. Determine the cumulative effects of
all, or any combination, of the actions described above
(N221-N225) that may adversely impact grizzly bears at
a multiple or amplified level. Past adverse impacts on

-68-

the bears and their habitat must be a major consid-
eration in the evaluation of each new action (Jonkel
1979). New actions must be evaluated on a regional
basis to avoid the cumulative effects of several well
planned individual actions impacting bears from too
many directions simultaneously. History records that
at some point in time, probably associated with the
degree of stress, grizzly bears no longer use certain
portions of their former range. Therefore, each new
action has the potential of being "the last straw,"
from the standpoint of the bear, and every effort must
be made to evaluate each new action with respect to
former actions and future actions.

N23. Coordinate, monitor and report on activities relating to

redressing population limiting factors and monitor compliance
with recovery plan.

Determine the habitat and space appropriate to the achievement of
the grizzly bear population goal.

N31. State or determine occupied space and habitat where manage-
ment considerations for grizzly bears are necessary, kj

N311. Identify or state occupied grizzly space and habitat
by land ownership and administrative unit.

N3111. Occupied space and habitat were delineated by

workshop members participating in a grizzly bear
recovery planning workshop February 26 and 27,
1979, Missoula, Montana (Fig 4 and Table 3).

N3112. Occupied habitat boundaries will be corrected as
new data become available.

N312. Identify or state Forest Service, Bureau of Land Manage
ment, state lands and National Park Service management
stratifications within occupied space and habitat (see
Table 3.)

N32. Compare agency management stratifications by administrative
unit with occupied space and habitat delineations, and
identify areas where additional management stratifications or
management direction is necessary (see Table 3) .

N33. Correct data in Table 3 as new information becomes available

N34. Recommend critical habitat.

N35. Identify travel corridors connecting islands of habitat or
grizzly bear ecosystems.

-69-

Resolve differences between occupied space and habitat and agency
stratifications within occupied habitat (Table 3), and/or adjust
presently delineated stratifications.

ASSUMPTIONS:

A majority of the lands within the Yellowstone Grizzly Bear
Ecosystem have specific management direction through
stratification as per the "Guidelines." All of the federally
controlled lands in the NCDGBE (or elsewhere) are under the
general management direction per requirements of the Endangered
Species Act. In addition, the forest service lands have general
management direction spelled out in the National Forest Manage-
ment Act (NFMA) , Forest Service Manual (FSM) Chapter 2670, and
various Region One Manual Supplements. BLM lands have general
management direction in the Federal Land Policy and Management
Act (FLPMA) of 1976 (PL94-579). However, federal lands in the
NCDGBE currently do not have interim guidelines relative to
grizzly bear management of specific land areas as were developed
for the YGBE.

The forest service intends to incorporate such direction for
grizzly bear habitat management in each Forest Plan (due in 1983)
as per direction in NFMA and FSM 2672. BLM will incorporate
grizzly bear habitat management in their Resource Management Plan
(due in 1983). The National Park Service is currently
considering application of the "Yellowstone Guidelines"
stratification system to Glacier National Park. The Flathead
Tribal Council is currently considering a management plan
including stratification that has been proposed by their
biologists. It is not known what is currently being contemplated
relative to future management direction on BLM or Blackfeet
Indian Reservation lands.

Stratification, with attendant management direction, reflects
differing intensities and importance of grizzly bear use.
Management direction for each stratified area must provide
adequate conservation measures to assure that the continued
existence of the grizzly bear is not jeapardized. A "bear
refuge" is not implied, but rather directions to managers on
"how" to make an action compatible with bear management
objectives rather than "what" is to be done. In addition,
guidelines for stratification must recognize that reclassifica-
tion upwards will be necessary if documented evidence supports
that a specific area is vital to the survival of the species, or
downward if it is determined to be relative unimportant.

-70-

The development of interim management direction and/or guidelines
specific to grizzly bear management prior to 1983 (USFS) and for
all other lands is recommended to expedite recovery.

N41. Areas for resolution and/or adjustment within the Lewis
and Clark National Forest.

N411. 475,836" acres of stratified lands within occupied
space and habitat that are in need of management
direction .

N412. 304,064 acres of occupied space and habitat that are
in need of stratification and management direction
relative to grizzly bear use.

N413. 5,300 acres of private lands within the forest that
are in need of stratification and management direc-
tion.

N42 . Areas for resolution and/or adjustment within the Black-
feet Indian Reservation which include 138,000 acres of
private lands and tribal and allotted lands are in need
of stratification relative to grizzly bear use and need and
management direction.

N43 . Areas for resolution and/or adjustment within the Helena
National Forest.

N431. 70,925" acres of stratified lands within occupied space
and habitat that are in need of management direction.

N432. 103,148 acres of occupied space and habitat that are in
need of stratification and management direction rela-
tive to grizzly use.

N433. 6,958 acres of private lands within the forest that are
in need of stratification and management direction.

N434. 615 acres of state lands within the forest that are in
need of stratification and management direction.

N44. Areas for resolution and/or adjustment within the Lolo
National Forest.

N441. 146,942" acres of stratified lands within occupied

space and habitat that are in need of management direction.

-Essential habitat (1977) USFS.

-71-

N442. 87,087 acres of occupied space and habitat that are
in need of stratification and management direction
relative to grizzly bear use.

N443. 18,974 acres of private lands within the forest that
are in need of stratification and management direction.
Note: 800 acres are within USFS essential habitat
(1977)

N45 . Areas for resolution and/or adjustment within the Flathead
National Forest.

N451. 1,667,100* acres of stratified lands within occupied
space and habitat that are in need of management
direction.

N452. 388,548 acres of occupied space and habitat that are in
need of stratification and management direction
relative to grizzly bear use.

N453. 161,872 acres of private lands within the forest that
are in need of stratification and management direction.

N454. 18,737 acres of state lands within the forest that are
in need of stratification and management direction.

N455 . 38,400 acres of state forest lands (Swan State Forest)
within occupied space and habitat in need stratifi-
cation relative to grizzly bear use and needs and are
in need of management direction (outside Flathead
National Forest) .

N46. Areas for resolution and/or adjustment within the Kootenai
National Forest.

N461. 121,472* acres of stratified
space and habitat that are
ment direction.

lands within
in need of

occupied
manage-

N462. 4,047 acres of occupied space and habitat that are in
need of stratification and management direction
relative to grizzly bear use.

N463. 15,324 acres of state and private lands within the
Kootenai National Forest east of Highway 93 that are in
need of stratification and management direction
relative to grizzly bear use.

-'Essential habitat (1977) USFS.

-72-

N47. Areas for resolution and/or adjustment within the Flathead
Indian Reservation.

N471. 223,511 acres of tribal and allotted lands that have
been stratified by relative use and habitat components
of grizzly bears are in need of management direction.
Note: Management plan has been formulated and is
pending approval of the Tribal Council.

N472. 20,910 acres of private lands within the reservation
have been stratified relative to grizzly bear use but
lack management direction.

N473. 9,510 acres of state lands within the occupied range
of a grizzly bear that are in need of management
direction .

N48. Areas for resolution and/or adjustments within Glacier
National Park.

N481. 1,013,120 acres of occupied space and habitat that are
in need of stratification and management direction
relative to grizzly bear use.

N482. 713 acres of private lands that may require additional
management direction.

N49. Areas for resolution and/or adjustments within Bureau of
Land Management lands which includes 24,240 acres of BLM
lands that are in need of stratification and management
direction relative to grizzly bear use.

N49A. Areas for resolution and/or adjustment within private
and State lands which includes 230,000 acres of private
lands and 113,500 acres of State lands situated outside
of National Forests, BLM, Glacier National Park or
indian reservation boundaries, but within occupied
territory that need to be stratified for relative
grizzly bears use and attendant management direction
developed .

Identify land parcels with actual or potential problems
for grizzly bears.

N49B. Review all areas (federal, state, and private) following
stratification and assignment of management direction
to resolve differences between classifications made by
land managers and recommendations made by research and
wildlife managers; e.g., areas in Badger Creek, Montana
Creek and Red Meadow Creek were not included in the

-73-

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-75-

1977 Forest Service designation of essential habitat.
Many wildlife managers and researchers believe these
plus other areas belong in stratification and manage-
ment direction designation equal to essential habitat
or MSI.

Stratification of habitat for relative use implies that the
management direction will relate to direct grizzly bear
mortality, indirect (habitat related) mortality and human/
bear conflict potential. Private lands within and outside
Federal agency administrative boundaries are frequently high
risk areas for bears and often complicate agency management
direction. Landholders should be encouraged by agency and
county personnel to eliminate condi-tions that may create
human/grizzly conflicts. Manage- ment direction described
in the "Yellowstone Guide-lines" would be appropriate to
follow in principle for problem solution. Long-range
solutions may include closure, easements, leases or purchase
of problem areas if warranted, and if other satisfactory
solutions are unavailable.

Monitor grizzly bear population and habitats.

N51. Monitor grizzly bear population prior to recovery.

N511. Develop and conduct an intensive monitoring system to
measure the selected population parameters by using an
appropriate experimental design with sufficient
sampling effort to permit valid comparisons with the
benchmark statistics in Nlll.

N512. Collate, analyze, and compare current research data
data with benchmark statistics to determine recovery
progress and plan compliance. Coordinate population
analysis to assure a common understanding of techniques
used in ongoing studies. Circulate appropriate
reports .

N513. See Y513.

N514. Evaluate current mortality quota (N=25) annually and
adjust if research so indicates.

N52. Monitor grizzly bear population following recovery.

N521. Develop and conduct an extensive monitoring system to
index one or more of the selected population parameters
and to provide information on the trends in geographical

-76-

and ecological distribution. This should be a
systematic sampling method to allow valid assessments
of population trends by managers.

N522. Standardize the monitoring procedures and reports and
and deposit all reports with the Grizzly Bear Recovery
Coordinator, who will submit reports to all relevant
agencies and personnel.

N53. Monitor grizzly bear habitat prior to recovery.

N531. Develop a grizzly bear habitat classification/research
and management system to determine the nature and
extent of habitat components in the grizzly bear
ecosystem. Use a mapping scale appropriate for valid
assessments of trends (changes in quality, loss or
gain) in habitat components. Standardize terminology
(see BGP Special Report No. 41).

Classify and map habitat components giving nonwilder-
ness areas first priority.

Establish a quality index for the extent and condition
of the habitat components in the ecosystem.

Establish a benchmark of present habitat values to
measure cumulative effects of all actions over time
that have impacted grizzly bear habitat.

Monitor changes in grizzly bear use of habitat
components under the various types and degree of human
use (i.e. logging, mineral or energy exploration
recreation, etc.).

Determine and evaluate the results of habitat changes
and modifications in order to assess the cumulative
effects of these changes.

Identify conservation and enhancement procedures and
measures used successfully to improve habitat and
report annually.

N54. Monitor grizzly bear habitat following recovery.

N541. Inventory and map the changes in the extent of habitat
components every 5 years.

N542. Continue evaluation of present habitat values to mea-
sure cumulative effects of all actions over time that
have impacted grizzly bear habitat.

N532.
N533.
N534.

N535.

N536.
N537.

-77-

N543. Coordinate and review agency actions and plans; report
periodically on status of recommended actions and
programs necessary for plan compliance--advise
appropriate agencies on actions necessary to avoid
relisting of species.
Manage grizzly bear population and habitats.

N6l. Develop and apply systematic management guidelines on fed-
eral lands prior to recovery to maintain, enhance or
expand habitats; to make land use activities compatible with
grizzly bear spacial and habitat requirements; to minimize
the potential for conflicts ; and to resolve human/bear
conflicts .

N611. Develop and refine procedures for relocating grizzly
bears .

N6111. Refine present procedures, expedite handling and
search for new areas to relocate nuisance bears.
Review interagency agreements (See Y6111).

N6112. Research and develop methods to retrain problem
bears to develop avansive conditioning program that
will cause the problem bear to avoid repeating the
behavioral pattern that led to the human/bear con-
frontation (see Y6112 for additional comment).

N6113. Develop and coordinate interagency agreements and
procedures to introduce grizzly bears into areas
of former habitat or to bolster populations
nearing extirpation outside the NCDGBE (see note
following Y6113).

N612. Control or remove documented nuisance grizzly bears.

N62 . Manage population and habitats on private and state lands
prior to recovery by developing and applying systematic
guidelines; recommend land use activities that are compatible
with grizzly bear spacial and habitat requirements; minimize
potential for grizzly/human conflicts; resolve conflicts (see
N611 and N612).

N63. Continue management of population and habitats upon recovery
of the grizzly bear population in the ecosystem, review
control methods and harvest quotas for sport hunting of
grizzly bears on non-Park lands.

N631. Intensify management activities and monitoring of
grizzly bears in areas of sheep allotments; to reduce
losses of both bears and sheep.

-78-

N632. Establish baseline data on grizzly bears for at least
two years prior to the issuance of any permit for major
construction activities that may create an unusual
disturbance for the bears.

N633. Accelerate radio- tagging grizzly bears and increase
monitoring efforts in areas where special permits or
unusual activities may be impacting grizzly bears.

N7 . Develop and initiate appropriate information and education pro-
grams. Reducing man-induced mortalities is a major factor in
effecting the recovery of the grizzly bear. Therefore, it is
crucial to the recovery effort that people understand reasons for
actions in order to have a favorable attitude toward the bear.
Private conservation organizations interested in the recovery of
grizzly bears could be of assistance if they would disseminate
approprite information in their publications and news releases.

N71. Sample, quantify and evaluate public attitudes toward grizzly
bears, grizzly habitat protection and maintenance, land
use restrictions, mitigating measures, relocation of bears
hunting, nuisance bear control actions and habitat acquisi-
tion or easement.

N711. Sample and evaluate attitudes of people residing in or
adjacent to grizzly bear management areas.

N712. Sample and evaluate attitudes of people geographically
removed from grizzly bear management areas.

N72. Formulate ways to improve public attitudes and acceptance of
habitat maintenance and protection, research, and management

N73. Agencies having the authority and responsibility for control
actions will institute and carry out information and
education programs to inform citizens having problems with
grizzly bears of the appropriate procedures and contacts for
assistance .

N74. Develop means to extend public attitudes to action plans
and/or funding.

N8. Implementation of the Plan by jobs, priority and cost. To fa-
cilitate implementation the Fish and Wildlife Service will
appoint a Grizzly Bear Recovery Coordinator to collate all
relevant information on grizzly bears, coordinate and stimulate
compliance and action to implement rcovery plan. Submit progress
reports and conduct workshop and meetings as necessary (See Y81).

N9 . Revise appropriate federal and state regulations to reflect
current situations and facilitate implementation of actions
necessary for species recovery including the initiation of
international cooperation where appropriate.

-79-

NCDGBE

FOOTNOTES

1/ Study area densities averaged 1 bear per 15 square miles;
several research biologists suggested adjacent areas may harbor less,
bears or even half that density. Using these two extremes (1/15 mi
and 1/30 mi ) to estimate upper and lower limits for the population in
this ecosystem outside GNP, then adding 200 grizzly bears from GNP
(Martinka 1974) , a range of 440 to 680 bears was tentatively agreed
upon by persons working on bear in this ecosystem. Because the four
wilderness areas represent a very significant portion of this
ecosystem (2,515 square miles) and because they have not been studied
or sampled, it could be assumed they may harbor greater densities of
bears than the peripheral areas based on the intact habitat, fewer
disturbances, etc. Higher hunting success also seems to indicate this
may be true, however no additional grizzly bears were added to the
above estimates due to lack of data to support these assumptions.

2/ Servheen (1980) using the most conservative estimate for the
NCDGBE population (1/30 square miles exclusive of Glacier National
Park), computed an initial estimate of the numbers of adult females
(4.5 years and older) in this ecosystem. From a sample of 180 bears of
known sex and age (kills), Servheen (1980) developed a surviorship
curve which indicated 29% of the population were adult females (65).
To this estimate he added 60 females from GNP (Martinka 1974) to
conclude that there may be as few as 130 adult females in the
ecosystem. These data (29%) approximate the numbers of adult females
from data gathered in GNP by Martinka (1974) in which he estimated
that 29.8% of the population were adult females. Schaffer (1978),
interpreting data from the Yellowstone ecosystem (Craighead et al.,
1974), found 30.4% of the population were adult females.

7280 (total square miles) r 30 = 242 bears
242 + 200 (GNP pop.) = 442 bears (lower est.)
242 x .29 = 70 + 60 (GNP) = 130 adult females
130 7 3.4 reproductive cycle (Craighead et al. 1974) =
38 breeding females

Repeating the above process using the higher estimate (1 bear per 15
square miles), and adding GNP data, the upper estimate of 680 total
bears (198 adult females of which 58 could be breeding females) is
desired.

3/ The Endangered Species Act of 1973, as amended, requires
federal agencies to carry out conservation programs for grizzly bears
and other threatened and endangered species and to insure that any
action authorized, funded or carried out by such agency does not

-80-

jeopardize the continued existence of these species or result in the
destruction or adverse modification of their critical habitat. The
National Forest Management Act Regulations (Federal Register Volume
44, No. 181 Sept. 17, 1979) re-emphasizes the above and further
requires that "objectives be determined for threatened and endangered
species that provide for, where possible, their removal from listing
as threatened and endangered species through appropriate conservation
measures, including the designation of special areas to meet the
protection and management needs of such species. Forest Service
Manual 2672 states the direction for implementing the intent of the
National Forest Management Act Regulations.

National forests and national parks with lands in the Yellowstone
Grizzly Bear Ecosystem have adopted the "Guidelines for Management
Involving Grizzly Bears in the Greater Yellowstone Area" (December
1979). The "Guidelines" designate special areas which are stratified
in terms of management direction reflecting the differing intensities
and the importance of grizzly use. They provide for the protection
and management needs of the species in accord with existing laws. The
"Guidelines" provide interim direction while Forest Management Plans
are being prepared. They will be incorporated either intact or
amended into Forest Plans. Grizzly bear management guidelines for the
NCDGBE do not exist. Guidelines similar in concept and content to
those for the Greater Yellowstone Area are urgently needed, at least
on an interim basis.

4/ The occupied space and habitat for each grizzly bear
ecosystem was determined by qualified personnel in attendance at each
of six workshops. The precision of designating occupied habitat was a
function of the amount of formal research conducted in the respective
areas and the degree of familiarity various qualified personnel have
with specific areas or regions. Designation of the areas was based on
what is biologically and ecologically practical and feasible for
grizzly bears. Species occurrence and the presence of habitat
components were major considerations. Delineated areas are those
where management considerations for grizzlies are necessary. The
boundaries include areas which have different relative values to
grizzlies. Some areas may be necessary to species needs and survival,
others may not be needed. Boundaries will be adjusted as data become
available .

-81-

RECOVERY PLAN

CABINET-YAAK GRIZZLY BEAR ECOSYSTEM

Subgoal: Secure and/or maintain a viable, self-sustaining
grizzly bear population in the Cabinet-Yaak
Grizzly Bear Ecosystem (CYGBE) (Fig 4)

Establish a population goal in reference to the present
population conditions and limiting factors.

There are no documented population parameters for the CYGBE.
Adequate data on this population or any of its sub-areas are
lacking. Albert W. Erickson under contract with the Lolo
National Forest in 1973-74 indicated that a few grizzly bears
were present in the Thompson Falls, Plains and Trout Creek ranger
districts and deemed the area capable of supporting a small
resident population (Erickson 1976). Subsequently, Erickson under
contract with the Kootenai National Forest in 1976-77 estimated
that less than a dozen grizzly bears exist in the Cabinet
Mountains, and that extirpation could result if specific
management actions were not initiated in the near future
(Erickson 1978). His estimate apparently does not include
portions of the described ecosystem that are in the Yaak River
drainage or west of the Cabinet Mountains in Idaho.

The Cabinet Mountains and the Yaak River drainage may be
considered by some to be two distinct grizzly bear population
centers. However, using all of the data available at the time of
the workshop held in Libby, Montana, March 6,1980, those in
attendance made the decision to consider both areas to be parts
of one grizzly bear ecosystem. There is a break of some 10 or 12
miles between the occupied territory of the Cabinet Mountains and
that of the Yaak area. The linking corridor is a series of 10-12
mountain peaks forming a high divide zone that would offer
protection for bears moving between the two areas. Many
biologists working in the general area believe that interchanges
of grizzly bears between the Yaak area and the Cabinet Mountains
and between Yaak and British Columbia are necessary for the
continued existence of this population (See BGP Special Report
No. 41).

Attendants of the meeting and area biologists familiar with the
area, believe the habitat components and spacial requirements for
the species are adequate. They have delineated approximately
1,800 square miles as the presently occupied range of grizzly
bears in the ecosystem and believe the habitat will support a
viable population.

-82-

In order to establish a goal for this population, without benefit
of data equal to that of either the YGBE or the NCDGBE, a decision
was made to use a minimum viable population requirement established
by Shaffer (1978). Shaffer concludes, "A minimum viable population
(MVP) for any given species in any habitat is tentatively defined
as the smallest population having a 95% chance of remaining extant
for 100 years despite the foreseeable effects of — ." Using data
available for the Yellowstone grizzly bears and a computer simulation
for testing the relationship of population size and survival, he
hypothesizes that a population of 30 to 70 grizzly bears within
a minimum area of 2500 km2 (965 mi ) (Northern Rockies) to as much
as 7400 km2 (Brooks Range) (Shaffer 1978) , is required to support a
MVP. For purposes of erring on the side of the grizzly bear, the MVP
population goal for this ecosystem was set at the upper limit of 70
bears for the presently delineated area of 1,818 mi2 (1 bear/26 mi2).

Cll. State or determine the level at which the grizzly bear
Dopulation is viable and self-sustaining.

Clll. The grizzly bear population in the CYGBE will be viable

and self-sustaining when monitoring efforts indicate that

recruitment, natality, and mortality are at levels
supporting a stable or increasing population. The
population will be judged recovered (eligible for
delisting) when it is determined to be viable at a
population size of 70 bears or more and/or monitoring
efforts document the following statistics or their
biological equivalents computed as a running six year
average :

Reproductive rate 0.524 to 0.593 Cubs/female

divided by
repro. cycle

Females with cubs of
the year

7.0

(Martinka
1974a)
(10% of
total

est. pop.)

Cubs/ female

1.78

(Martinka
1974a)

Reproductive cycle

3.0 years

(Martinka

1974a)

(Craighead

3.4 years

et al .
1974)

Avg. annual known
man-caused
mortality
1968-78 (9 bears*)

less than
0.82 bears

(Greer 1980
pers. com.)

One bear legally killed by a hunter in 1974.

-83-

CI 12 . Re-evaluate population data (CI 1 1 ) as new information
becomes available.

C12. Determine or state present population characteristics which
are unknown at present.

C13. Identify or state the man-related population limiting factors
if present population characteristics are less than those
judged necessary to sustain a viable population.

C131. Identify or state the sources of direct mortality

C1311. Illegal hunting

C 1 3 1 1 1 . Poaching, vandalism, malicious killing

C13112. Accidental losses resulting from mistaken
identity by black bear hunters.

C13113. Private citizen control by livestock opera-
tors, apiarists, outfitters and resort oper-
ators in protection of property.

C1312. Accidental deaths

C13121. Road kills (highway, train, etc.)

C13122. Scientific error

C1313. Control measures

C13131. Agency (State, NPS, or USFWS) control

C131311. Livestock conflicts

C131312. Other property damage

C131313. Life threatening situations

C13132. Private citizen control

C131321. Self defense.

C132. Identify, estimate, or state activities which can
indirectly limit grizzly bear populations through
adverse habitat changes, human displacement of grizzly
bears, grizzly-human conflicts or adverse conflict
resolution.

C1321. Grazing operations

-84-

C1322. Timber operations (including road construction)

C1323. Mining, water impoundments and energy explora-
tion/development

C1324. Recreation operations

C1325. Human development of conflicting enterprises;

subdivisions, dog kennels, fish farms, boneyards,
garbage dumps, etc.)

C1326. Cumulative impacts

Redress population limiting factors.

C21. Reduce the numbers of bears lost to the population through
direct man-caused mortality.

Recommended annual man-induced grizzly bear mortality goal
for expediting species recovery is zero.

C211. Illegal hunting.

C2111. Provide a concerted law enforcement effort by
developing a specially trained law enforcement
team coordinated by the Fish and Wildlife Service
to minimize the illegal killing of grizzly bears.
One or more persons representing the Fish and
Wildlife Service, Forest Service, State of Idaho,
and State of Montana will be appointed. Close
coordination with law enforcement officers in
British Columbia and Alberta will be maintained.
Each member will receive specialized training to
work on illegal kills of grizzly bears. The team
would be trained initially by the Border Grizzly
Project (BGP) personnel in such matters as
distribution, home ranges of identifiable bears,
movements by season, mating habits, current
location of radio-marked bears and other
biological information that may be helpful to the
team. Representatives from the Forest Service and
Bureau of Land Management will be encouraged to
attend in order to more ably assist in gathering
field evidence.

All incidents of grizzly bear kills, suspected
illegal activities, and rumors of kills will be
communicated with the enforcement team, their
respective agencies, and the BGP on a daily basis
or as often as practical.

-85-

The Enforcement Team Leader will keep all members
of the enforcement team and the BGP informed and
will organize coordination meetings as needed.

Special emphasis will be directed at covert
operations which may be operating commercially.
The enforcement team will operate through an
interstate, interagency agreement under the
direction of the Fish & Wildlife Service. It is
imperative that the Enforcement Team Leader
establishes a line of communication and a rapport
with all field personnel and field office staff in
order that he may be notified immediately of a
violation or threat of a violation.

Public assistance will be solicited in reporting
suspected or known illegal kills. Persons
furnishing information which leads to a finding of
civil violation or a conviction of a criminal
violation of 50 CFR, Part 17.40 regarding grizzly
bears, can be rewarded up to one half of the fine
or civil penalty not to exceed $2,500.

States having a toll free number for reporting
violations or for information should publicize
their number as a means of reporting grizzly bear
problems and grizzly bear deaths.

C2112. Reduce accidental losses resulting from mistaken
identity by black bear hunters.

C21121. The state conservation agencies will make
information available to all black bear
hunters to assist them in distinguishing
between black and grizzly bears.

C21122. State agencies will issue special warnings to
black bear hunters using areas frequented by
grizzly bears.

C21123. The special enforcement team will investigate
accidental grizzly kills and recommend
prosecution when appropriate.

C2113. Reduce accidental deaths

C21131. All agencies will increase warning signs
along highways and roads in high use grizzly
bear areas.

-86-

C21132. All agencies will increase efforts to clean
up carrion and other attractants along
highways and other routes.

Suggested methods to address this problem can
be found in "Guidelines" pages 15, 30 and 36.
(See Footnote 3, YGBE)

C21133. State and federal agencies will seek the co-
operation of railroad train crews in re-
porting all collisions resulting in the
death of large animals that could attract
grizzly bears. Removal or burial of such
animals will be arranged.

C21134. Agencies responsible for licensing, con-
ducting, or in any way overseeing rodent
damage control programs using toxic
substances in occupied grizzly bear habitat
should use the most selective (but effective)
rodenticide available, and use it in the
lowest effective dosage. Poison bait will
only be used under the on-site supervision of
a certified applicator. Disturbances on the
treatment site should be created for a
minimum of three nights following application
of any rodenticide in order to discourage
scavenging by grizzly bears. Poisoning
within grizzly bear habitat should be delayed
as long as possible into July to minimize the
potential for grizzly bears to consume
poisoned rodents or bait (O'Gara 1980 pers.
com. ) .

C21135. Reduce losses due to mishandling of bears,
overdose of immobilizing drugs, or improper
post-handling. Only experienced personnel
who are working under an ESA permit and are
certified by a sponsoring unit as
knowledgeable in the application of capture
techniques, immobilizing drugs, transpor-
tation of drugged animals, scientific
data collecting, etc., will handle grizzly
bears. The safest effective drugs available
will be used.

C21136. Prepare detailed guidelines for trapping,
immobilizing, transporting and handling
grizzly bears .

C2114. Agency control on Federal lands will be in accordance
with 50 CFR 17.40

-87-

C21141. Animal damage control officers or agency
personnel will take actions similar to those
found in the "Guidelines," pages 11, 27, 35,
and 59, and will follow appropriate inter-
agency agreements, when controlling grizzly
bears involved in livestock conflicts.

C21142. All other agency control related to grizzly
bears should be similar to actions indicated
in the "Guidelines" directions starting on
page 59 or guided by appropriate agreements.

Control by private citizens. The only legal
citizen control of a grizzly bear is that related
to self defense. The law enforcement team should
carefully investigate each case of grizzly
mortality alleged to be self defense.

Agency control on private and state lands. Follow
principle described in the "Guidelines"procedures ,
pages 61 and 62 related to MS2, or other procedures
developed by FWS, MFW&P, IF&G, and in accordance with
Federal and State laws.

C212. See Y212, Part II

C213. See Y213 and N212, Part II

C22. Reduce or eliminate activities identified in C132 which
indirectly limit grizzly bear populations through adverse
habitat changes, human displacement of bears, changes in
bear behavior induced by human intrusion, adverse
grizzly/human conflicts or adverse or inadequate conflict
resolution.

C221. Grazing, bee keeping operations, etc.

C2211. Develop and apply systematic management guidelines
on Federal lands to make grazing operations,
beekeeping, etc. compatible with grizzly bear
spacial, and seasonal habitat requirements.
Management direction is currently given in
"Guidelines", pages 11, 27, 35 & 45.

C2212. On state and private lands, agencies and field
personnel of agencies involved in grizzly bear
management will communicate intent of "Guidelines"
as described above (C2211) as a cooperative
extension effort.

C222. Timber operations (including road construction,
reforestation, etc.)

C2115.

C2116.

-88-

C2221. Develop and apply systematic management guidelines
on federal lands to make timber operations
compatible with grizzly bear spacial and seasonal
habitat requirements. Management direction is
currently given in "Guidelines," pages 17, 32, 24
& AO.

C2222. On state and private lands, agencies and field
personnel of agencies involved in grizzly bear
management will communicate intent of "Guidelines"
as described above (C2221) as a cooperative
extension effort.

C223. Mining and energy operations

C2231. Develop and apply systematic management guidelines
on Federal lands to make water development and
mining and energy operations compatible with
grizzly bear spacial, and seasonal habitat
requirements. Management direction is currently
given in "Guidelines, " pages 17, 32, 38 & 48.

C2232. On state and private lands, agencies and field
personnel of agencies involved in grizzly bear
management will communicate intent of "Guidelines"
as described above (C2231) as a cooperative
extension effort.

C224. Recreation activities

C2241. Develop and apply systematic management guidelines
on federal lands to make recreation activities
compatible with grizzly bear spacial and seasonal
habitat requirements. Management direction is
currently given in "Guidelines", pages 14, 28, 36
& 46.

C2242. On state and private lands, agencies and field
personnel of agencies involved in grizzly bear
management will communicate intent of "Guidelines"
as described above (C2241) as a cooperative
extension effort.

C225 . Human development. Land management agencies, state
agencies, county commissioners, county zoning boards,
responsible for regulating homes, summer homes, cabins,
camps, farm operations, etc., that may have attendant
dog kennels, pig or goat farms, garbage dumps and
boneyards, should give consideration to the needs

-89-

of grizzly bears in any actions requiring their
approval when these activities invade the occupied
habitat of the grizzly. For private lands not subject
to the above restrictions , wildlife managers should
give consideration to purchase, lease or easement if
habitat components are necessary to survival of the
species.

C226. Monitor and determine the cumulative impacts of past
project actions. Determine the cumulative effects of
all, or any combination, of the actions described above
(C221-C225) that may adversely impact grizzly bears at
a multiple or amplified level. Past adverse impacts on
the bears and their habitat must be a major consider-
ation in the evaluation of each new action
(Jonkel 1979). New actions must be evaluated on a
regional basis to avoid the cumulative effects of
several well planned individual actions impacting bears
from too many directions simultaneously. History
records that at some point in time, probably associated
with the degree of stress, grizzly bears no longer use
certain portions of their former range. Therefore,
each new action has the potential of being "the last
straw," from the standpoint of the bear, and every
effort must be made to evaluate each new action with
respect to former and future actions.

C23. Coordinate, monitor and report on activities relating to
redressing population limiting factors and monitor
compliance with recovery plan.

Determine the habitat and space appropriate to the achievement of
the grizzly bear population goal.

C31. State or determine occupied space and habitat where

management considerations for grizzly bears are necessary.

C311. Identify or state occupied grizzly bear space

and habitat by landownership and administrative unit.

C3111. Occupied space and habitat were delineated by
workshop members participating in a grizzly bear
recovery planning workshop March 6, 1980, Libby,
Montana (See Fig 4 and Table 4) .

-90-

C3112. Occupied habitat boundaries will be corrected as
new data become available.

C312. Identify or state U.S. Forest Service, Bureau of Land
Management, state lands and National Park Service
management stratifications within occupied space and
habitat. See Table 4.

C32. Compare agency management stratifications by administrative
unit with occupied space and habitat delineations and
identify areas where additional management stratification or
management direction is necessary. See Table 4.

C33. Correct data in Table 4 as new information is made available.

C34. Recommend critical habitat.

C35. Identify travel corridors connecting islands of habitat or
grizzly bear ecosystems.

C4. Resolve differences between occupied space and habitat and agency
stratifications within occupied habitat (Table 4) and/or adjust
presently delineated stratifications.

ASSUMPTIONS

A majority of the land within the Yellowstone Grizzly Bear
Ecosystem have specific management direction through stratification
as per the "Guidelines." All of the federally controlled lands
in the CYGBE (or elsewhere) are under general management
direction as per requirements of the Endangered Species Act.
In addition, the Forest Service lands have general management
direction spelled out in the National Forest Management Act
(NFMA), Forest Service Manual (FSM) Chapter 2680, and
various Region One Manual supplements. However, federal
lands in the CYGBE currently do not have interim guidelines
relative to grizzly bear management of specific land areas.

The Forest Service intends to incorporate such direction for
grizzly bear habitat management in each Forest Plan (due in 1983)
as per direction in FNMA and FSM 2672.

Stratification, with attendant management direction, reflects the
differing intensities and importance of grizzly bear use.
Management direction for each stratified area must provide
adequate conservation measures to assure that the continued
existence of the grizzly bear is not jeopardized. In addition,
guidelines for stratification must recognize that reclassification
will be necessary if documented evidence supports that a
specific area is vital to the survival of the species or
conversely, shows it is of lesser importance.

-91-

The development of interim management direction and/or guidelines
specific to grizzly bear management prior to 1983 for USFS lands
and for all other lands is recommended to expedite recovery.

C41. Areas for resolution within the Kootenai National Forest.

C411. 514,754" acres of stratified lands within occupied
space and ^tyabitat that are in need of management
direction. -

C412. 319,141 acres of occupied space and habitat that are in
need of stratification and management direction.

C413. 53,105 acres of state and private lands within the
forest boundary that are in need of stratification and
management direction.

C42. Areas for resolution within the Lolo National Forest.

C421. 62,280" acres of stratified lands within occupied space
and habitat that are in need of management direction.

C422. 57,700 acres of occupied space and habitat that are in
need of stratification and management direction.

C423. 1,475 acres of state lands within the forest boundary
that are in need of stratification and management
direction.

C424. 12,684 acres of private lands within the forest boundary
that are in need of stratification and management
direction .

C43. Areas for resolution within the Panhandle National
Forest (adjacent to Cabinet Mountains)

C431. 69,848 "acres of stratified lands within occupied
space and habitat that are in need of management
direction.

C432. 148,896 acres of occupied space and habitat that are
in need of stratification and management direction.

C433. 4,960 acres of state lands within the forest boundary
that are in need of stratification and management
direction .

^Essential habitat 1977 (USFS)
- See Footnote NCDGBE pp. 80.

-92-

C434. 15,960 acres of private lands within the forest

boundary that are in need of stratification and
management direction.

C44. Areas for resolution within Bureau of Land Management lands
which include 2,000 acres of BLM lands that are in need of
stratification and management direction relative to grizzly
bear use.

C45 . Areas for resolution within private and state lands which
includes 17,700 acres of private lands and 2,100 acres of
state lands situated outside of National Forests and BLM
boundaries, but within occupied territory that need to be
stratified for relative grizzly bears use and attendant
management direction developed including identification of
parcels of state or private lands representing actual or
potential problems to the recovery of the grizzly bear
population.

Note: Stratification of habitat for relative use implies
that the management direction will relate to direct grizzly
bear mortality, indirect (habitat related) mortality, and
grizzly/human conflict potential. Private lands within and
outside Federal agency administrative boundaries are
frequently high risk areas for bears and often complicate
agency management direction. Landholders should be
encouraged by agency and county personnel to eliminate
conditions that may create human/grizzly conflicts.
Management direction described in the "Yellowstone
Guidelines" would be appropriate to follow in principle for
problem solution. Long-range solutions may include closure,
easements, lease, or purchase of problem areas if warranted
and other satisfactory solutions are unavailable.

C46. Review all areas following stratification and assignment of
management direction to resolve differences between
classifications made by land managers and recommendations
made by research and wildlife managers.

Monitor grizzly bear population and habitats.

C51. Monitor grizzly bear population prior to recovery.

C511. Develop and conduct an intensive monitoring system to
measure the selected population parameters by using an
appropriate experimental design with sufficient
sampling effort to permit valid comparisons with the
benchmark statistics.

-93-

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-94-

C512. Collate, analyze, and compare current research data with
data with benchmark statistics to determine recovery
progress and plan compliance. Coordinate population
analysis to assure a common understanding of techniques
used in ongoing studies. Circulate appropriate reports.

C513. See Y513.

C52. Monitor grizzly bear populations following recovery.

C521. Develop and conduct an extensive monitoring system to
index one or more of the selected population parameters
and to provide information on the trends in
geographical and ecological distribution. This should
be a systematic sampling method to allow valid
assessments of population trends by managers.

C522. Standardize the monitoring procedures and reports and
deposit all reports with the Grizzly Bear Recovery
Coordinator .

C53. Monitor grizzly bear habitat prior to recovery.

C531. Develop a grizzly bear habitat classification/research
and management system to determine the nature and
extent of habitat components in the grizzly bear
ecosystem. Use a mapping scale appropriate for valid
assessments of trends (changes in quality, loss or
gain) in habitat components. Standardize terminology
(see BGP Special Report No. 41).

C532. Classify and map habitat components giving non-
wilderness areas first priority.

C533. EstaDlish a quality index for the extent and condition
of the habitat components in the ecosystem.

C534. Establish a benchmark of present habitat values to
measure cumulative effects of all actions over time
that have impacted grizzly bear habitat.

C535 . Monitor changes in grizzly bear use of habitat compo-
nents under various types and degree of human use
(i.e. logging, mineral or energy exploration/
development recreation, etc.).

C536. Determine and evaluate the results of habitat changes
and modifications in order to assess the cumulative
effects of these changes for the entire grizzly bear
ecosystem.

-95-

C537. Identify conservation and enhancement procedures and
measures used successfully to improve habitat and
report annually.

C54. Monitor grizzly bear habitat following recovery.

C541. Inventory and map changes in the extent of habitat
components every 5 years.

C542. Continue evaluation of present habitat values to

measure cumulative effects of all actions over time
that have impacted grizzly bear habitat.

C543. Coordinate and review agency actions and plans; report
periodically on progress of recommended action and
programs necessary for plan compliance. Advise
appropriate agencies on actions necessary to avoid
relisting of species.

Manage grizzly bear population and habitats.

C6l. Develop and apply systematic management guidelines on

federal lands to maintain, enhance and expand habitats, to
make land use activities compatible with grizzly bear
spacial and habitat requirements, and to minimize the
potential for conflicts; and to resolve grizzly/human
conflicts .

C611. Develop and refine procedures for relocating grizzly
bears .

C6111. Refine present procedures, expedite handling,
and search for new areas to relocate bears. Re-
view interagency agreements (see Y6111).

C6112. Research and develop methods to rehabilitate
problem bears; develop an aversive conditioning
program that will cause the problem bears to avoid
repeating the behavioral pattern that led to the
human/bear confrontation (see Y6112 for addi-
tional comment) .

C6113. Develop and coordinate interagency agreements and
procedures to introduce grizzly bears into areas
of former habitat or to bolster populations
nearing extinction (see note following Y6112).

C612. Control or remove documented nuisance grizzly bears
after giving consideration to the recommended mortality
level (see Y612 and footnote).

C62. Develop and apply management guidelines on private and state
lands that maintain or enhance habitats; recommend land use

-96-

activities compatible with grizzly bear requirements for
space and habitat; minimize potential for, and resolve,
grizzly/human conflicts (see C611).

C63. Continue to manage populations and habitats on all lands
following recovery in the ecosystem. Refine control methods
and develop a coordinated system for control of population.
Sport hunting will be a consideration under a harvest quota
system.

C631. Establish baseline data on grizzly bears for at
least two years prior to the issuance of any
permit for major construction activities that
may create an unusual disturbance for the bears.

C632. Accelerate radio- tagging grizzly bears and

increase monitoring efforts in areas where special
permits or unusual activities may be impacting
grizzly bears.

Develop and initiate an appropriate information and education
program. Reducing man-induced mortality is a major factor in
effecting the recovery of the grizzly bear. Therefore, it is
crucial to the recovery effort that people understand reasons for
actions in order to have a favorable attitude toward the bear.
Private conservation organizations interested in the recovery of
grizzly bears could be of assistance if they would disseminate
appropriate information in their publications and news releases.

C71. Sample, quantify, and evaluate public attitudes toward
grizzly bears, grizzly habitat protection and maintenance,
land use restrictions, mitigating measures, relocation of
bears, hunting, nuisance bear control actions and habitat
acquisition or easement.

C711. Sample and evaluate the attitudes of people residing in
or adjacent to grizzly bear management areas.

C712. Sample and evaluate attitudes of people geographically
removed from grizzly bear management areas.

C72. Formulate ways to improve public attitudes

and acceptance of habitat maintenance and protection,
research and management.

C73. Agencies having the authority and responsibility for control
control actions will institute and carry out information and
education programs to inform citizens having problems with
grizzly bears of the appropriate procedures and contacts for
assistance .

-97-

C74. Develop means of extending public attitudes to action plans
and/or funding.

C8. Implementation of the Plan by jobs, priority and cost. To facili-
tate implementation the Fish and Wildlife Service will appoint a
Grizzly Bear Recovery Coordinator to collate all relevant infor-
mation on grizzly bears, coordinate and stimulate compliance and
action to implement recovery plan. Submit progress reports and
conduct workshops and meetings as necessary (See Y81).

C9 . Revise appropriate federal and state regulations to reflect
current situations and facilitate implementation of action
necessary for species recovery including the initiation of
international cooperation where appropriate.

-98-

-100-

RECOVERY PLAN

SELKIRK MOUNTAINS, SELWAY - B I TTERROOT WILDERNESS AND
NORTH CASCADE MOUNTAINS GRIZZLY BEAR ECOSYSTEMS

Subgoal: Secure, maintain or re-establish grizzly bear
populations in the Selkirk Mountains (S),
Selway-Bitterroot Wilderness (SB) , and North
Cascade Mountains (NC) areas at viable
population levels. (Figs 5, 6 and 7.)

1 (S,NC,SB) Determine the present status of the grizzly bear
population in each of the three ecosystems.

Data on these three grizzly bear ecosystems are
lacking. Only a few observations or other evidence
noting the existence of grizzly bears are being
recorded. Whether this is a result of a lack of effort
or a scarcity of bears, or both, is uncertain.
Presently there does not appear to be much enthusiasm
for increasing the numbers of grizzly bears in these
areas. There has been no concerted effort to determine
the status of each population and a very limited amount
of data are available on the extent and quality of the
habitat. The high cost of collecting data in these
ecosystems may detract from the effort necessary to
recover grizzly bears in the YGBE, NCDGBE and CYGBE.

2 (S,NC,SB) Determine the space and habitat necessary to support a

viable population of grizzly bears in each of the three
ecosystems .

3 (S,NC,SB) Determine the appropriate actions necessary or develop

a more refined recovery plan for each grizzly bear eco-
system based on the data developed in Steps 1 and 2
above .

Note: There is little that can be done at this time except

exercise the normal protective actions in accordance
with current federal and state regulations. Until
items 1 and 2 are executed, and the data made
available, informed management decisions will be
difficult.

Several wildlife biologists familiar with the Selkirk
Mountains area are of the opinion that there is
sufficient evidence on the grizzly bear population, at
least in that portion of the ecosystem in Idaho, to

-102-

formulate a recovery plan similar to that of the CYGBE .
A greater commitment by state wildlife agencies and
federal and state land managers to determine the
present status of the population and the extent and
quality of the occupied grizzly bear range is needed
before a viable population goal can be estimated.

Biologists participating in the workshops and
subsequently have not been able to unanimously agree on
how many populations are necessary for recovery of the
species in the conterminous 48 states. For practical
purposes and with the welfare of the species in mind,
three areas were chosen to concentrate on a recovery
effort--YGBE, NCDGBE and CYGBE. Other populations are
expected to receive maximum protection under state and
federal laws. A continued effort should be made by
state and federal agencies to gather data on grizzly
bears as funds permit, but not in a manner that will
detract from the primary goal of the recovery plan.

-103-

-104-

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PART III

JOB IMPLEMENTATION AND BUDGET

Assignments of estimated costs and jobs are summarized on the following
pages.* Specific information for jobs listed can be found in Part II.
Estimates are based on costs of projects currently being conducted in
the YGBE (IAGBST) , jobs ongoing in the NCDGBE (BGP) , Forest Service
projects of similar design, Bureau of Land Management estimates, National
Park Service estimates and costs of current programs by state wildlife
agencies. States have the alternative of funding through their own
resources, Pittman-Robertson cost sharing, Section 6 of ESA, or other
federal cost sharing programs. Federal agencies are expected to budget
and allocate funds to accomplish assignments.

Priorities of jobs were assigned as follows:

Priority one (1) - Those actions absolutely necessary to prevent

extinction of the species.

Priority two (2) - Those actions necessary to maintain the species'

current population status.

Priority three (3) - All other actions necessary to provide for

full recovery of the species.

When several lead agencies are listed, it is expected that cooperation
and coordination will resolve any problems.

*GOALS AND OBJECTIVES WILL BE ATTAINED AND FUNDS EXPENDED
CONTINGENT UPON APPROPRIATIONS, PRIORITIES, AND OTHER
BUDGETARY CONSTRAINTS.

-117-

ABBREVIATIONS

BGP Border Grizzly Project

BIA Bureau of Indian Affairs

BLM Bureau of Land Management

CEA County Extension Agents

CRCB County Rodent Control Board

DCA Department of Community Affairs

EPA Environmental Protection Agency

FS U.S. Forest Service

FWS U.S. Fish and Wildlife Service

IAGBST Interagency Grizzly Bear Study Team

IDL Idaho Department of Lands

IF&G Idaho Fish and Game Department

ITD Idaho Transportation Department

MDA Montana Department of Agriculture

MDH Montana Department of Highways

MDL Montana Department of Livestock

MDNRC Montana Department of Natural Resources and

Conservation

MDSL Montana Department of State Lands

MFW&P Montana Department of Fish, Wildlife & Parks

MSFD Montana State Forestry Division

NPS National Park Service

USGS U.S. Geological Survey

WDG Wyoming Department of Game

WG&F Wyoming Game and Fish Department

WSC Wyoming State Commission

WSF Wyoming State Forestry

WSL Wyoming State Lands

WWD Washington Wildlife Division

-118-

GENERAL CATEGORIES FOR IMPLEMENTATION SCHEDULES

Information Gathering - I or R (research)

1.

Population status

2.

Habitat status

3.

Habitat requirements

4.

Management techniques

5.

Taxonomic studies

6.

Demographic studies

7.

Propagation

8.

Migration

9.

Predation

10.

Competition

11.

Disease

12.

Environmental contaminant

13.

Re introduction

14.

Other information

Management - M

1. Propagation

2. Reintroduction

3. Habitat maintenance and manipulation

4. Predator and competitor control

5. Depredation control

6. Disease control

7. Other management

Acquisition - A

1. Lease

2. Easement

3. Management agreement

4. Exchange

5. Withdrawal

6. Fee title

7. Other

Other - 0

1. Information and education

2. Law enforcement

3. Regulations

4. Administration

-119-

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-165-

APPENDIX A

COMPUTER MODELING

Chris Servheen, consulting with Bunnell and Tait, used two popu-
lation estimates extrapolated from densities of three study areas and
Glacier National Park, plus the age structure and survivorship data
from a kill sample (Greer, 1979), to apply a computer model to a bear
population in the NCDGBE . They applied different levels of human-
induced mortality and varying levels of natural mortality and repro-
ductive rates, to estimate the long-term effects of those parameters
on this population. The computer model was developed by Fred Bunnell
and David Tait at the University of British Columbia.

The model employed two initial population estimates, 440 bears
(low) and 680 bears (high) (see footnotes NCDGBE); two survivorship
rates of .8 .9 .8 18 x .9 (cubs to age 22 years) (highest), and .8 .9
.7 .7 .7 .7 .7 .7 .14 x .94 (cubs to age 22) (lowest); and two repro-
ductive rates 2.3 cubs/3.0 cycle (high) and 1.78 cubs/3.4 cycle
(low) :

1) Both populations increased rapidly in the simulation when
the high survivorship and high reproductive rates were used with a
man-induced mortality of 12 bears.

2) Both populations declined when low survivorship and the low
reproductive rate were used with a man-induced mortality of 12 bears.
In fact, both populations declined in this simulation, when the man-
induced mortality was reduced to 0.

3) Increasing the man induced mortality to 24 bears and using
the high survivorship and high reproductive rate the higher initial
population increased slowly.

4) Again, using the higher population estimate, highest survi-
vorship with the lowest reproductive rate, the population remained
stable when man-induced mortality was at 0.

Note: Actual survivorship data on this population is non-exis-
tent, data on litter size, reproductive cycles and densities are based
on very limited data. The simulation model is a tool that is totally
data dependent and must be viewed in this light. The test did
indicate research needs and will give others interested in simulation
models for grizzly bears a starting place.

The level of specific sex and age mortalities by man or the
natural mortality and recruitment will probably never be precisely
determined (Greer pers. com. 1980). McCullough (1979), indicates that
high proportions of adult males may suppress survival of subadult age
classes .

The sophisticated simulations for bear populations with few
mortalities, limited current data, and historical assumptions appear
to indicate exaggerated trends that do not appear to coincide with
existing field observations.

-166-

Similarly, estimates for the rate of population growth or decline
(implied from life tables and fecundity) in small populations with
small changes each year, are inadequate for estimating rate of
population change, or status (Tait and Bunnell, 1980).

-167-

APPENDIX B

Comments by agency on Agency Review Draft
of the Grizzly Bear Recovery Plan.

-168-

UNITKD VTATYI DSPANTMKNT Of AamCULTUW.

roAirr •envies

P.O. lox 2*17
WMhlngton, D.C. 20013

2670

JAN 16 1981

Mr. Lynn A. Greenwalt

3. Table D Indicates that leas then one-third of the tree
needed to support e minimum viable population (HVP) of 70 heart,
It available on public lands In the United States portion of the
Selkirk Mountains. Irrespective of ownership pattern, a popu-
lation of bears does still exist In the Selklrks. Given the
ownership patterns, there appear to be three options for managing
the United States portion of the Selklrks:

Mr. Lynn A. Graenwalt
Director, Fish and Wildlife Service
U.S. Department of the Interior
Washington. D.C. 202^*0

Dear Mr. Graenwalt:

This letter contains Forest Service comments on the agency review
draft of the Grizzly Bear Recovery Plan. After this plan Is
approved, the Forest Service will prepare an action program to
Implement appropriate parts of the Recovery Plan.

The Recovery Plan presented Information In Tables 2, 3. and *), maps,
end written text, which depicted current occupied grizzly bear
habitat, current grizzly bear populations, and recovery goals.
We have extrapolated from this Information to estimate population
numbers by ownership or management units. We feel that these
preliminary estimates will be useful In establishing Forest Service
objectives during planning processes. We would like to work with
you to refine these population objectives. Our specific comments
on the dreft plen ere as follows:

1. The disparity In our extrapolated beer numbers and densities
between the Yellowstone Grizzly Beer Ecosystem (YG6E) and the
Northern Continental Divide Grizzly Bear Ecosystem (NCDGBE) Is
confusing. The two ecosystems ere almost Identical In are*, yet
meeting the population paremeters established for recovery results
In 306 beers (1/26 sq. ml.) In the YGBE end 650 bears {1/13 sq. ml.)
In the NCDGBE. The metter Is further confused by the Indication
that 70 bears would be considered a recovered population In the
Cablnat-Yaak Grizzly Bear Ecosystem (CYGBE) (page 108, Recovery Plan).

While not questioning the recovery objectives set forth In the Plan,
we would like to see a better biological explanation of why population
parameters resulting In such widely varying population numbers
within eech ecosystem were selected as the recovery goats.

2. Each of the ecosystems has a variety of landownershlps
(Tables A-D) . The NCDGBE Is particularly fractured with II owner -
ships. How were the carrying capacities of the private, State, and
Indian Reservation lands considered In the determlnetlon of
population perameters needed for recovery?

a. Disregard the grizzly population.

b. Maintain United States habitat In a condition to
support e density of one grizzly per 26 square miles, in hopes
thet management on Canadian and private lands would maintain a
similar capeclty, and a MVP would be maintained.

c. Intensively study the current grizzly population and
map habitat, with the goel of manipulating habitat to Increase
bear densities to the greetest extent possible.

It appears to us that the Selkirk population is peripheral In the
United Stetes and we do not control adequate habitat to achieve
recovery. Therefore, we would recommend a management scheme per
I tem b ebove.

*-. We ere concerned about the leek of public Involvement or use
of the NEPA process In development of this plan. The U.S. Fish and
Wildlife Service (FVS) contends thet a recovery plan simply prescribes
whet must be done to achieve recovery and recommends that various
agencies Implement the plan, and that It Is not a decisionmaking
document.

We believe the Recovery Plen Is a decisionmaking document In that
It sets a goal In terms of population parameters resulting In
numbers of bears end It delineates occupied hsbltat, or the area
necessary to achieve the goals.

The proposal to Increase current numbers of grizzly bears Is a
highly controversial matter and can have significant effects on the
human environment. This Is evidenced by the outcome of formal
consultations, relative to the grizzly bear, on timber sales on the
Gallatin National Forest, hard-rock mining on the Kootenai
National Forest, road construction on the Flathead National Forest,
and oil and ges leasing on the Lewis and Clark National Forest.
In each of these consultations, a jeopardy opinion was Issued,
resulting In significant changes In the original management plans
for other resources. Comments (letters) we have received from the
general public and newspaper articles Indicate that grizzly beer
management Is a controversial subject and not everyone wants more
bears.

Mr. Lynn A. Greenwalt 3

The 1976 FWS proposed rulemaking to delineate 13 million ecres es critical
habitat for the grizzly beer was extremely controverstel . The recovery
plan proposes e recognition of some 12.3 million acres as occupied grizzly
habitat. We believe thet such designation will be highly controversial,
especially If It is not explained and the public Is not allowed to comment.
Some factions of the public might perceive that we have delineated de-facto
critical habltet without going through the proper procedures as outlined
In Federal Register Vol. U, August 15, 1979.

A careful review of the following portions of CEQ, regulations seems In
order: 1502.3, 1508.3, 1508.8, 1508. 11, 1508. I*, 1508.17, 1508.23
end 1508.27.

Regerdless of whether the FWS feels that the Recovery Plan Is In compliance
with NEPA or not, the Forest Service, through the land menegement planning
process, will echleve necessery public Input and comply with NEPA es
programs and actions Identified In the Recovery Plan are implemented.

S- Occupied habitat, as delineated In the Recovery Plan, was developed
at various meetings. The Forest Service objected to the lack of mapping
criteria et several of these meetings, to no avail. Although several
Forests dlsegree with the Recovery Plen's delineation, the Forest Service
will officially accept these del i. tee t Ions We wish to go on record,
however, es being strongly opposed to the lack of mapping criteria.

6. Page I. It may not be possible to "remove11 the limiting factors,
as stated In objective 3- Perhaps "regulate" the factors Is a more
realistic objective.

7. Page k, paragraph 2 of the plan s: '-.es that social, political,
and economic (nonb lolog i ca I ) factors were it 1 msldered In plan
development, and such nonbtologlcal aspect, wl I have to be dealt with
by administrators. We fear that not addressln these nonblologlcal
aspects may be a serious Impediment to Implementing the Recovery Plan.
As stated above, this Is a highly controversial subject. If the plan
does not consider and Incorporate social, political, and economic factors,
It will likely receive resistance from the public.

8. Page 9. Since the stepdvwn portion of the Recovery Plan (Y61111)
cells for reseerch on averslva conditioning of bears, It might be useful
In this section on Behavior to summarize existing Information on this
subject.

9- Pege 12. The most current citation on the grizzly studies In
Teton WI lderness , Wyoming, should reed:

Hoek, J.H., T.W. Clark, and J.L. Weaver. 1980. Grizzly beer
ecology In Brldger-Teton Netlonel Forest, Wyoming. In
C. Meslow, ed. Fifth Intern. Conf. on Beer Research
end Menagement. In press.

10. Page 19, line 19- Should "relative" read "relevant?"

-169-

Mr. Lynn A. Greenwalt *t

11. Page 26. In the section on Netellty, there Is no Information
presented on litter sizes. It Is particularly Important to provide
such data because this Is one of the monitored population parameters.

Also, In the section on Natality, It may be useful to cite H. Picton's
paper relating decreased precipitation In the Yellowstone area during
the pest >0 yeers to decreesed litter sizes for grizzly bears during
this seme period.

12. Page 30. The section on Mortality Jumps right Into the specific
case of mortality In the dens. A more logical sequence might be to
proceed from e general discussion of mortality causes and rates to more
specific cases.

13. Page 33- The questions raised here, regarding aggressive behavior
of bears and conditioning possibilities, are a good addition to the Plan.
Would It be no re appropriate to place them in the section on Behavior?
Also, In tine 7, "aggressive" is misspelled.

ft. Pages 39 and ItO. The discussion on timber harvesting should be
expanded to explain the specific consequences of timber harvesting,
positive and negative. Also, the consequences of the associated factors
Involved with timber harvesting, such es road construction, should be
discussed separately.

15. Page *tl. Why no reference to Knight's work on denning which Is
the most up to date?

16. Pege 50. Our records show very few reports of grizzly bear
sightings south of Bitch Creek. None are recorded as far south as
Leigh Creek. Therefore, we recommend that occupied habitat for the
Terghae National Forest be shown only as far south as Bitch Creek
(North Fork of the Teton River).

Also, for table 2 (page 66) the acreage summary should be:

MS I
MS2

Occupied Habl tat

iso.oooi7.
159,68^

A correction on this master map was mede In I98O by the Shoshone National
Forest and has been provided to Don Brown, Recovery Plan Coordinator.
The acreage figures In Table 2, page 66, reflect this revision but the
1979 map used In the plan does not show the correction. We suggest the
updated map be used to avoid confusion end to accurately represent occupied
habitat on the Shoshone National Forest. A copy of the correct map
(Enclosure 1) Is enclosed for reference.

Mt. Two Top end Wlnegar Hole

Moose Creek Plateau (Reas Pass to Robinson Creek)

Mr. Lynn A. Greenwelt '

17. Fe»e 51, ¥111. We recognize the need to ettebllth • reference
point for • r.cov.ry terget. However, wo recommend the porametert thet
r.pr.t.nt tho population of the period 1959 to 1569 b. pratented In the
Plen with qualification. Tho parameter! reflect e populetlon thot wot
heavily dependent on on irtlflelol food toureo (dumpi) . Thoroforo, It
ll pottlblo thot with tho more natural eondltlont of todoy, • populotlon
demonttrttlng the terget parameter! may not bo obtolnoblo.

Wo receeeeend thlt point bo empheilzed In tho Plan and thot an action I torn
bo written that doacrlboa tho nood to continually avaluata tho peremetert
mod to describe a racovared populotlon. Tho Plan thould document thot
tho target parameter! nay change as more Information ll gathered. It
may be moit appropriate to discuss thli matter on page 2.

16. Page 5*. Mil. The Mating of three separate flgurei (II, 6,
end 5) •« the maximum limit to men-cau»ed mortalltlee la confuting and
unneeettary. Wo recommend the number offered by the recovery planning
group (6) be uted.

19. Page 5», Will. We tuggott the law enforcement arm of tho
Forett Service be specifically Identified et a cooperator.

20. Page 60, Y222I. The tentenee "Supplemental guide! Inea for
M.S-1 end KS-2 landt have been prepered end ere available (Mealey
port. com. 1980)" thould be deleted. Thlt ttatement doet not belong
In the Recovery Plen et the tupplomentel guldellnet have not been
reviewed or agreed upon by the partial to the epproved "Guideline!."
If and when thete lupplementel guideline! would be uted, they could
be Incorporeted Into the revlied or amended "Guideline!."

21. Pege 41, Y225I. The lait lentence refert to "tpeclet menegort."
Whet are "tpeclet managers?" Thlt term thould be clarified to attlgn
retponilblllty to the proper egeney.

22. The lection on "Anumptloni," pege 63, leevei the eonnotetlon
thet legion I Is doing nothing reletlve to management of grizzly
boor habitat outside of detlgneted essential hebltet. We would like
to tee e ttatement edded which reeognliet the ongoing Forett plennlng
proceit. For exemple, "Plennlng, et per the Motional Forest Management
Act, It now underwey on the Gallatin and Cutter Netlonel Forettt.

Thlt plennlng effort It eddreiilng menegement of grizzly been end
their hebltet."

2J. Pege 6*, YU22. Pelt record! Indlcete beer! heve occupied thli
eree, but hebltet quellty doei not Juttlfy MSI. No recent lighting!
heve been made In thli eree.

2k. Pege 65, Item Wei. The Foreit Service hot eccepted the
acreegot as presented In the Recovery Plen.

Mr. Lynn A. Greenwelt 6

25. The mopi Indlcetlng occupied hebltet In the recovery plen ere
difficult to reed because of the well scale. However, It eppoers there
la on Inconsistency between the acres of occupied hebltet on the
Cutter NF Indicated In Teble 2 (pege 66) end the eree delineated on the
mop. The ecrei In the Teble ere correct, but the mop seemi to be In
error. We heve enclosed e Foreit mop (Enclosure 2) with the correct
eree scribed.

In addition, the 156,500 ecrei of occupied hebltet on the Cutter NF
thould be broken out et follows: MSI - 32,000 acres; MS 2 - 12*i ,500
acres. Thete detlgnatlont ere contldered Interim to completion of the
Foreit Plen.

26. Wo tuggott the Tablet depleting occupied hebltet In the plan
Indlcete aquere mllet et well et ecret, since the text refert to
densities of bears In tquare mile terms. It would elto be helpful
If the ecret end tquere mile figure! were toteled.

27. Pege 71, Y612. Alio, the following should be Inserted et the
end of Y6I2: ". . ., per the crltlarla end itepi provided on pp. 59-62
of the Guideline!."

28. Item V65 (page 72) may be unworkeble, and the need for such e
requirement Is not cleer. It may be unworkable In thet other lews
end reguletlom may preclude a 2-year deley between permit request!
end the decision es to whether to ellow the activity (e.g. IB92 mining
lew; 1922 oil end gel leasing lew), in addition, the peat work done by
the Crelgheadi, current work being done by the Interegency Yellowstone
Grizzly Seer Teem, end habitat mapping being done by the Forests, hes
brought together e considerable amount of information on grizzlies

end their hebltet. The wording In Y65 seems to Imply thet tlte
specific Information Is needed. These tome thought! epply to I terns N6M
(pege 103) end C63 (pege 12a.) - In some cases beiellnn date may need to
be collected but, In others, sufficient Information may be available.

29. Pege 7*>, Item C. The referenced figure thould be 3 rather
thin I.

30. The last sentence In the flrtt peregreph on pege 92 It Incorrect.
The Lolo National Foreit addressed grizzly bear menegement on 162,181
ecrei In their Oreft Foreit Plen (April I960). The final plan will
consider bear management on all ecrei Identified In the Recovery Plan.
All other Foreit Plent will do llkewlie.

31. The figure given for "Acres Stratified by Grizzly Use" for the
Kootenai NF In Teble «, pege 121, It Incorrect. The correct figure

ll 5I4.75*.

32. Pege 137, V22M. Under Estimated Cost column, the ttetement
thould reed the tome et In Y22J1 two peregrepht ebove. The statement
et written doet not epply to Federel lendt.

Mr. Lynn A. Greenwelt 7

33. Pege 138, Y22SI. Thlt ectlon does not egree with the text es
written on pege 61. The Action should be to epply the "Guideline!" In
occupied ranges rather then "restrict" or "withheld" permit!. Certeln
permit! end/or typei of development may not Impact the grizzly beer.
The option to permit, restrict, or deny thould be left open pending
an oiteitment of the proposal.

3*. Page 139, Yell. YI21, Yajl ; Fege 1*0, IfWJj Pege HI, M5I.
These plen Item assign the Forett Service et hevlng leed responsi-
bilities for making recommendations on private lend reletlve to
conservation of the grizzly beer. The Forett Service he! limited
authority for tuch a role but will be heppy to cooperate. Thli may
be more tpproprletely enlgned to the Stete wildlife egeney end the
U.S. Fish end Wildlife Service.

35. Pege Ut, Y5M, Y52I, Y53I. Thlt Action Item thould be expended
In order to clarify how and who will do tha ectual monitoring of the
parameters. Monitoring the itetut of the grizzly beer li the basic
retponilblllty of the Flih end Wildlife Service and the State wildlife
agencies. The Forest Service would heve betlc responsibility for
monitoring habitats on Nat I one I Foreit System lends end tome responsi-
bilities under the NFMA reguletlom for monitoring the beer In
cooperation with Stete egenclei end the FWS.

36. Pages U2 and 1*3, Y532, Y5321 , Y5322, 1*632 J, Y532«. Thete
actions and the supporting text on pege 69 ere vague end ere not cleer
et to whet should be done. Y5323 cells for estebl Ithment of benchmarks
of pretent hebltet veluet to measure the cumulative effect! of actions.
Thlt ll not consistent with other sections which tpeek to hebltet
component!. We suggest thet benchmark! be eitebllihed for hebltet
components rether than values.

37. Page 1*5, Y65 end Y66. The statement In the Estimated Coit
column, ". . . thould Include cost in permit feet," thould be deleted.
Thlt It not e legitimate cost to be pelted on to e permit applicant.
It It an administrative cost incurred the tame et eny environmental
anelytlt report on eny proposed permit or project. Furthermore, the
Foreit Service hes no batlt for passing tuch a fee on to the applicant.

36. We heve e concern ebout the Interegency Grizzly Beer Study
Teats end dutlei Inferred upon them by the Recovery Plan. The Study
Team con complete meny Jobs end collect much of the Information
called for In the Recovery Plen. However, the Study Teem Is e
representative of member agenclet end mutt terve the egenclei*
needt. The Study Teem mutt not unlleterelly be enlgned or under-
tone responsibilities without agreement end direction being provided
by the Study Teem Steering Committee end I tt member egenclea.

Mr. Lynn A. Greenwelt

At thlt time, we do not believe the Dreft Recovery Plan should designate
eny dutlei for the Study Team. Cither the Recovery Plen must delete ell
reference! to the Study Team In Section III and the Job implementation
and budget lection or the Steering Committee end member egenclei mutt
egree to the actions the Study Team will perform before the Plen Is
finalized end epproved. The first option would expedite approval of
the Recovery Plan.

We believe It would be best If the Recovery Plen did not refer to the
Study Teen, other than to recognize their technical cepebt I Itles.

We certainly eppreclate the opportunity to review thli dreft of the
Grizzly leer Recovery Plan. Nr. Oon Brown end othert who contributed
to the plan heve done e commendable Job. The Foreit Service will assign
top priority to thoie ectloni needed to achieve the recovery of this
meant f I cent animal .

Sincerely,

,/R. MAX PETERSON
Chief

Enclosure

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ted States Department of the Interior

N1621(496)

NATIONAL HARK SERVICE
WASHINGTON. D C 2U24U

m I 3 1381

To: Director, Fish anil Wildlife Service

Acting Deputy

Through; Assistant Secretary, Fish and Wildlife and Parks

FrouOETJTYiUi. rector. National Park Service

Subject: Comments on the Grizzly Bear Recovery Plan Draft

General Comments: This second version of the Grizzly Bear Recovery Plan
seems to be a well organised far reaching approach towards balancing the
interrelated problems of bear management, human impacts, habitat require-
ments, and societal needs. For example, the reduction of human caused
mortality seems the most readily solvable problem leading to population
recovery, and the mechanism of using interagency enforcement teams to
police tho illegal take of grizzlies is certainly appropriate. On the
other hand, most of the difficulties we encountered in the plan are derived
from the lack of reliable data pertaining to grizzly bear population dynamics.
Aa an example, the data used to describe "recovered" populations arc based
variously on estimates (with large variances) which by their nature are
probabilistic, are generated from models and not real populations, or are
based on data obtained by questionable methods. Despite such apparent
lieitations the available data are all that exist and hence, they must be
used in the decision making process. Consequently, the plan should stress
two points: a) more indepth data should be obtained from the populations
hero considered, and b) present decisions concerning grizzly bear mnnagc-
mont should b* regarded as subject to modification as our knowledge increases,
finally, the literature review is generally thorough and documents the
issues adequately. The fow instance.-: where facts are mentioned without
Sources, and the occasional typographical orror can be easily corrected in
the final version.

Specific Suggestions:

** Tage 22: Table 1 is an interesting comparison amoni; various populations.
It should be clearly noted in the caption that the density data difference
between areas may actually result from differences in study methods, season-
ality, length and depth of study, etc.

** Page 23: The first paragraph is simply meaningless, beginning with the
introductory sentence. What is meant by "space is a species communal home
range"? We suspect Professor Sagan would disagree vehemently. What evidence
exists for grizzly bears exhibiting "communal" social behaviors of any kind?

•* Page 33: Please offer citations for statement about retraining theories
and practices. How would the recovery team plan to develop such a grizzly
bear retraining program? Could similar techniques be used for block bears?

Paga 34: The main paragraph (added since tho first draft) implies hunting
is naaded for grizzly bear population regulation. This seems ill advised,
givtn tha lack of any appropriate mortality data to support the notion. The
continued implication that "relatively few problems" are encountered in non-
park is a functioning of hunting (whether illegal or legal) is inaccurate
given Servhean's (1979) statement that the fewer problems in non-park may be
more likely a function of lower bear/man ratios in such areas.

•* Page SI: Ylll - Reproductive rate should be 0.656 (not 0.6S0) (Craighead,
at al 1971). Most of the data presented here are derived from models predicting
DECLINING bear numbers. What is rationale for using these data to define a
haalthy recovered population? Is it wise to allow 17-19% man caused mortality?
Knight (1980) suggests no more than 5s man caused mortality should be permitted.
Furthermore, such percentages could change as the population densities are
known to change.

** Page 52: Y121 - Average known man caused mortality was reported by Knight,
at al (197S) at 11.000 should be regarded as conservative; "...until the popu-
lation status and trends are determined, we cannot afford this high mortality
rata If the present population size is to be maintained." They state the num-
ber of unreported (illegal?) grizzly deaths may be substantial.

•* Page S3: Yl 3133 - Please Include appropriate paragraphs discussing "grizzly
rehabilitation training" in narrative portion of the plan.

** Page 59: Y212 - "Nuisance bear" requires careful, precise definition. At
present It means anv bear someone doesn't happen to want.

•* Page 79: N121 - There appears to be a substantial discrepancy in reproduc-
tive rates shown in this table. Is there a typographical error?

(Citations here refer to bibliography of the draft plan)

AixMf ss omi ii

United States Department of the Interior

In lieply Refer To:
FWS/OtS

FISH AND WILDLIFE SERVICE
WASHINGTON. DC 20240

FtH U 3 1881

"•****rTlaie» .Regional Director, Region 6 (ARD/FA)
From: Director

Subject: Comments on the Grizzly Rear Recovery Plan, Agency Review Draft.

The following are comments on the Agency Review Draft of the Grizzly Bear
Recovery Plan, We have combined comments from 0ES and the Division of
Wildlife Ecology Research (Denver Wildlife Research Center and the Assistant
Leader, Montana Cooperative Wildlife Research Unit).

1. Page 1, Goal and Objectives. Recovery should be defined, I.e., "To
remove the grizzly bear from threatened status In the 48 conterminous
United States" as stated on page 46, Part II. Objective (1),
'...species recovery" should be changed to "viable self-sustaining
populations." Population goals do not necessarily totally represent
species 'recovery1' since the listing Involved consideration of factors
and threats beyond population numbers. This 1s only one, albeit
Important, aspect of recovery.

2. Page 2, paragraph 2. line 2. Who "generally concluded" the viability
of the Vellowstone population; the bear researchers, recovery plan
preparers, etc.? Page 2, paragraph 3, line 5. Change "recovered
population in that ecosystem* to viable self-sustaining populations
in that ecosystem."

3. Page 3, paragraph 1, line 5. "determining" Is misspelled. Page 3,
paragraph 3, Una 1. "Mark L. Shaffer (1978)" should be "Stephen C.
Shaffer."

4. Pages 3-4. The discussion of the Cabtnet-Yaak Grizzly Bear Ecosystem
(CYGBE) population goals is unclear and contradictory. Was the
computer model used to determine the population parameter values and
population goal for the CYG8E (Page 3, paragraph 3)? In the last
paragraph, page 3 It is stated that simulation analysis should not be
used to determine final or total numbers of bears in these ecosystems
(Yellowstone and Northern Continental Divide); yet, Item C1U,

page 108, In the step-down outline bases recovery on these parameters.
What 1s the Justification for using them on the Cabinet-Yaak Ecosystem?
Why was the decision made to use the model when remnant populations 1n
Europe contradict "this premise?" These decisions may be valid but
the Justification Is not obvious. Does not the model use the same

assumptions which raised objections on page 2 and 4 when applied to
the Yellowstone situation? The statement that this is a "dynamic
plan" Is not reinforced due to the lack of mechanisms to periodically
reevaluate the population parameters and the assertions that the
species will be "Judged recovered" based on these parameters. On
page 4, paragraph 2, non-b1ol ogical aspects should not be avoided and
in fact were not avoided. For example, on page 49 it is indicated
that cooperation and coordination between individuals and among
agencies 1s the most Important factor 1n saving the grizzly. Also,
1n the recovery plan outlines for each population there are references
to non-biological aspects such as monitoring for compliance with the
recovery plan and sampling and evaluating public attitudes. This
paragraph is misleading.

5. The section on "Perspective" Part I (starting on page 1) should be
rewritten to state, rather than defend the source of the data. This
section 1s confusing and at times seems contradictory, as outlined in
4 above.

6. The systematic discussion on pages 5-6 is indefinite. The recovery
plan should call for work to clarify the taxonomy of the grizzly and
brown bears, which 1s out of date. The recovery plan should recommend
such work If funding requests are to receive a high priority.

7. Page 9, add the following statement: Encounters between humans and
bears 1n Glacier National Park would Indicate that these concepts
have not been understood.

8. Page 11. lines 5 and 6. What is meant by "this peripheral range."
What areas or populations were Included In this?

9. Page 14. Why are the grizzlies in Colorado not included in the
discussion? They are also protected under the Act and the plan should
at least address the need to ascertain the grizzly's status 1n Colorado.
Page 14, paragraph 2, Hne 6. BMdger-Teton , not Rrldger, Teton.

10. Page 15, paragraph 2. Are the " . . . notorious plains grizzlies..."
documented to be extant and different taxonomically or as a popula-
tion, from grizzly bears in Glacier Nattone' Park or those west of the
divide? If this 1» possibly the case it sIk ild be included as an item
to be studied In the taxonomic studies of the species.

11. Pages 15, 16 and 17. Grizzlies in Canada Interchange with bears in the
Cabinet-Yaak (C), North Cascade (NC), Northern Continental Divide (N)
and possibly the Selway-Bitterroot (SB) Ecosystem populations. This
interchange has been identified as important. It would, therefore
seam Important to include this in the step-down outline, such as,
establishing International cooperation and/or agreements with Canada

on research and management of grizzlies.

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-4-

12. Page 17, last paragraph, 11ne 6. Does thl » Include Interchange with
the north Cascades?

13. Pages 17, 19 and 20, "Corridors." Maintaining corridors has bm
1d**t1f1*d as an important aspect for "1nter-1solate dispersal between
populations." This was also one of the factors for the basis of
listing the grizzly under Section 4(a)(l)(5) of the Act. This needs
to be considered In the Individual populations step-down outlines as
an objective, as outlined In the Abbreviated Step-down Outline,

Itaa 35. Is there a need to establish translocations to the Yellow-
stone ecosystem to Maintain gene flow or e n corridors be established?
How will 'gene flow" be accomplished with the Yellowstone population?

14. Page 29, paragraph 2, last line. The rtateaent, "the need to provide
aaxlaua protection for females Is essential to recovery" Is not
specifically addressed In the step-down outlines. How will this be
Implemented?

15. Page 32, (4) and (S). What 1s "erosion of habitat' and "eroding
habitat?" Is this referring to "change" or "loss" of habitat? The
meaning 1s unclear. Cannot log-'ng be considered beneficial at times
If cutting blocks are properly dt Igned and site preparation 1s
properly done based on current research results? This potential Is
reinforced later In the plan on page 37 (last paragraph) and page 39
(3rd paragraph).

16. Page 40, paragraph 1, line 2. Is the "correlation" a statistical
correlation? If not, terminology should be changed.

17. Page 46, paragraph 1. "North" and "true" are misspelled. What Is the
"human force spreading across the land?" This needs to be restated.

18. Page 47, paragraph 4. Change 'Recovery levels are defined..." to
"Viable self-sustaining populations are defined..." Last paragraph,
line 1. Add "necessary" between "equivalents" and "for."

19. Page 48, Objective. Change "recovery status" to "recovered status."

20. Page 49, Abbreviated Step-down Outline, Item 35. 'Identify travel
corridors to connect habitat Island* or grizzly bear ecosystems." Add
this (tea to the Individual population outlines pages 63, 91, 117 and
the Implementation Schedules (IS).

21. Page 49, Item 41. "...by administrative area" can be consolidated Into
Item 4 on all outlines, unless other methods of resolution are known.
Then they should be stated under additional Items 42 , 43, etc.

-5-

31. Pages M, 83 and 109. Item V, N and C 2. Under 'Redressing
population limiting factors," there Is a sensitive question that
need* addressing, what special consideration 1s provided for female
bears who happen to merely b* In the ana of, or actually Implicated
In a conflict situation? Female survival Is disproportionately
crucial compered to males, where does the agency (especially Park
Service) policy recognize this 1n their actions following an Incident?

32. Pege 57, Y 21136; Page 86, N 21124; and Page 112, C 21134. These
recommendations for rodent control in grizzly habitat seem to need
revision. The first sentence 1s not Inaccurate but 1t Is misleading.
It implies that agencies have a choice of toxicants or toxicant
concentration levels. It would seem that 1n most, 1f not all, control
programs on public lands there 1s only one toxicant option. Also,
disturbance for 3 days after baltlnn does not seem practical, due

to the long time that poisoned rodents and stored bait can remain
available. If control needs to be done In an area heavily used by
grizzlies, then there should be consideration of alternatives such as
plastic-net protection or Increased stocking rates (1n the case of
gopher control program on forest land).

33. On Page 57, Y 21134; page 113, N 21135, but missing from page 87,
It 2113-th* following statement occurs: "Drugs demonstrated to be
dangerous to bears will not be used." While the Intent 1s reasonably
clear, the statement could be construed to prohibit the use of virtu-
ally any drug on bears since ell of them are dangerous at high dosage.
We suggest rewording to: "The safest effective drugs available will
be used In all Immobilization efforts."

34. Pages 63, 91 and 117. Renumber Y. C, and N 33 to Y, C and N 34 to
conform to the Abbreviated Step-down Outline (paqe 48). Change "desig-
nate Critical Habitat" to 'recommend Critical Habitat" on all outlines.
Add Hem 33 as in the Abbreviated Step-down Outline to each population
stop-down outline.

38. Pages 68, 100 and 122, Item Y, C and N 511. It might be beneflcal to
develop monitoring systems whose results are comparable among
populations though the techniques might vary.

34. Pages 68. 100 end 122. Add Items V, C and N 5112 - "Periodically
analyze adequacy of monitoring system for arriving at population
parameters. '

37. Pages 70, 102 and 124. Change Items 61 throunh 64 on all the population
outlines to correspond to the abbreviated outline Items 6 through 64,
page 49.

38. Page 77, hi, paragraph 1. This discussion and computation of the
average annual mortality rate (17.8 percent) Is not clearly presented.
The reader cannot follow how the 17.8 percent was calculated or from
where this figure was derived.

22. Page 49. Add Item 5 (SI and 53) "Monitor Populations, Habitats' to the
IS for the Selkirk (S), NC and SB populations. This would be appro-

Jrlet* and Justified as a method to determine population status. Add
tea 6, "Manage populations and habitats" to the S, NC and S8
population's IS. This would also be appropriate.

23. Page 49, Abbreviated Step-down Outline, Item 53. "Populations" Is
Misspelled. Renumber "S3. Monitor populations after recovery" to
Item 52 and renumber Item '52. Monitor habitats before and during
recovery' to Item 53 to conform to the Individual population outlines.
Chang* the second Item *61." to "62."

24. Page 49, Add Item 9 to Abbreviated Step-down Outline to conform to
Individual population outlines.

25. Pages 51. 78 and 108, Items Y, N and C 111. Change "Judged recovered*
to 'Judged viable self-sustaining" or "optimum sustainable." This 1s
the stated goal. Population parameters are only one element required
to achieve delisting or "recovery." We agree with the need to estab-
lish a measurable goal for the grizzly populations. Page 108, C 111.
Change "CfiYBE" to CYGBE."

26. Page* 51, 78 and 108. Add Item Y, N and C 112. "Reevaluate population
criteria (1n 111.1 as new Information becomes available." Also add to
the Implementation schedule. This 1s needed because of statements
based on the divergence of opinions over the Craighead's Yellowstone
data (reference page 2), the need to use the most current and best
available deta (reference page 3) and to add to the dynamic plan
concept (reference page 4).

27. Pages 52 and 79, Items Y and N 121. The presentation of this data and
data in 111 are unclear. Which factors correspond to one another?
Where more than one number 1s Indicated for a criteria, which takes
precedence? Should this be expressed as a range? These tables should
be clarified. Is cub-sex ratio Important?

28. Pag* S3, Y 13133. This should be explained. What 1s grizzly
rehabilitation training?

29. In Itaa* Y, N, and C 1326.226,2261, and 542; Y 5323, C S34, and N 534.
Chang* "cumulative effects" to "cumulative Impacts" thus avoiding
confusion with the more restrictive Section 7 definition of "1nter-
reltttd and 1nter-d*p*nd*nt actions." What agency will be responsible
for tabulating this? How will it be used?

30. Add the following to the appropriate Implementation Schedules and
assign agency responsibilities:

a. Y 21135 and C 21136; Y and C 21141 and 21142; Y and C 21151 and
n 21141; Y and N 212 (There is no equivalent In Cab1net-Yaak
narrative); Y 311; C and N 3112; C and N 3122 and Y 32.

-6-

39. Page 78, N 1, paragraph 1, last sentence. Wording Implies that a
population (number or density) goal comparable to Glacier National
Park (GNP) was applied to the remainder of the ecosystem. This creates
« problem If the reader Infers that the plan will strive for GNP-level
beer densities throughout the entire ecosystem. This should be
clirlflad to avoid possible misinterpretation.

40. Pag* 136. Y 21136; Page 148, N 21124. It does not seem that EPA should
be the agency with lead responsibility for monitoring rodent control
programs; It should be the Individual agencies managing the subject
lands. Page 136, Y 21136; Page 148, N 21131; Page 163, C 2114. In our
review, we did not find where a compensation plan for livestock owners
Is allowed, but S183.000, $74,000 and $15,000 respectively (over a

3 year period) 1 s proposed for control work . W1 th the status of the
grizzly bear being of concern, 1t follows that nonlethal methods of
conflict resolution should be paramount and compensation nlnht be one
approach.

41. Place comments on duties of the Grizzly Bear Recovery Coordinator under
the appropriate section In the step-down outlines not In the IS. Other
extensive comments on agency responsibility should be In the step-down
narratives not under estimated costs 1n the IS (I.e. Items C 21134

C 2211; C 2212 - page 163).

42. Page 172. Add Itaa 81 to S, NC and SB population outlines and IS's.

43. The literature citation section needs Improvement. Sources are not
always completely Identified or described as to what they are (typed,
mlaeogrephed, In-servlee). Some citations are In reverse chronology.
K. L. McArthur Is cited heavily from unpublished reports. His
affiliation Is not specified. His reports are often used as a
secondary source from which to dt* original work. Since some of the
paper* come from stendard Journals (I.e., J.W.M.), this kind of
tertiary paraphrasing is awkward.

In summary, w* appreciate the effort and thought that went Into the Plan.
However, we believe the statements which Imply that meeting the stated popula-
tion 90*1* will result In "recovery" should be reworded. We agree with the need
to state measurable population goals, but that these goals are one of many
factors which need resolution before the species can be considered "recovered"
end thus delisted. For example, adequate regulatory mechanisms must be quanti-
fied and Identified for "recovery" to Injur* th* continued existence of the bear
one* delisted. We realize some reguletory mechanisms are now In existence,
howaver, th* plan does not Identify specifically what else is needed and at what
point these mechanisms are sufficient to delist the Grizzly Bear. Other factors
which wt believe have not b**n adequately addressed for Implementation Include:
atlntonanc* of travel corridors for genetic Interchange between populations; the
Importance of interchange of Individuals between Canada and the U.S. for tic
well being of the species 1n ecosystems of the U.S.; specific measures needed to
•flhenc* female survival rate*; and the need to reevaluate th* population
criteria a* better data is obtained. Explanations of th* population criteria
could be improved and stated more clearly.

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.7-

Attached «re coaanents iubi»1tted from the Division of Law Enforcement, the

EnvlroHneiiUl Protection Aopncy, U.S. Forest Service end the National Park

Service. Mi hoe* these coxontt will assist In completing the plan. Please
send us five copies of the Plan for approval.

Attachments

UNITED STATES GOVERNMENT

Memorandum

FISH AND WILDLIFE SERVICE
PORTLAND, OREGON

Regional Director, Region 6, Denver, Colorado

DATE: October 30, 1980

PMOSA AMtetent Regional Director, Federal Aeelatance,
Region 1, Portland, Or eg on (AIA-SE)

SUSJKT: Agency Review Draft — Grlealy tear Recovery Plan

'-up:

UNITED STATES GOVERNMENT

Memorandum

: Regional Director, PHS, Kl'ijlon 6

Acting

: Rational Director, Re si on 2 (SE)

CS. KISH k WILDLIFE SERVICE
Region 2, Albuquerque, New Mexico 87)03

November 17, I960

Ue have coapleted our revlev of the Grlaaly Bear Recovery Plan and have the
following comment, for your cone lderet Ion.

P«o Element T21U1

In thoee eltueclone where acre than one LE SAC Dletrlct le
Involved in an area, an Agent from each Dletrlct ehould be
Included In the ipaclally trained lav enforcement team.
Thla action will facilitate rapid coaavualcatlon of Infor-
mation and enhence coordination of effort.

rjMi He»ant T2113n

Mill* PVS uy h«v# responsibilities for overecelng and In
mm Instances conducting rodent control projacta In grimly
beer habitats, the activity of creating disturbencee la the
treatment alta for tbraa nights foUovlng application of any
rodantlclda should not ba a part of that reoponelblllty. This
la lanlied In Part III, page 136, and we wish to raltarata
thla thought hara.

la evarvlav, tha Plan la well-written, good format and appaara to addraaa
tha aajor coacarna for thla spades.

Thsak you for tha opportunity to offar thaaa eoaaMnte.

tusrtcr: Agancy Review Draft — Grizzly Bear Recovery Plan

Wa have reviewed the subject plnn nnri concur with the proposed recovery
efforts. Tha plan developers are to he congratulated for putting togeth-
er a aanagasMnt tool that quantifies goals, while recognizing the data
supporting the ac Indices are weak.

We eupport the ranking of taaka within the ecoeyetema and would encourage
elnllar direction be provided that would rank the ecoayatema themselves.
Thla ftuggaatiou Is nwide because of the magnitude of the recovery efforts,
funding conatralnta, and different degrece of threat to the six griezly
bear ecoeyatens. This for™ of direction, as well as that proposed, will
be changed aa data dictates.

We appreclete the opportunity to review the plan.

*v

-3B0

USefleyie.

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// / /

United Slates Department of the Interior

FISH AND WILDLIFE SERVICE

PA/SI/lear. Griatly—
Recovery Plan

NOV

tm

Tol Arc M*nuger, Billing.

tttm

Proai Rational Director, Region 6

10. Peg. 17, luc paragraph, third eentsnce — Suggest changing
"ehould ba a aeceeeary part" to "la a neceeaery part."

11. Paga 20, laat paragraph, fourth aantenca— Should ba ravrlttan.

12. Paga 21, flrat paragraph, laat aantanca — What are the population
eettaatee?

13. Paga 25. flrat paragraph, aecond aantanca — Should be broken
Into two eeatencaa.

1*. Page 25, aecond paragraph— Ian' t there eufflclent Information
on the Yallovatone Gristly Sear Ecosystem to give an average for males
and female* ?

Subjecc: Grlgsly Sear Recovery Plan, Agency Review Draft

We offer the following commence on the agency Review Draft of the Crlzily
War Recovery Plan.

1. Pag* 3, aecond paragraph — Somewhat confuting because "Colorado
grlsillee" la Included in the carentheeea with the other four ecoeyetema.

2. Page 8, flret paragraph, aecond sentence — la "when" eupposed to
precede "grlatllea have characteristic pattarna of behavior"? Otherwise,
It does not seam to fit the reet of the paragraph or the behavior of the
irlaaly.

3. Pag* °i flrat paragraph, flrat sentence — Appears that this
ahould be broken Into two eentencee, or perhape the comma can be replaced
by a aemlcolon.

4. Page 10 — The "Peat Distribution" aectlon haa a lot of information
on present distribution. Perhape thla aectlon ahould be renamed.

5. Pega 12, laat paragraph — Appeara to be out of piece.

6. Page IS, flrat paragraph, laat aentance — appeara that thle
ahould ba broken Into two sentence.

7. Paga IS, laat paragraph, flrat aantanca — "Ecoeyetem" ahould be
capitalised.

0. Pegs 16, second paragraph, third sentence — What la meant by
"the occupied range mey be expended"? Do you mean by biologists ea more
information la gained, or by bears?

9. Paga 16, second peragraph, laat aentance — "Crlitly" Is misspelled.

Saw* eT—aj mti few Serve Amtrinl

IS* Page 25, third paragraph, aecond sentence — Suggest you change
It to read "Age and eex structuree are dynamic varlablea Influenced by
eo many factora, such ea habitat condition* , rime of the yeer observations
at* made, hunting, etc., that trying to determine an averege population
may not ba appropriate."

16. Page 27, laat sentence — After they reach maturity.

17. Paga 32, flrat paragraph — Part (3) neede to be rewritten or e
sixth category added, as not all livestock kills are the reeult of care-
laaa llvaetock husbandry. The aow and yearling killed thle summer In
the rancher 'a corral waa aurely not the reeult of poor husbandry. A
eejslcoloo should ba used at the end of part (3) and the "end" removed.

18. Paga 35, fourth paragraph, laat aantanca — It appeara that this
belonge In leat paragraph of paga 3a.

19. Paga 39, third paragraph, aecond sentence — Need a comma after
"Convareely." The third sentence needs an "of" between "effects" and
"clear cut ting."

20. Paga AS— la thla eummary out of place? It le not a summery of
the preceding part of the Plan.

21. Page 46 — "Primary Goal" ahould be changed to "Primary Objective"
to conform with "Endangered and Threatened Spaclee Recovery Planning
Guldellnae." Can thla objective ba made mora definitive? If poeelhle.

we need to define at what point the grlialy can ba delleted.

22. Paga At— Wa Sugg set you oalt the word "Objective" end uee the
aantanca a* an Introduction to the etepdown outline. Aa it appeara now,
eomeooe could mistakenly use It aa the objective of the Plan.

23. Page 51. third line — Change "Subgoel" to "Subobjectlve."
Perhape there ahould be a statement lndlceting that the footnotoa are
located at tlie end of the aectlon.

24. Paga SI, Till — Thla la not really en objective. Appeara like
It ahould be uead aa text under the eubobjectlve, Tl, or Til.

25. Paga 52 — Doea the information In T121 accomplish plan item
T12? Thla la not really an objective, eo it ahould probably be used aa
tent under T12 or elsewhere.

36. Llatlng all the plan ltema aeperataly for each of the three
■aln ecosystems cauaae much duplication. Thla greetly increaaea the

,J* "•Vna "•kM recovery see. much more formidable than what
it la. If plan lteaa beginning with the digit 1 could be moved to
Part I then It seems that other plan ltema for the three ecoeyetema
could ba combined Into one etepdown plan in Part II. Part III could

" U U- Y, Ct and H could be need In front of

""**" "•"",1»t >*o neede to ecconpllah each plan item
in the different ecoeyetema, and what the eetlmated coet la.

26. Page 54— Appeara that T211 can be used aa text under Y21 and
Y2111 moved up to Y2U.

27. Page SB and 59— Appeere that Y21151 and T21161 can be used as
test under Y211S and T2116, reepectlvely.

am

28. Page 59, T22 — Suggest you change to "Reduce or ellminete
actlvltiaa Identified In Y132, I.e., thoee which Indirectly limit , . .

29. Each ecoeyetem aectlon le so long with so many plan items that
It la hard to visualise entire recovery programa for each ecosystem.
Would It be possible to prepare foldout eheate for each ecoeyetem that
Hat the plan ltema? Meet of our other recovery plana have theee foldout
annate.

30. Many of the above comments made on the Yellowstone Ecosystem
sleo apply to the etepdown plana for the other ecosystems.

31. Page 77, Nl — A population estimate le given for the Northern
Continental Divide Ecosystem, but one waa not given for the Yellowstone
Ecoeyetem, an ecoeyetem for which we have more complete data.

32. Pag* — Why not break 1 and 2 down further to show what
ae*4a to be dona to accompli eh theaa plan Items?

33. Paga 130, 1 — Suggest you change the third sentence In the
paragraph to "Preaently, there doea not appear to be any noticeable
enthusiasm beyond the field biologist level for increasing the numbers
of grltsllee In any of thaae areas."

3a. Peg* 130, 1*7 and 162— No plan ltema beginning with the digit 1,
are listed. Does thla mean that the Information presented In Part IX
for tl, II, and CI accomplishes theaa plan Items? If bo, thla information
ahould appear in Part I rethsr than Parts IX and XIX.

33. Paga 137, Y2242— Under "Action", "cooperative" is misspelled.

-174-

^Sr*ow o < two

UNHW STATES GOVERNMENT

memorandum

fail ir' of IndWo Attain

Agoncy t«ovlov Drnft - Ctlssly Boor tocovory Pin

**• Ac t 1m taj tonal Dlrocior, tan loo » (Attanttoni J
U.S. ftsh sn4 WlUllfa Snrvlco, QMvtr, Colorado

It sppaars that tKa stap-dovo Crlsily Boar loco vary Plan will provide
awoatontlnl neologies! data oo gristly bnara. linen tKa plan will lapact
two of tho Indian rasorvstlooa within ths Nor thorn Cootlnsotsl Dlvlda
Gristly War Icosyston, thn Flnthnnd and Blackfaot, tribal and Buraau of
Indian Affairs Involvonnot will on aasantlal, not only to tha trlbsl
rasourca prograjnt lovolvod, but to tha ovornll succnss of tha plan. As
such, tha luraau supports ail phnsss of tho • tap-down plan whars trlbsl
and fernou InvoUnawnt Is outllnnd and lnsurns that Buraau and tribal
coordination with thn othar aganclaa will ba pursund.

In ordsr for ths rncovory plan to nont Its gosls snd objsctlvaa, funding
for thn pcojsct will bo crucial. At tho prassnt tint, funding for any
■pacific phaso of such a step-dowo plan has not bnan rsquostsd or
sppropc Is tod. tinea Buraau snd tribal Involvnannt In tha overall plan will
bo significant to tho succsna of thn rac ovary of thn gristly boar, funding
for tills acojnet on tho raoorvntlooa any bo llkoly, provided that satisfac-
tory projact proposals by thn raapoctivc Burnau ngnnxlas and/or trlbns ara
swsnulttnd for approval .

In ordsr to fwlly uaplonont thn proposnd plsn on Indian Lands, addltlonsl
funding will bo nocoosary. Stncn Indian rssnrvntlons srs not sllglbLo for
fusjdlng through thn vsrlous "Fadorsl wlldllfn consnrvstlon funds" for ouch
projects, sacur lag of funds for inplsntsntst loo of thn sctlvltlns on Indian
lsnds any ba dsisyod. Uconnandatlons, howovnr, will bo nod a within tha
lurnnu-fwndlng procoss to nocuro nscnassry dollars for laplonwntstlon of
gristly soar roc ovary projects.

Mo will rscnsnnind thnt closo coopnratlon bo as tots land with thn trlbos snd
Bur now sgnnclss In laplnnmntlng tho proposed rncovory plsn. This will bs
enacts! U ranching ovorsll Gristly Inar ftncovsry Plsn objnctlvns.

Ms othar conwnMts a pacific to any of tho nctlsltlnn In thn a tap- down plsn
will ba ssdn nt this tuns, wo sporscUta thn opportunity to rnvlnw tho
Ovnft tocovory Plan.

nnp^vTj *W1cu1tvr«

Aqtncy Htvltw Drift • Gr.Jilv B«ar Rtxovtry PUn

RECEIVED

/

tie

«IUO STATES GOVERNMENT

memorandum

to. R«f|1on«l Olrtctor, Region 6 „

U.S. Ftsh t midlife Service, Oenver, Colorado „

From: Assistant Area Director. Resources fj^ —

The drift olen was sent to the Slackfeet and Flathead Indian Reservations
within the Northern Continental 01v1de Grizzly Rear Ecosystem. We have
attached the conmnts received from Flathead Aoency, those from Slackfeet
will be forwarded uoon receipt. As we are all aware the Interest, studies
end management levels on end adjacent to Flathead Reservation present the
best circumstances for Initial Implementation of a nrlzzly bear recovery
oroorem. The manaoement plan developed for Flathead Indian Reservation 1s
In draft staqe and will he reviewed by the Tribal Council 1n the near future.

Our summation of the Job IiwlemenUtlon and Rudnet position shows the lead
responsibility estimated costs of $11?U5U for Blackfeet Reservation and
tt7,?S0 for Flathead Reservation to be soent over a three year nerlod.

We would pose to you the question of whether or not the GdRP will be Interpreted
by you is one of the specific F1sh 4 Wildlife Service resource commitments
under the Fish A wildlife Assistance to Indian's Policy. This specific
policy being: "Therefore, the Service will with the consent of the tribes
and utlno Service resources, develop end Implement fish and wildlife plans
On Indian lands for resource programs Important to the national missions and
mals of the Service and primary concern to the Department of the Interior.
Eueole situations would Involve migratory bird management areas, endangered
species recovery plans, anadronpus fish restoration projects, and areas of
Important fish and wildlife habitats".

alternatively, we would need a cost schedule for^ersonnel , transportation,
ner diem, etc. 1n order to support special funding requests for this nrogram.

Attachment

1

Buy U.S. Savings Bonds Regularly on tha Payroll Savings Plan

date.: November 14, 1980

UNITID STATES OOVtKNMKNT

Memorandum

TO Area Director, Billing* Area office

Attention i Agriculture - George Jennings

rasas : Supaxintendent . Flathead Agency

auajtCT: Craft Crlsaly rear Itocovory Plan Ccmrcnta.

Thie Recovery Plan for a species that 1» »o wide ranging, but yet has local-
ized areas that are critical, magnifies the cooperative agency effort neces-
sary to achieve recovery of populations. The Flathead Agency has participated
in efforts to provide for and manago grizzly coats for monj than 3 years. Our
intensive research here has been concluded by a contract with the Border Grizzly
Project St the University of Montana. Now our efforts here will include iirple-
aantation of guidelines into lend management activities such as forestry and
range, monitoring effects of timber sales in grizzly bear habitat, ran torn.,
population par arm ten snd to stratify habitat for management . We will cooper-
ate with ell agencies involved In this effort.

Ml feel the coats, tasks snd priority alignments listed in Part Ill-Job Inple-
santatlon and Budget ara realistic to accomplish the stated goals. Cocierative
efforts for funding will bs necessary to insure concurrent studies and manage-
ment isvlamsntaticn. Tha uiis,ijasu $21,000 par year for three years on the
riathsed Indian Reservation would undoubtedly have to ba secured by a special
funding request,

Tha sanagsaant plan developed for the Flathead Indian qesarvatlon is in draft
stage and will ba reviewed by the Tribal Council in the near future. This
plan coincides with the opals snd standards of the Recovery Plan and includes
taplsnantation of management guidelines. Cooperation on s regional level with
all agendas involved la included and is critical for insnagefrent and recovery
of the ^ae*s»iy bear.

of thsjjrsnYsary bear.
Menard whiteteU

ONITIO STATES ENVIRONMENTAL PFIOTECTION AGENCY
WAAMINOTON OC 104*0

I Meeker 21. I»i0

0.1. Depsrtaee: ef tea Xstsrlet
flak sad Wildlife Service
teealeitee. D.C. 20410

At teat lee ■ Pete Peslee, Office ef lassasatod Spsslse
Base Petal

As

far the Oclssls Issr. Ve appreciate tha opportunity

to ceasMst es this drsft docaaent. Kd Tlta a

ellellfe kleleflet ea ear staff kss stspsrsd ths sttsehed

se— acts 1st /sat eesatdaeattea. leeefnllv theee will be

aaefal la eevelsslas, a ftaal receveiy plea for the grtaely.

Otacataly years,
tayaead V. Matksay

avufjsjr^tnrvisrtt

-175-

NOV 1 7 FttCrO

xVo U.S. Stmti Bmii XiaUrii n itt Fxoll SMmm H~

Ill rotation to (N'i regulatory responsibility of pesticides tha docuaant
glvae enly scant mention of pesticides; end then only In relation to
r**eaaaa»det1onson the irtt of rodentuidei . No discussion 1i at von it to
which reemwUUtde. ehet Uraat gagctee. or ethar factors ralatod ta field

' — I tool and potential <Mn *" fHulM froa their use. In the
I of each • d1icuss1en the i no— nOit t«w> |1von art aesnlngless.

mOwrt considering, toxicity, potential for exposure, and what risk 1i con-
sidered acceptable, the recuMinfitlon It ado to ia« th« wo it tolactlvo
(•at effective) redantlclde. It 1i possible that the most selectlva (but
effective) could i enact tha gHuly, althar dlractly or Indirectly.

Tha i ii, —nidation an rodentlddes procaads to Indicate "poisoning within
gHuly baar habitat should ba delayed as long as posslbla Into July to
•Inlwiie tha potential for grltllles to contua* poisoned rodanta or baits
(0' tar* par. eaa. 1N0).' Again, without clarification, this stataaant
aafces little aanta. btiv would dalaylng traataant until aftar July raduca
tha potential far grltillas to cansaaa polsonad rodants or baits? Do food
habits Chaaaa ar

■hat?

la addition ta redantlcldas. tha usa of othar pattlcldas could adversely
laaact tha species, and tharafora soaa consldaratlan would saaa approprlato.
far aaaapla, tra any harblcldat uaad In tha known ranga of tha grliily, and
If SO, would tha rasultlng habitat modification Jeopardize tha racovary plan;
ar ara any Inaactlddas usad In tha known ranga and what lapacts wight thasa
cauaaT

aeJor crltlctta of tha docuaant Is that tha proposed racovary
sully ewdorstood or followed. Thara teoeers to ba several
far tha lack af clarity; net tha laatt of which Is unclaar writing.
Tat fallowing ara Just a faw examples:

plan Is nat aas

'■aeagnlilng that observation and aanagaaant conditions it that tlat wara
dlffarant fraa haw, a coaparabla population. Its equivalent paraaatars, or
tha blaloglcal equivalents, as wall as tha spaca and habitat usad by that
papulation ara assuaad ta represent a racovarad population 1n that ecoiystew"

rage II

Tha trand In tha numbers af grliilles 1n tha NCOSBC appaars to ba downward
whan tha addad s trass of Increasing hablut ancroachaant by Increasing
naabars af people 1s considered, tha need for action Is obvious."

raw H

friar ta first as true, a tale grlttly aay be wore inclined to dispatch a
reaale far food than to enter Into a social agrtiaant far meting."

(! was nat aaara that aale grlules had an astrus cycle)

Page i\

"Thara 1t Intufflclant evidence to fully assess the degree of aortal 1ty 1n the
{twaer ago classes of bears to adult bears, rearua i.l*7t>. ifkart and Stakes
IHlf). and Nagy and hut tall (It*) 1a hcArthwr (Wl) Indies tathat H aay be
■Etpartoat fartar. If yo wager bears ara net killed directly by aggrattlve
•aVCs, dtaaanlng swkeduHs aay ba forced to choose subaarglnal hoae range or
area* near hwaan habitation equally dangerous to their survival.'

If thara Is insufficient evidence to assess tha degree af mortality In younger
•at clatsas, than what evening doaa 1t have to conclude that disparting subadults
ara faced with an equally dangerous situation?

th addition, tha construction of this paragraph It obviously cuabartaaa.
rage 41

"Panning habitat descriptions and activity have been described for the Mission
Nauntolni (Montana) by Sorvheen (1M01"

I I raitael' tha subject was darning of grlzxllet and not aountalnt.

Mp would strongly suggest an editorial Itetlon of tha docuaant. Ma would be happy
ta review it again fallowing editorial changes.

th) agree with your list ttotoaant on page «5, and If this draft docuaant 1s an
af tha all-out concerted effort, the future of the grlxily looks bleak.

wildlife biologist
Icolaglcal iffacta trench

srKAons oFHogrniuTA

helene, Montana 3*620
March 20, l*dl

Mr. DM V. Hlaalch. national Director
0. t. Fish tad Wlldllfn Ssrvlcs
P. 0. taw 1S4M
Bawver federal Center

Colorado 10225

Baar Mr. Mlaalchi

■h kawa reviewed tha Agomey tevle* Draft of the Crlnly tscovery Plan, mi a
draft ta tha raault of a good off art - I believe Don Irovo has dona an ax-
aallaat Jo* with a vary d Iff leal t subject. We da have aoaa concarna; follow-
ing are eur c mm cs. I aa aetry thay ara so late.

Pltet of all. I sal lavs sevarel of tha assumptions lapllclt In this lacovery
Plea ere, at beat, highly queetloaeble. I understand the legal lapllcetlone
af tha tktaataaad status, bwt aaa of the ward "racovary" la tale docuaant la
aleleedlag. Tha tans "racovary" lwpllae that tha apaclaa neede to ba racov-
arad and that It la oot racovarad now. mis la aa aeeumptlon bsead on an
arbitrary definition. Several elaaa throughout this Plan, euggeetlone ara
ends that ar* "neceeeary to aaeuro th* racovary of tha trirsly." Tvlcs la
tha esaaary a* page 4) It atataa that the grlaaly la declining - an sssuap-
tla* af avaa laaa sw*staat Lallty . rtaally, St ahoold ba pointed out that
tha Initial act af classifying the grlaaly ee e threatened apaclaa aaa. In
aar eploloe, arbitrary and without justification.

Out aaa* earlewa crltlclaa of this racovary plea concerns tha eaf in It loo of
"roeesery" Us sgraa with tha atataaaat on sags 1 af tha Introduction, that
it "shield ptavide via* la, eelt-eee tela lag population* la patpatwlty." we
da aet halleve that papulation a la* (above aaaa aialaoa) la a*e****rUy ra-
lated ta a viabls. eelf-eeetalmiag population. Population atahillty la a
faacilea af a b*l*ac* sstwsiu racraitaaat and aertallty ratae. Thia racov-
ary plan eeeae to imply that aaaa previous, population level auat ba achiev-
ed la erdar for it ta ha "reeovared." It should he clarified that tha lavel
agreed wpo* far a racovarad Telloeetone population (equal to or greater than
ear tag tha Craighead study) will alaoet certainly h* higher than a ■lalaaa
viable population. Th* pa 1st la that "ncovary" a*d "wlaiaua viable popala-
l ara aet eyaewyaoa*.

as aaygael a racovary level a* usa th* wliil— viable population. The
Telleweteae papulatioa shoals' he eeewaed to h* recovered wbea It ia squal to
sr greats r than th* level during the Craighead study (a population Which sea
tairsjailsg ia tha fece of Halted hunting la Mmifoea end MyeaUag). racovary
fee th* but tears gopuletlae aeald be e level eqaal to or greater than the
HH-75 level whee it wea dacUrad taraeteaed.

Mr. Oea V. Mlnnleh
■age I

March M. 1M1

Th* racovary plan Hate aevetel criteria or pareaatare that will ba uaad
(aa a raaaiag d-yaet average) to Judge population recovery. Several of
these, Including reproductive, aortallty, cube par feaala and reproductive
cycle ere tataa; fewelee with cube of the yeer and aan-cauaed annual mor-
tality are reel nuwbere. We euboit theee ere two different typee of
neahere. are not coepatabls and cannot be evaragad with Che eawe weaning.

A rate ie the raault of a aeepllng procedure and la repreeentotlve of the
entire population for a given year. Aa such, ao averega glvea eech year
equal weight. A real nuapjar aay ba the reault of a eaaale. but the Inten-
tion le to schlsvs a coaplata aouaaratlon; aa such, anything laaa than a
fall eewaaretlon doaa not rapreeent tha population that year. This would
eayeer to he a spec tally true of feealee with cube of the year where the
auaher seen ie were a function of observability than tha effort expended
eheervtng. Observability u e function of weetber, aaa son, vegetation
growth, obeervlng conditions, obeerver eaperleace, conditioned raaponaaa
af the heere, etc.— obeervlng effort eight only ba a elnor factor.

wham aaadtere ere svereged, th* average is automatically akaved In tha
direction of the niawter furthaat frea the average. Thla ia accepteble
shea averaging reteet It le sot acceptable when evereglng ouaaere raault-
isaj frea ebeervebUlty bus which ere not repreeentetlve of that yeer e
actual eltuetioa.

If faealeo with cube la to be one of th* criteria uaad. and If it la ln-
taeaed to be s sailuua anaaaratloe, then ell information gathered should
he eaad to obtain the beet poeelble figure, for exaaple. If the number of
fsaMAse with yeerlUge uceede tha nsaaer of feaalea with cube obeerved tha
preview* peer (aa ts tha caae with (night 'a lt73 end If 76 dete). then the
faaalee with tebe figure frea the prewieue year ahould be edjueted upwards.

Thia ia a aeeful criterion aad find lags wUl he coapared to thoee of the
Craighead study- Without am "ebeervebUlty Index." however, the figures
will aet he coaserable. It le laportaat that euch ee Index ba developed
aad. by tha end of the study, that It la acceptable to management ee well
ea the reaaarcb taaa. Periodic review of theee efforts by e technical
review paael would help gwereetee lte acceptance.

It meet ha acknowledged that for eat maaaaaaaat practices continue to ad-
eereely affect th* grlaaly beer. That "timber herveat la most beneficial
aa a gristly bear habitat in paeon t tool U ea ovarelagllf lcetloo

aad, at beet, mieleedlng. If timber herveat la ta enhance grlaaly habitat,
tha aasnamilng araaa meet be aeintelned aa cover aad fraa froa dlotuiheaceo
until the cat ever arae has recovered - thia eel do* if ever, hepeeae.

gatwtel burns, which neve tha pataatial of Improving habitat conditions, ere
still ^morally aaggraaaad. Including vildaraaae flree. The above statement

-176-

Mr. Doa H. Htnnlch
torch 10. 1M1

regerdla* adjacaot cover areae also holds true for um aurroundlni burned

If uipMi 1« axpectad to •on it or population nd habitat trands, aora aan-
paasr aad assay will ba naadad. Ha ara preeently vorklng with land aanaga-
m afsaclaa oa tlaoar aalaa aod roada, but aaldoa (at to look at a aala
ana ears tkao one*. Idaslly. aa ahoald sake pr.logglng, logging and post-
lotting laepectlone of critical babltata Juat to aaka aura that our racoa-
aaoaatloaa, or at laaat aoatt euldallnae, ara follovad. It doaa llttla good
ta asvslop guldellnee and aaka t labor and road aanaesaant racoaaandatlona
ualaaa aoaaoaa la available to aaa abathar or not thay vara followed.
Perhaps tola could ba a raspooslbtllty of tha Grltily tecovery Coordinator.

I hawa dlacaeisd othar aspects of tha flan vlth Don grown and do not ballava
they annul repeating la thla letter

Tha iallia Departaant af flab, Wildlife, and Parka la currently eupportlng
■tlttly Investigations with • slgnlf leant portion of our tightened hudgata.
«a do aat ballava tha ease laval of coamltaant haa baan aada by aoaa of tha
•that reap see lb Is standee. Tha lew level of lnvolveaant and coaBltaant by
tha laad aaasglog aaanclaa haa baan disappointing . Ha ballava tha fadaral
-j caa, aad ahould, do ana than thay have for tha grluly.

Ha ballava tha 1 a n— ml a r 1mm la thla plan. If followed, could provlda
mi in to aany of tha quaetloes atlll unanavarad and halp guarantaa a
bright fatara for tha grlaaly la Montana.

I aap rae lata tha opportunity to coaaant. Again, 1 aa aorry thay ara lata,
linear*!*!

Jaass H. flyoo
Blractor

STATE OF IDAHO

DEPARTMENT OP FISH AND GAME

> SO WALNUT ST - P O tOX 2J

eotii idaho men

April 2. 1981

Mr. tM L. Brows.

erluly Bur tecovary Plan leader
Oeoertaent of F1sh, wildlife end Perks
1420 test Sixth

Mi***, hmum men

Our Don:

Thli Is t Mntl consent on th« Grlttly Bear Recovery Plan
tnd replaces tha on* I stnt to you July 28. 1*80 and ono
sont to Nr. Wayne Brewster Noveaber 20, 1980.

Plwso us* tha changes agreed by you and Lloyd Oldenburg
In Denver, March 13, «nen you reviewed tech of ay prtvlous

— nts.

Than* you for all tha offort which 1t has taken to get this
plan to whtrt 1t 1s now.

If you hiv* furthtr questions, pltata call .

$1nctr*ly.

si haa trsw*

m

•TATlWj^^Vor WVOMIMQ

Hoveseer 13, 1980

J watt C. trttJMn
Acting Regional Dlrtctor
U.S. Daptrtaant of Interior
F1sh and Wildlife Sarvlc*

p.o. io> am

Denver Federal Cntir
Colorado 8022S

Re: FA/SE/Beer, Grlzily--
lUc. Plin

Door Nr. Britain:

bbjuja^ re viewed tha Bristly lair Recovery Plsn tnd tar* th* following
Abbreviated tup-down out Una, pao* 49

Ma sra not cartsln how this outllnt rolitas to tha rtcovary pltn. It
tsaetrt to at dlractad toward working tha pita Into tha mtnageaont of tha
frtttly by State tnd Fadaral agencies. Tha ovflln* 1s vary bread tnd wt
sat llttlt wrong with It. ttjwevar, tha location of plan taploaontation
(ttap 8) taaat out of sequence. It seeae aor* logical to begin lapleeen-
tetien of tha pltn prior to stops 5, « tnd 7.

nacovory Pltn: Population Monitoring T 1 - Y 121 (pag* SI and 52)

at do not tgrat with tha concapt of inking tha ttttlnaant of tht popu-
Ittlen paroattert is reported by tha Craigheadt t aattur* of tht success of
fWawary. Available date should ba us ad to aaka tha bast tstlaatas of tht
atari at* present. A populitlon objective should ba tsUbllshad tnd popu-
lltie* ttrtoatofi should ha aatsurod tnd utad to ettlaate futurt population
levels, one* tha objtctlva for populitlon slta Is rttehtd, tho populitlon
par a» tars will ttttbllth aanegsaamt stnttgltt to bo followtd to mlnuln
na papulttlon it th* objective laval. Tht list of populitlon pinatttrs
presented or thalr biological equivalents are not Indapandant. Actual
values for that* statistics say vary froa thost attturtd by tht Cnlgheads
or tht InUrtatncy GHuly taar Study Ttaa (lAtlST) ahlli population
rtcawars tnd dots wary wall. Ut ballavt i aor* nallstlc approach would
h* ant ksud on an objtctlva for population slza with a aonltorlng tystta
•toad an tht tntlyslt of rap reduction ind aorullty data on an annual and

KJUlotO

-177-

Jaan C. (rltaan
Rowtabar 13, 1980
Pt ga Two

(a: FVStVaatr. firltzly-llac. Pltn

lllaotl huntlno: Y 2111. (ptga St tnd 5S)

Tha concapt of t law tnforcaatnt team sttas roisonible but jurisdic-
tional tnd supervisory p rot lata nay aakt tht tun 1n«fftct1ve. A more
raatomblt approach would s**m to bt a nor* loosoly structured aoproach
with U.S.F.M.S. tnforcaaant ptrsonnal assisting state personnel with the
solution of violations within sac* state's iret of Jurisdiction. As long
•a tha grittly mains federally listed, the U.S.F.W.S. would ttkt tht
laad In that* ettforcaaant m tittles Upon delisting, tht states would
tab* tat lead.

aadwca Accidental Depths: Y 2113 - Y 21131 (page 57)

Tha ayoaing Saae tnd Fish Departatnt does not hive the capability of
keeping highways free of carrion. Wt will, however, encourage the State
maiaay Dtptrtatnt to Increese their efforts in gHiily habitat.

T 21133. Tha likelihood of this departatnt moving carrion away from
rellHSd treat! MM raajbj, t*W If thaea MlHlt (ft in in ICtldlbll
area, tttl iafirtaint ledll tnc PMIMFC88 IRdj tlat to do thli M I Urge
stale, rtoaevar, If mortality of grluly bur along nllroidt btcoats i
significant problea, this Daptrtaant aould do everything possible to assist
1a reducing these aortal 1 ties.

T 21134. Tha stattaent is aaae that a sponsoring unit oust certify
t drug before it It used on betrt. What Is a sponsoring unit?

Aaanc, Control of BrtuUati Y 11 14 (ptga II)

Y tit and Y tit. Tha Bantral of specific problea bears with e licensed
■water is feasible. Public hunting should be considered tt t tool to atniga
grluly populations. In addition to the supervised taking of problea bears.

Cost of the Mecovory Pltn ta WaaFO

The following est la
should giv* seat idea of

ettiaste of cost* to tha Daptrtaant 1s prollalniry, but
actual costs:

let

Trained law tnforcaaant ttaa aeabar,
it It 1 1taly that with the various
obligations resulting froa tha pltn
(I.e. ctrrion rtaowtl, public educttion,
handling of problea bears, tnd enforce-
■ant) will require, it tha wiry least,
one- he If tan.

Cost

$15,000.00 t year

C. SrltMK
13. 1M0
baft ThrNo

ft*. FA/SI/tMr, BHnly--leK. Plan

1

*.

inv ii^iwnifl(iOT< or wii ■ pur is

•radicated m the antlmatlwi of the
MRTi

ftt.000.ro year

1.

•a»l1e Education, V5.IO0.0O fir»t yttr.

I 1 ,300.00 y«r

4.

Srluly bear Recovery Coordinator.

$ 6.2SO.0O year

5.

•rliily besr horttllty Coordinator.

( 850.00 year

1.

Aesatrcn tod Otvtleoaont.

$ 5,000.00 ytir

7.

Aomrtnistretiye tlab - 1 Mn Month.

t 2,300.00 yaer

at nttati that the cott to this OtptrvaHit the flrtt yo*r could bt
•» auc* ti Ml. 700.00 and fM,W0.00/ye*r thereafter. This cost Is certainly
not escettlva 1f the option 1i extinction of tht orltily boar. HoMver. coiti
CMld b* rodMMd If alternative* vara contldarad to torn of tha Iteag In
tta recovery. Ona altarnatlvo would bo for tha U.S.F.H.S. to accapt graaur
fiscal rtaaoMlblllty for this plan.

Thank you far pro*ldtM aa «iu tht aft»rtar<1ty to coatwit.

Slneoroly,

H, DONALD OEXTIA

ASSISTANT DIKCTOR-OPERATIONS

i. ii

lee dor. Wyomlnq Cooperative riah a
wildlife on it

UNITED STATES GOVERNMENT

memorandum

6^

«/■/*•», Orlxely ]
hep team! Director, taqlcm a

I ham mill tha srlaaly Peer bonry riaa. Omdl, I faal
tha Plea la »U written and provides a food d motion (or Hint
tha frlasly population.

that
in tain lap

1. Ma riaa oaaae to ba directed toworda recovery of tha gristly popula-
tlaa for hunting. Thla la flna, however, thara ara uny k:< people who
•meat J net lib* to aaa tha haara aad photograph tha. n» Plaa doaa

pahlla education. IMf ahaald. If peaelblo, lncludo protected
vielt attaa far tha potato.

1. fcoeltet oahoaienseiit la maatloned several tinea In tha riaa. Tha kay
to aalatatalaf tha bw population la through habitat maintenance,
empmnele should ba plaoad oa determining tha habitat and food requirements
af tha grlaaly. aafaxanoa la made to apaoa. Tha Man alao addroaaaa
MtaUa-haatlaa. Thla la «aad, pnysevea, taHiaim i m .war, roemvmva, traae-
nlaegco llaaa and wood lota arasaatr what tip tha minimal alia habitat
■■riasiiy to empmee-t a viable grlaaly popalatiaa? No* do «a maintain
aaah an araa attb human psooomoot

1. Tha Plaa rafan to tha Shaffer aadal. thla aodal only provldaa a refox-
anoe pelat haaa an evelleble data. Tha Plaa ltaalf questions aoaa of tha
•Ma. Tbae, tha aadal shesOd ha tha eegtualag point. Nora field atudlaa
em aaaaaaary to provide batter data and larger aaaplaa to aaka eueh aodala
enaatlaa.

leasee with the snjor prlerltlaa artabllahad by tha Plant funding lawala,
hpeetmi', m lea. It aay ha stall lory to tm naat rata af forte la araaa
eaah ae tmUmi mn where the hear popalatiaa U large.

STATE Of
WASHINGTON

DEPARTMENT OF GAME

an Na* u*m Ww. ul 1 1 <*•*•. w» am

31 Octobar 1980

Jaaaa C. Oritmen
Acting legloaal Director
P. 0. box 23416
Oaavar Padaral Cantar
Denver, 00 80225

PA/n/baer, Brlaaly lac. Plaa

Dear Nr. Crltmaai

heterdlag the Agency lev law Draft of the Or inly Baar Racovary Plan. I
hare rawlawad tha document aad hava aada tha following obaarvaclona.

Waealagtoe haa aarglnal grlaaly popula clone In Selkirk Mountains and tha
North Caacedee. Tou have termed theae "Orltaly bear Ecosystems" SMCSK
aad NCBbt. It la our obeervetlon that theae araaa In Washington rapraaant
aa Inelenlf leant portion of range for a Canadian population. Wa hava found
na eTiastoBtftf deeming la Waaaoaarten. faaprw^lg, ye* treaeaamt lapll..
that political eub-dltioiea eonenoe espsratea gttasly populetlone froa
Canada ead aakee than the reepatlblllty of the political entity at which
yew can point a finger.

The primary goal on p. 46: "To raaova tha grlialy beer front threatened atatua
la tha 48 coetarelnoua United Stetee" la the epltoaa of the above rationale,
tonebody In planning, not familiar with the problem, might aaauae chat alnce
the grimly le oely preeeat la four or five etetee, the other 13 or 44 atetee
ere wader the gun. go we both know, the "41 coateralnoue United Stetee" le
eamalieia* eieleglaally ea a eeperata entity, poeolbly beceuee aeet Americana
believe tha "lower 41" la the ceater of tha Dnlvaree. In thla cooeldaretlon.
It le Important to think of Aleeka end Hawaii, not ae atetee, but ee terrl-
torlee or eetellltee which ere not a part of the ceatrel core.

Orlaallee are rere In Haahlngton, although you hava Identified chat wa have
two of the eevan Gristly bear Icoeyeteme. pp 171-172 ldentlflee WD to
eapend 1120,000 over three yeera to detormloo the ttetua and habitat of
grlsallee la tbeee two "ecooretaee" . He have already dona thla to our aatla-
f action within the budgetery llmltatlona under which we operate. We ara not
euro that amending 1120,000 would tell ue anything about the ♦ 10 grlsallee
which wa doa't already euepect. Wa are euro thet apendlng $1?0,000 would not
remover the gristly In Weehlmgton. We do not have $120,000 nor even $1,000
which we oea epend oa thla problan. Our Nongaae budget le already committed
la ether arena ead It eppeere to ue that tbeee proposed grl
weald be e east a of public funga.

Jamaa C. Crle
31 Oct. 1910
Page 2

following are aome obaarvatlona about the etetemente In the text:

(1) e.l: Minimum Viable Population (MVP) 30-70 beara. When adjacent Canadian
eraee are Included, our population* nay ba that large.

(2) e.3t Minimum area required to eupport KVT: 403 ml_. When Canadian araaa
ere Included, we have minimum araa required.

(3) a. It While feaalee with young comprise leee then 201 of population, they
caused 791 of tha Injuries to people. Wa hava not obaervad faaalas with
young In Washington and hava not had Injuries to people.

(4) p. 11, 45: estinctlona should be changed to estlrpatloae. "Extinction"
refare to epeclee lose not removal from one eree.

(3) P. 12, 13: 1100 and 1973 grlaaly range by Schneider le undoubtedly en over-
eta tenant In thet 1S0O mop shows satire etete aa grlssly raage. tegardleee
of reference, 1800 le the broad-brush approach and 1975 nit-picks. If 1800
le Inaccurate for Washington, I euepect It le for Oregon and Nevede also.
He realise that the dramatic "then ead now" la typical treatment for rere

(I) p. 14: Colorado's kill la elallar to ours for 1979 and la the only poeltlva
evidence of e grlssly population. We hava sightings over the years in the
gelklrte. Whet about Colorado sightings?

(7) a. 17: tnterchentea between all ether populations are feaaible. end conald-
eretloa to protect travel corrldore ehould be a naceaaary pert of future
lead plane, between Selklrko and Caacedee this la doubtful through Waahlng-
toa, although I have not looked et possibilities In Canada. Protecting a
travel corridor across Pond Oreille, Columbia, Saepoll and Okanogan rlvere
le fer fetched.

(I) p. IS: grlssly bear tcoeyetcma In the conterminous 48 Stetee 1979. It
shows bCE la aaly four atetee. The other ii heve nothing to do with It.

rill been

"Isolates of

(I) J.tfi Natural hebltetf— tfMfb.a .alafldt-

fensetly larger continuous habitat, thla le eteculatlen. It may hava
alweye haaa thla way.

(10) p. Hi - — maintaining corrlcora for lnter-leolete dlepereel between popu-
lilioMi «ee (7) above.

(")■».,»' IrMaa home r.aee tw^tt pllM). hVeloo-ll? {64 to ?»3>; femalee-
72 (40 to IIP). We aay not hava enough room for grltallee.

tl"1ft»VEO -i78_

Jwt C. Orle
)1 Oct. 1IW
rag* >

(U) i.Mi GrlsslUs hgve o— of tin lawn reproductive rotes among

terroetrlsl entmali- Thle i» charecterietlc of May extinct species and
My m an Indicator that Ilka thoaa elrmady gone, they ara program* sd for
extinction Vy their biology aa wall u thalr loaa of habitat to aan.

(U) t.301 "The only Rood RtisRiy la a deed one". Not heard In Vaehlngton
isiouea thay ara ao rata.

(14) af34i People who — provide unnatural food — eaare reaponelblllty for
future fgrris and violence committed by grlitllos. Maybe true, but a
hard pill for a naulad victim to evellov.

(13 1 a. 3gi POX of aerial redlo relocations of instrumented grlsslles were in
dayiga corar*— (but)-— only IX were more than a kilometer froei an opening.
gemma the "plalne grtaaly" doesn't Ilka the open plalne.

(It) to tl-*2i Panning habitat nay be a population Uniting factor. Have not
found dana la Waehlngton.

(17) P. tit bwdxatory conatrelnta ouporvieory commitment half-hearted

attanpta to
auato f

join

xaly comply — -with provlelona of—
lng or lack of full cooperation by" — aganclae — was

the Recovery Plen. In-
of tax

dollar o—oa tine t Ion ■ only an all-out concerted effort — atate ogencleo.
Again* extinction la the wrong word and It eaema to uo that budgetary
conatrelnta ehoot down ouamrvlaory conmldaant to grlatllea and aubatltute
eupervlaory commitment to budgetary conatrelnta .

The goal expreoeee In our proponed atrateglc plan for grlrsllae la "maintain
population at currant level" and we will do thle with complete protection under
law. We would like to contribute nlnor funding to Jonkel'e Border Gristly
project, but we will not even give lip eervlca to spending the funds you sug-
geet in the Recovery Han.

Sincerely youre.

Big Cans Haaagi

UW/rpb

cct Dan grown, Montana Pish t Cn

United States Department of the Interior

NATIONAL PARK SERVICE
INTERAGENCY GRIZZLY REAR STUDY
FORESTRY SCIENCES LAB

P.O. BOX IS76
BOZEUAN. MONTANA 58715

November t, 1980

Mr. James C. Crltnan
Acting Regional Director
U. S. Plan am) wildlife Service
t. 0. Box 25*86
Denver Federal Center
Denver. CO 80225

Deer Mr. Grltnan:

I have carefully reviewed the Crlaily gear Recovery Plan end an Impressed
by lte completeness.

Although I eee no problem with using the 1939-67 deta aa a basis for
recovery - in fact, I eee no other alternative - I do think that the
ecological equivalent should be etreaeed norc. Given the lover reproduc-
tive retee characteristic of the preaant population and the changea In
land uaa elnce 1967, the sane number ot_ beers will not produce aa viable
a population. '

I have a few mora apeclfic commence, aa followa:

Page 20 - Clven 5.5 million acres In the Yellowstone Ecosystem end
current eetlnatae of 200-330 baere, the density would be between 1 beer/
23 ml2 and 1 bear/4* el2.

Page 25 - The everege home reuse of 42 ml2 for e gristly beer in the
YeUowotone tcoayetam la far too email. Our published dets show evereges
of 9* mi2 for 12 baare in 1976, 199 ml2 for 20 baara in 1977. 110 el2 for
beare in 1978. and 112 el2 for 19 baare In 1979.

Pege 31-1 haven't computed it out, but an average ennual mortality
rata of 17-18 percent seems very high for a apaclee with ouch low
productivity.

Pagee 32-33 - Those sources of man-ceueed mortality Hated under
private cltlaen control other than aelf-defenee should be listed under
Illegal hunting.

*****

RECEIVED

Page 71 - The poeeible conaeoueocoo of instilling a faer of nan Into
baara should be coneidered. If much a program were aucceeaful, it could
limit the carrying capacity for baara elnce bears would tend to avoid areaa
with noderete-to-hlgh recreational uaa.

Page 142 - In reference to "intensive monitoring for population
Parameters," Don Brown and I talked thia over with the understanding that
the IACBST would do the actual monitoring sines we vere engeged in that
type of activity already. I eee that although all of the egenclee partici-
pating la the atudy ara Hated, we ara not Hated aa a cooperator. le
this an overaight? Also, when Don and I talked about budgets for this
activity, I van talking about a total research budget rather then Juet
■nattering. The 8*00,000 listed for thle activity la vary high, even for
a research budget.

Generally, the coats Hated for the Yellowstone Icoayntam appear to be on
the high aide.

UNirtO STAT» DKPApVTMKNT or AOniCULTUrtl
FORIIT IINVICI

■IMttMT ROTATION

4200

November 10, 1980

1 Mr. Jmh C. Crltaen
tUcief Regional Director
Fleh and Wildlife Service
P. 0. to* 254M
Denver Federal Center

t- Denver, Colorado 80225

Deer Nr. Crltnan:

Richard ft. Knight
Teen Lender

Thank you for the opportunity to review the Agency review dreft of
the Crlaily Bear Recovery Plea. Our Itetlon consent a ere euauerlied
ee follow* :

1. We found the docueaot difficult to critique. Mr. Brown haa
done a fine job of suaaerUlng and organising the Information. However,
auch of the content ie difficult to comprehend because there appeara to
be e aubetentlal enount of duplication due to treating each ecosystem

aa e eeperete entity. We believe eoea bind of overall sumaary state-
aente end euaaary teblea would be very helpful in tracking reeoanende-
tloue end coete. In none ceeee we ere not eure whether auch itene ea
the Lew Bnforcenent Teas T2111, N2111, and C2111 la a single entity
or three eeperete effort* . By totalling budgets into e single compila-
tion we would have a better conprehenalon of the Magnitude of the Job.

2. Tellowetone dletrlbutlon deta. Figure 3, One of our scientists
le currently couriering nape for hie euaaary uenuecrl.pt of the Tellow-
etone Crlsaly Beer ecoeyatea date. He notea that eoea nlnor revision
of thle nap night be poeeible in the near future.

-179-

9. Recovery Stetletice. One of the recovery etatlatlca epeclflee
that eoea nuaber of feaalee with cube should be observed . For the
three ecoeyeteea thle eaouote to about 5 percent of the populetlon in
the Telowetoae. end about 10 percent In each of the other two areea.
We believe the Tellowetone figure aay be far aore reelletlc, partlculerly
when coneidered In relation to the amount of experience and flying tine
required to produce Information unobserved by the bears. The present
feaele-vlth-cub target any ant be poeeible la the other ecoeyeteea.

RECEIVED

StVl3-80

a>R>»)»Err

2

4. Action ltene under 22, reletlng to population limiting fectore.
call for determining tha eccumulstlve effects of paat actlona Impacting
grliallee. Thla la an estreaely important cone apt , but difficult to
track In tarma of coordinated affort in tha document. In particular,
tha document la apllt us In auch a way that it la not poaalbla to tell
what bar tha Job la considered raaaarch or management, or whether tech-
niques eslet for actually accomp 1 lehlng tha work.

]. Job Implementation and Budget. It might ba halpful to add aoma
furthar explanation undar tha ltam "Priority of Joba." Aa It now atanda,
tha document aaya that our number 1 priority, and thua thaoratlcally tha
araaa which ahould receive primary funding and attention, ara In tha
Cablnat-Taak and tha North Caacadaa and gelway-Bltterroot Ecoayatama,
•Sara currant baar populations ara minimal and currant raaaarch la
minimal. Tat, I auspaet, tha varloua aganclea will continue to put a
groat deal of affort In tha othar acoayacama which arm Hated aa lower
priority.

6. Part III. Pagee 13* and 1*0. Undar ltaaa T422 and T432 tha
Interagency Crlaaly gear Study Team la given lead role reeponalbllltlaa for
helping resolve dlffarancae In egency stratification and management direc-
tion. Since the IACMT la a raaaerch team without line management authority
they ahould be Hated aa coopsratore rather than undar lead reeponelblllty.

7. Estimated Coata. we assume tha coate are eetlmstsd st tha
lowest organisation level, the project level rather than Regional Office
or appropriation level. Even as, aoma appear to ba quite low. Alao,
where poaalbla, coata for an action ahould be eetlmstsd whether they ara
part of an ongoing program or not.

I hope tha above comment a will ba halpful. If you decide to put together
e nummary table of coata, and particularly those aeeocleted with research
neede aa compared to management needs, ws would appreciate the opportunity
to review and dlecuee them with you In relation to our Experiment station
research program.

gin oa rally,

ft. BAT
Station Director K^y

Unrrvo eraTXa Dvutuimt or AeettcuiTune
pomaav eamvice
Bocky Mountain Poreet and Langs Experiment Station
222 South 22nd Street
La r amis. Wyoming (2070

4200

October 28, 1980

'Mr. Jamas C. Crimen
Acting « eg lone 1 Director

Dgrw

P.O. Boa 25484
Denver Padaral Center
CO 80225

Deer Hr. Grltaan:

1 have reviewed tha agency review draft of the Crlaaly gear lecovery
Plan and found It very Inter sec log. The Information presented In
Pert I bring everyone up-to-deta on tha statue of tha Crlaaly and
points out tha problem,. The Information on dletrlbutlon and popula-
tion la not encouraging, but It etlll shows there la a poeelblllty to
■anege the grlaaly bear habitat In a way that will keep then around
for a while. The approach to show tha bare bones of tha situation
ahould help to make tha problems eaay to understand and help support
efforte to get the grlttly Into a recovery situation.

The step-down plan end Implementation schedule shove the cooperative
efforts that generated the recovery plan. There la not time to loae
In this fast moving society and already we are hearing the problems
sssoclstsd with energy exploration and grlnly bears. If all the
human activity could bs dens while tha bsars ara In their dans during
the winter It might help. Getting people out of tha beer' a habitat
during the rest of ths year would be the nest problem.

Tha mark by Blaachsrd relative to gristly uss of timbered araaa waa
Interesting to us. The elk and aula dear exhibit the aaaa use of
timbered sreaa during tha summer daylight hours in south central
Wyoming. Their heart rates wars higher during ths warmer weather
ana since they have a poor systaa for stsylng cool, they need ths
'•"J*"1 *» adjust sad conserve energy. Ths slk end dssr

•on t use timber for resting during the day when It's cold In ths
winter. So thla behavior has to be thermal requirement rather than
security, although when people sears them they head for timber.
Since bears have the same physical problsas with staying cool during
watra weather. They would atay near tha thermal cover during tha

Tha priority of Joba and budgets appear to ba in line with the
present situation. The support of Pederal agencies la contingent
upon available funds and public concern. Certainly tha U.S. Poreet
Service le concerned and obligated to support ths program.

Ths Recovery Plan (sags 130) for ths Selkirk Mountains, North Cascade
Mountains and Salway-tltterroot Crlaaly Beer Ecosystem show a aubgoal
to: "Secure, maintain or re-eetabllea grlttly bear populations."
This sukgoal say be too strong a statement until preeent status of
trlxelles within ths three ecosystems ara known. There ahould be
some affort mads to determine the f eeelbllitlee and confllcte related
to having grlislles In these arena along with tha status of the beers.
It aay show ths reasons why grlislles ara not doing well In the srea
and point out tha Halting fsctors for future i

Hlncinly,

UwiTco graves OeeanTMewT or Ammicw-rume
Fomaar asnvics

Rocky Mount>1n Forest and Range Experiment Station
240 West Prospect
Fort Collins, Colorado 80526

Kvjvember 3, 1980 •>_ —

Mr. Jams* C. GHtjun
Acting Regional Director
U.S. Fish end Wildlife Service
P.O. Box 25486
Denver Federal Center
LDenver, Colorado 80225

A. 10*11 VAID

Baaearch midlife Biologist

Deer Hr. Grltasn:

Enclosed are soao coaansnti on the review draft of the Grlizly
leer Recovery Plan by Lorln Ward. Project Leeder at Ltrsnie. WY.

Me hope that these ccaxwntt gre helpful.

Sincerely,

CLYDE T. FAS1CK
Assistant Director

Enclosure

RECEIVES

n-s-ao

-180-

ARTMBNT f *MU a* UAM*

230 South FrsnklLn
Juneau, Alaeka 99801

December 31. 1**0

To

J«M C. Grltman
Actio, kagioaal Director
0.1. Fleh (ml WUdllfe Service
Box 25486, Denver Federal Center
Dam, Colorado 80223

Mar Mr. Crltmani

John Beacham, preeldent of cha laar Biology Aaaoclatlon, haa asked aa to
ayuthaalae cnanante of Aaaoclatlon offlcara and council aaaibaia on tha
sgaucy review draft of tha Orliely laar Recovery Plan. Tha Bear Biology
aaaoclatlon la coapoaad aalnlj of north American agency and university
people with a apaclal inter cat la hear biology and aanagement. We
teallie that our comments ara being auhmlttad after your Sov ember 17
deadline. Mowever. we understand other revlevere have been granted an
extension end «a hope that our comments will therefore be conaldared.

t vlll flrat present general comments made by two or acre reviewers and
than no re ■ pacific coaaanta. leepoudanta provided ante detail than la
praaented here, but many of tha coaaanta not Included Here should be In
other reviews which you receive.

For tha Tsllovetona population, It appears that too much reliance la
placed on Craighead data froa beare utilising an unnatural food aource
(garbage duapa). It la vail documented that nutrition and food aupply
can Influence reproductive parameter! . A food aource auch aa a garbage
dump might elao affect lntree pacific etrlfe ana other behavior. Tha
gar heme dump altuatloa no longer ex late and it might therefore be preferable
to mam Knight ' • data aa tha baali for describing reproductive biology,
home range alia, population composition, and perhaps other parameters in
relation to habitat available now and In tha future, or et leant lntcgrete
Knight's data with tha Crelghaede' data. Reference only to Craighead
data occurs at eeverel placee throughout the plan.

With retard to tha KDCM, CP data ara extrapolated to provide e population
estimate of 500-800 anlmmla . Tha mean ((50) la basic to tha plan «nd,
mora detail should ha provided on how cha 500-800 figures ware oht '
eapeclally alnce It waa by personal en— mlcatlon and details are »M
avallabls in tha literature.

at la detailed tot tha abort tan but an amotion le aade ofj
tan monitoring and costs. This ta eepeclelly Important aa

6*81

Deccabar 31, 1980

and actlvltlee arc increasing and placing more prteaura on gristly bear
peculation*. Short tar* budget flguraa ara high. It la qulta poaalhle
that etete and federal egenclea vlll not be able to provide funds at
theae level*. The plan ahould propose alternative funding eourcea.

Tha plan treats all arena in a similar manner regardless of the quantity
or quality of data for each area. A batter approach night ba to tailor
a ulan tu «*rli ar«*a hy Mi|ihaall1tig light Let prota.it Inn and r**Mr< li hi
areaa where population data ara lacking ("C.SM.BB, and C-T) . In arras
vlth populetlon data, auch data ahould be uaad along with available
knowledge about inpacta of varloue land uaea (logging, llveetock gracing,
cummer home development . oil and gae exploration actlvitiea, etc.) to
develop a oommraaanelve plan with epeclflc recommendations.

Horn epeclflc co

Dta are aa follow*.

P. 4, para. 2 - The Plan state* that nonblo log leal aapecte of gristly
bear aanogcaent were not considered, and that the** will be left to
administrator* .

Cocyent i Hon biological eepacta nay be aa Important aa biological
aapecte and we believe they ahould be conaldared In the Plan.

P. 19, para. 2 - Plen eta tea that grlssly bears have "unpredictable
home range elae."

Cp*M

age of

Orlsily beer home range alaaa ara influenced by the aa* and

age of tha Individual and by the quantity end quality of their food
aupply and lta spatial and temporal distribution. Therefore, one would
anticipate conelderable variation in ho** range elae, but generally one
ahould expect eaeller beam range* where food aupply le good (coeatal
brown bears) and larger range* where food auppllee are snrglnal (Tellovstonc.
Tuao*. ate.).

P. 24, para. 2 - Plan states that eubadult faaale grlaallee do not
dlaperee and that tha anther eceoaaodatee tha* within her ho** range.

fun* mn 1 1 This behavioral strategy haa been described for bleck beare,
but can It be supported by tha literature on grlsily bear*.

P. 24, para. 2 - Plan euggeat* that fcaals grlaallee ere territorial.

Caamaenci This atateaaat contradict* earlier statea*nt on page 23,
paragraph 3.

December 31, 1980

Deceaber 31, 1980

P. 25, pare. 2 - Plan etatoe that "in the Ycllovatone Grlialy leer
Kcoayetea the everege home rang* alte was 42 ml2 (Craighead end Crelgheed

»72c)."

Comment: Knight any eleo have data on home renge si**, end If eo, we
euggeet that it b* Included. Hoa* ranges are dynamic end flguraa would
have nor* value if data were Included on eex, age, and length of tin*
bear* ware aonltored.

P. 32, pare. 1 - Plen lists five categorlee of man-related mortality

nt i This could be sore complete
lity froa ftusssll's 4-year etudy

Co— mat i This could be more complete by citing finding* on nan-induced
mortality

P. 31, Cover aectlon - Plan aakas no distinction between visual and
theraal cover requlreaeats of beers.

Coaaenti Plan should distinguish between tha visual and theraal cover
requlrcaenta of bears and thereby acknowledge that they ere different
and important.

P. 31, Sac. Til and Till - Plan uses reproductive pereaetere reported by
Craighead a aa baele for eveluatlng recovery etetue.

Coennti Knight may have data which are e nor* accurate reflection of
tsr response of beere to their dependence on a natural food aupply. If
so, these data might ba batter to uee than tha Craighead date.

F. 31, Average estimated annual mortality rata - Plen suggests recovered
status with 18.63 percent mortality (Craighead at al. 1974) or 17.10
percent (Shaffer 1978) .

Thame eeaa like high mortality ratea for tha Tellowetone
gristly population to sustain if both aaxae are Included In tha mortality
(ame Cowan 1*72, p. 382). Va suggast caution before piecing auch rmphaele
oa population simulation models became, eo many variables that are uead
to eetlmsts annual mortality ratae ara "beat estimates or gueeeoa" and
are not baaed on hard data.

-181-

Pp. 51-32 and footnoteo, pp. 74-75 - Plen atatae that Cralgheada reported
a cenaue efficiency of 77.3 percent and Cowan recomputed e ceneua efficiency
of 58.6 percent. Cralgheada ware seeing 14.889 femulee with rube per
year and Knight reported 12.0 faaalea with cube.

Comment l Pemelee with cube reported by Crelpheads should have been
relatively aaay to see becauae bears were concentreted at duapa. We
euggeet that Plan addreaa tha different censuring efficiencies of Crelgheada
and Cowan and relate theae to censuring efficiency of Knight's study
and tha eeeoclatlon between the 14.889 females with ruba reported
by Craighead end the 17.0 femalea with cube reported by Knight.

F. 54, Flan ltaa T21111 - Flan deacrlbea lnveetlgatlon proceduree for
Illegal kills.

Comment : Klllo could ba learned of eoonar and better Information thereby
obtained If e toll free number for reporting kills were established end
publicised. This appliaa also to private cltlaen control (YS115) and to
other ecoeye terns.

F. 57, Flan ltaa y 21 134 - Flan etatea that only experienced peraonnel
certified by e sponsoring unit will handle grlaallee.

Part of tha Flan could ba to prepare requirements for certification
slaller to guidelines In T21133. This appliaa to other acoayateae alao.

F. 13, 8ac. V2111221 - Flan states that faaale aorullty would be
reduced by e hunting regulation which prohibits the shooting of baara in
groups of two or more.

£1 Another regulation to reduce feaala mortality would ba to

allow hunting only during periods whan feat aa are leeet vulnerable.
There la eeaa ov Users that feaelae ere la» vulnerable In tha spring.
(Incidentally, wa do not understand why measures to reduce female mortality
la the acDOii are not part of tha Flan for tha TGBE and other ecosystems) .

F. 136. Plan ltaaa T22U, T2221, T2231, T2241, and T2231 - Plan glvae
than ltaaa a Priority 3.

C«aaanti Should ba (Ivan Priority 2. All Flan ltaaa for Tellowetone
•ad almn tot other acoayataaa pertaining to tha stratification of habitat
an public lands ehould ba given Priority 2.

Sincerely,

/'Jack W. Laatfar ^
Vice President
tear Biology Aaaoclatlon

THE WILDLIFE SOCIETY

MONTANA CHAPTOT
September 10, l»eo

Mr. Juhi C. Grltmen
u»0l Plan and Wildlife Service
P. 0. Box 25484
Mnvu Federal Center
Denver, Colorado 80225

Daar Mr. Grltmani

Thank you for providing tha Montana Chaptar of Tha Wlldllfa Society
with tha opportunity to comment on tha review draft of the Grizzly
Max Recovery Plan. I aa responding to thle document aa a repre-
sentative of tha Montana Chapter, but I do not have expertise with
grlssly beara. Several other Chaptar members, Including Richard
Knight, Charlea Jonkel, members of their raapactlve atudy teams,
and U.S. Foreat Service, BLM, Park Service end Montana Department
of riah, wildlife and Parka, alao will, in their official capaci-
ties, review this document. Tha Montana Chaptar aupporta their
ooesaenta.

Tha Introductory portion of tha document did not adequately sup-
port tha step-down plan and job Implementation. Examples of
speolflc weakneaeee follow.

Tha taraa 'direct mortality" and "Indirect mortality" are flrat
used on p. 48. Thoaa terms should have been defined and their
function aa population-limiting faotora clarified In the Intro-
duction.

Frequent reference la made to the "Guidelines." Thoee guidelines
should be Included In thle document. Are thoee guidelines suffi-
cient or ahould othera alao be developed?

frequent reference la made to a "Grlizly Bear Recovery Flan Coor-
dinator." Thla document ahould Include a job description and
quallf lcatlona for that position. Similarly, tha role of each
cooperating agency In the selection of that individual should be
defined.

It la apparent from thla document that the grlizly bear became a
threatened apeclaa because of human encroachment. Likewise, C2261,
p. Uf, Indicated that "each new action (conflicting land usea)
has the potential of being 'the last straw,' from the standpoint
of the bear." Yet, In the Implementation eectlon, actions to apply
guidelines to potential land use conflicts era only rated aa
Priority J. Anything less than Priority 1 aeema lncongruoum^p^.. ,

AN ORGANIZATION FOR PIOFIS5IONA1 WILDLIFE BIOLOGISTS

OCI-2-80

Mr. James C. Grit man
September JO, I960
Pega Two

It ie noceeeary to Include the job Implementation in ita present
format because it defines specific actions to execute each item
In the step-down plan. Yet, In that format, and with 28 coopera-
tors, it also deflnea bureaucratic chaos. The job implementation
ehould be ebatracted to Include e deecrlption of responsibilities
for each cooporatur, and clear direction for management and research.

Indeed, "to be healthy . . . means to be whole." Just as National
Parka are not complete ecosystems, tha six occupied grizzly bear
areaa arc a mere vestige of the historical species distribution.
Successful management to conserve grizzly bears and their habitats
within thoee six ecosystems \f » yity narrow definition of recovery .
True recovery never will occur and tha health of the Biosphere thus
le falling. The preaent atetua of the grizzly thus serves to demon-
strate the magnitude of our responsibility to all of our wildlife
roaourcee, not juat threatened and endangered species. Implementa-
tion of the Grizzly Bear Recovery Plan will be difficult and ex-
pensive. The cheapeat and moat affeotlve recovery plan for non-
endangered apecles is wise stewerdship now, while those populations
still are healthy.

Again, thank you for the opportunity to review this document.

Yours sincerely,

John G. Mundinger
Secretary-Treasurer

Montana Chapter - The wildlife Society

JOMima

NATIONAL WILDLIFE FEDERATION

1412 Sixteen* Street. N.W., Wsshlnfton, D C. 200 J* 202— 797-fcHOO

Movessber 4, 1910

James C. Orltman

Acting Regional Director

0.8. Department of tha Interior

Fish and Wildlife Service

P.O. Box 25486

Denver Federal Canter

Dearer, Colorado 10223

Be i Orlsily Bear Recovery Plan
Dear Mr. Orltman i

Tha National Wildlife Federation (BWF) welcomes the
opportunity to sea m t on tha Grlssly Bear Recovery Plan.

WWP, with more than 4.6 million members and supporters,
la tha largest private conservation organisation in tha world,
war la dedicated to tha restoration, viae uaa, and perpetuation
of tha natural resources of tha Worth American Continent.
Oar m—tiiri use and enjoy tha wlldllfa resources of tha
On 1 ted States, Including the grlssly bears, for recreation,
aesthetic enjoyment, photography, and aolentlflc etudy. Aa
such, MNP le vitally Interested in tha recovery and conserva-
tion of grlssly bear populations In the lower 46 states.

>ar» I

An understanding of the grlssly bear population status
and trend, lte habitat needs, and the basis for axceaelve
mortality rataa Is essential to an analysis of tha overall
Recovery Plan. Part X of tha Recovery Plan provides an
emoellent and ooasprebenelve overview of tha status of tha
grlssly and lta habitat needs and sets tha stage wall for a
review of tha remainder of tha plan.

RECEIVED

wis ■bo-

ss C. Orltman
4, I860
Page 2

HQ »

Step-Down Outline

Tha stated objective of the step-down outline is to
• describe methods and actions needed to bring grlssly boar
populations to recovery status" (emphasis added) . In two
critical respects, tha step-down outline falls abort of thia
act Ion- forcing objective. First, paragraph 3.34 of tha
outline cells for the designation of orltical habitat. Merely
designating auoh habitat la not an action in tha aanae of the
stated objective, particularly if tha habitat la not on
federally-owned or managed lands. Wa suggest that beyond
designation, that the outline call for acquisition of critical
habitat, and designate funding sources for such acquisition.
Second, and similarly, paragraph 1.33 requires tha Identifica-
tion of travel corridors. As Part I of tha Recovery Plan
Botaai

The necessity of developing or maintaining
corridors for inter-isolate dispersal between
populations may prove to be vary important.
"... Individuals dispersing from adjacent or
oontlguoaa ha hi tea oaa abora up a faltering
population. * (Plan, pp. It • 20.)

Tbua, aa with critical habitat, tha outline ahould alao addraee
various approaches for acquiring travel corridors.

Recovery Plant
Tellowetone Qrlisly Bear Boosystam (YQBI)

Rather than cessment on the recovery plan, job Implementa-
tion eohedule and budget for each of tha six ecosystems, we
haw* limited our comments to tha YOBS. In general, our comments
on tha TOM are representative and apply to tha other systeae.

While paragraph Y211 (p. 54) recommends a goal of "zero"
for man-induced grlssly mortality, tha plan aettlee for eleven.
Wa question the selection of eleven, particularly where the
Planning Group want on to recommend that the man -caused mortality
rata not exceed five or six grizzlies. Further compounding our
concerns over tha selection of thia apparently high figure la the
Recovery Plan' a adm.'aelon that population figures are difficult
to determine and thua uncertain. (Recovery Plan, p. 74, note 1.)
Oncertelnty of thle sort would seen to call for a more conserva-
tive approach to grizzly mortality.

-182-

Jsmee C. Qrltmsn
Novaatber 4, 1980
Page 3

Jnu c. Orltman
Dovabw 4, 1S80
Page 4

According to paragraph Y21123, araaa opan to black bear
hunting will ba restricted If the hunt conflicta with the
gristly. Ha euggeet that the Recovery Plan rscognlte that
Implaaeentation of these raatrlotlona depends on both atata and
federal authority and the cooperation of theee two antltlea.
In turn, each of thai* authorities shouid ba spelled out in
the plan and how they will ba implemented, absent tbsse specifics.
It Is difficult to ssmss the likelihood of auocaas of this
suggestion.

Ha suggsst that the Recovery Flan define the terns
"nuisance bears" and 'problem bears" (see, e.g., paragraphs ¥212,
Till and T(llll) . A clear understanding of these tens is
essential alnca they directly affect gristly mortality ratea.

Throughout the TOU Recovery Plan, atate and federal
officials are assigned specialised tasks or responsibility
to protect grltsly bears. For example, under paragraph Y21132,
all agencies must clean up carrion along highways. Onder
paragraph X21122, warning signs must ba placed along highways
In high-use grlssly sreaa. Each of theae requirements is
important to the maintenance of grlssly bear populations. He
suggest that the Recovery Plan identify the authority (statutory
or regulatory) upon which theae responsibilities are baaed,
who will exercise this authority, amd whether it la a
discretionary or mandatory duty. Ry establishing the baaia of
these requirements, we would ba in a batter position to judge
the likelihood of their eventual Implementation and success.

Paragraph Y3 ahould contain a land acquisition provision
much like that of paragraph Y32S1. The mere designation of
orltloal habitat is quits useless If the area is in the private
domain and cannot be protected or managed.

rmft III

While the job implementation schedule for the YGBB
assigns estimated costs for • three-year period, it falls to
establish a fixed, deadline-oriented schedule for implementation
of the Recovery Plan for YOU. He euggeet a achedule which
ooatalas beginning detae, sohmdule milestones, and all reaaonably
foreseeable dates for the aooompllahment of specified objectives.
Absent such a fixed achedule, the plan may experience unneceeaary
delays. Moreover, public groups suoh aa HHP are not adequately
apprised of the Plan's schedule of operation. He consider
sptsdy Implementation of the plan to be eesentisl, yet we have
mo Idea to when the plan will be commenced.

Peges 13) through 141 oall for recommendations on ths
purchase of privets property. Once again, we suggest that
the purchase of land and the sources of land acquisition
funds are eaaentlal ingredients of the Recovery Plan. In that
regard, we suggest that land purchaae be a budget Item in
Part III. Furthermore, we suggest that the plan analyse the
various federal and atate acquisition programs which can or
will be ueed to acquire land under the plan.

The job achedule does not refer to the provisions of
Y21123. Believing that this is an important provision, we
euggeet that it be incorporated in the schedule.

Finally, the job sohedule also omits ths garbage dump
provisions of Y1323. Since garbage dumps in national parka have
presented serious bear/human conflicts, we believe this problem
should be addressed In the job sohedule.

In closing, HHP commands the Recovery Plan for ita
comprehensive approach to maintaining the gristly bear,
■owever, attainment of the Recovery Plan goala la much mora
likely If the authority for implementing many of the Plan' a
suggestions and rsnrsxs sndatlons is thoroughly understood, if
the program is more structured In a timing aenaa, and if
adequate land aognlslslam etajectlvwaV sjpa established.

Respeotfully submitted,

Thomas 0. Tomaaallo
Counsel

Resources Defense Division

TOT iks

22, 1980

AMERICAN WILDERNESS ALLIANCE
4R4**^4*mm"*wmw**aB^«ssifsmr*e*ie».

124 Puller, Melons. Montana 3**01
(40*1 441-0323

*> . Ikin S»I«H

Iknt. Ospt. of Plan, Slldllta, t Parks
1420 tut tuth Avanim
Selena, Montana S**01

I sesllss that I 'a not on your list of official rsvlswsra for ths

^ bear reoovery plan, nor do I olaia any sapsrtlee In grlaaly
ess* ssaagsmsM. smnn, x'm writing to paas slong ons eoamsnt i had
arts* rssslng sear ths draft plan.

As you know, tho foraat (srvios la In tha prooaas of allocating land
tejmrlous uses, prlsarily as wilderness or nonvlldsrneos. Sines dealgnation
waesr ths 19*4 Wilderness Act would obviously provide habitat protection for
r",'"™1' hsar in such araaa aa ths Nonusent Peak region just waat of
Wllovstone National Park, It esses proper that tha Poreet Sarvlca'a land
!ir^_ "•o^10"' should oonaldar tha 1 apart on tha grlaaly bear. Praaantly.
the Purest tarries la reluctant to evaluate ths impact of land allocation on
the gristly bear or other threatened or endangered apeciee. Inatead, the
sasmsy prefers to wait until epeclflc land uses (I.e. logging) are recoo»nc*d
before carefully studying the lapact on ths grlaaly. However, et thia nag.
or taa proses, Major land allocation declslone are already aade.

? dlaaarae with thia approach. Land allocation can here a treaandoua

***t1*" °" the rTlsaly hear. Por instance, vlldorneoo

°« provide habitat pretsotleii and nonwildernsss can allow various conflicting
t^rJ^T*i 1 ™VlM th»l sosflietlsm land uses oaa hs prevsntsd in nonwlldarnee

that w^m T0"*"1** " °- »sco»*ry piss can contain soma Ismguaga

M^SSL T51 . mnUm 60 °°a*tUz »»*«t of their lanT

allocation, on the grlaaly bear and other threatened er T*Un,sr.d .peel...

KTATK OK >!<».\TA.\A
DKl'AHTMKNT UP ACHICI I.TI HK

•aaautsiA. niintama mm

23, 1980

Mr. James c. Gritann
Acting Rsgional Director
U. 8. Dspertmsnt of interior
Pish and Wildlife Service
P.O. BOX 25486
Denver Pederal canter
09 10223

Dear Mr. Oritsmn,

*snk you for the opportunity to review the Gristly Bsar Imcovery Plan.
It arrjaaxs that our role will be in line with ths normal duties carried
out by ths rrrwinxsoantal sartapenmrtt (Pesticide) Division.

Although wa have no subatsntiws crmmsnts at thia tin, ws would like to
*» *■»* Informed of sir/ mjuusmtsd ohangas that occur during ths review

Sincsraly,

N. <2srdon MoOsber, Director

M0M/kg

I thanks for sending a easy of the plan.

Or. John Craighead
Dr. Char lea Jonaal
OS. Menard taught

teat regards/
Bill Schneider , editor

ana

10-4-80

■1S3-

4»4SSi.sll1..4««lss/e>»is)aiii)lii)»..0S,,il,i,.)tl SJMssHsjsi

DEPAFT 1ENT OF NATURAL REfXJRCES
^ AND CONSERVATION^

> C. Grltmen

19, 1980

rwii JCT.f

UKuixnna

STATE OF MONTANA-

< epoetin 4 » jrti

boreemar 19. 1980

Jmi C. 6r1ta«n

Acting Regional Director

USD!, F1ih ind Wildlife Service

P.O. Box 25486

Denver Federal Center

Denver, CO 80225

Deer Mr. Srltmn:

Thank you for the opportunity to cawent on tht 6r1zzlv Bear Recovery
Plin. Department personnel reviewing the plen generally felt It presented
t good siaeaary of current knowledge about grizzly beers, providing e basis
for state land managers to understand and attempt to srinlialze effects of
■anegeeamt actions on the bears.

The Plan Identifies six grizzly bear ecosystem, three of which may
be affected by the eianageeent of state and private lands In Montana. These
ire the Cabinet/Teak Grizzly Bear Ecosysten, the Northern Continental
Divide Grizzly Bear Ecosysten, and the Yellowstone Grizzly Bear Ecosystem.
Within the three mentioned ecosystems It appears that there art two main
areas of responsibility that the experiment1 1 Division of Forestry Is being
asked to assist In. These are:

1. State lands need to be stratified with respect to their Importance
to grizzly bears and then management objectives formulated for the
stratifications. This appears to be a process similar to designat-
ing "critical habitat", or 1n the terminology of the "Yellowstone
Guidelines", designating "Management Situations".

2. Timber management and other activities on state and private lands
within three ecosystems need to be planned and evaluated with con-
sideration to grizzly bears, and coordinated with similar plans
for adjacent federal lands.

The Depertment is committed to offering assistance 1n these responsibilities,
a* these are things that are already being done on a case by case basis and
completion of the stratification Job should streamline our land management
process. For Instance, the Swan tow State Forest Management Plan recog-
nizes the grizzly bear as a species requiring special management, but lack
of specific Information hat hampered efforts towards implementing meaning-

Page t

ful tpeclel management procedures. This situation will hopefully be remedied
in the Swan River Stete Forest and In the similar planning effort currently
taking place on the Stillwater State Forest. In addition, one area which may
not have yet been tapped which 1s partially DNPX's responsibility under this
plan It communicating the Intent of grizzly management guidelines to affected
private landowners assisted by the Division of Forestry.

Tht Department will attempt to keep current on guidelines as they are
developed and refined through Border Grizzly Project studies and continuing
consultation with the Department of F1sh, Wildlife, and Parks, at well as
through further development of tht Grizzly Bear Recovery Plan.

Sincerely,

Wayne Wetzel

Environmental Coordinator

WU/bw

cc: Don Brown. Fish, Wildlife, and Parks
Jeff Jahnkt, Dlvltlon of Forestry

MRUaeOTON NOHTWfRN

S6

RESOURCES DIVISION

TIMBER AND LAND DEPARTMENT

700 South Awnu* Ww
Miaoul*. Montane 60801
Telephone (4081 6434637

knabit 18, 1980

Mr. Jemee C. Orltaen
Acting leglonnl Director
0.1. Ilek t Wildlife Service
P. 0. Bern 25414
Dearer federal Cater
Dearer, CO 002 25

Deer Mr. Crimen:

Inclosed are ccamemta relative to the agency review draft of the Grlttly
leer tecovary Tin. garlingfen lor there hem aateaalve land holding* within
■campled tritely baar territory and It la Imperative that private land-
owner* have the opportunity to participate la the development of a twi-
te tie reoovery plea.

generally, the plan haa attempted to Identify all biological factore and
eetlvltlee Which will require ettentloa or management If the gristly baar
la to he removed from threatened etatua In the lower 48 etetea. Whan
▼leered from the private sector, the plan pre* ante * confusing overlap of
federal and eteta ruaponelkllltlee Involving aa many aa eavnn lead agencies
to accoapllah a alalia tank. The role of the private landowner le not *de-
qeetaly defined . For Instance, over 208,400 acre* of private land la the
northern Continental Divide Ortssly hear Icoayotea la Identified aa requir-
ing "stratlf icatlon end nan a tenant direction." The For** t Service haa been
daalgnated aa the land agency la noat of thaee altuatlone with the private
laaaeeaer lietad aa a "coop ere tor." What tola will the private landowner
have la evaluating atretif icatlon and direction and how will this he accom-
pllebadf

Specifically, points rained by the plan are aa follows:

1) Within the Talloweteaa ecosystem, point T**2 (pate 65) suggests a
reviser of 20,000 scree la tarn Tsylor-tllgerd tang* of the Gallatin latlonal
Sorest for "lnclueloa in occupied grlssly range la light of the comments
regarding occupied habitat In the Back Creek-Yellow Mule* final enriron-
nmatal etetaamut." Ills rememendstlon haa been added elnce the earlier
technical review draft of the recovery plan, and suggests a user "revelation"
resulting a change la sal l gen set direction for this area. In reality, the
amah C reek-Tell cw aulas final II la ever three years old. While a taring
that potential habitat sedate la the headwater* of aema drainage*, the U
admit* that the frequency of grltely ana la unknown, and between 1973 and
1977 all gr 1**11** wan reportedly eeaa la or aaar luck Creak, though none
ef the *lghti*g* were confirmed. We qua* tine the rational* for re-eval-
o»tl*g the etatne ef thle Lara* area ef intermingled ownership baaed on the
VUr* eat* preeanted In the hack Creak-T.llow Hula* final is.

m

Mr. Jamaa C. Grltaaa
aoveaber 18, 1980
Pag* two

2) The HCDCST, population racorery levale call for at laaat 101 of the
total population to b* compoaad of faaalaa with cube of the year. However,
th* Tallow* ton* racovary levale epeclfy a alx-yaar *v*r*g* of only 5.4X

ef the total population eonalotlag of fenalee with cub* (14.889 feaal**
with cube In e population of 27J. animal*) . What la the biological Juatl-
t Icatlon for thla lower lever In the Tellowetone *co*yatant

i) Although population etatietlee are preeented aa goala for recovery,
the haalc quaatlon la how aaay nor* grlsslla* are required for recovery in
nnch population? Thla point waa not adequately discussed, and should
lncloda eon* ••timet** to avaluat* the feaelblllty of thl* plan.

4) tainted to th* pr*vlou* point, th* aire* of occupied territory In
the Tellowaton* *co*y*tea (8,496 square all**) and th* NCDGII (8,501 square
all**) are nearly th* eeaa yat w* **a quit* different recovery level* in
tare* of daneltl** or perhaps total nuab«r of hear* in each population,
leeevery daneltl** appear to be cheat on* bear pat 28 square ails* In
Tallowatona compered to one bear par 13 aqnare all** la th* SCDCBE. Pre-
sumably, the reaaon for thla difference la becauee habitat In the Tallow-
eteaa ecooyetaa 1* net a* productive for grlaallee a* the ICDOal. If thla
la the can*, than why wouldn't the racovary dannltlaa uaed for Tellowetone
be mora than adequate for the ICMgl whar* habitat potential la reportedly
of higher quality! There name to be confuelon on what population goal 1*
necaeeary for racovary and what total number would be deelreble to fully
ntlllae habitat potential. The latter figure eppnare to bo much higher
than required for population racorery In th* ICDOal.

3) legardlag the leaue of continued aport hunting In the ICTJCBI popu-
lation (W2111221, page 13), a anjor cancan la to radnce mortality of feaal a a
It appaare that consideration for a reduced lavel of bunting on all boar* la
Implied but •hould be *apllcltly atnted.

One alternative Hated propose* reducing female nortallty by prohibiting
th* (booting of bear* In group* of two or more. Thla alternative would b*
difficult to enforce end perhaps Ineffective. It le doubtful that * buntar
would verify that * gristly la alone before bn eboote, especially In dan**
vegetation where other baara could aaelly ha undetected. The eetlnete that
only 33Z of th* adult faaalaa would be vulnerable under thle alternative
a bawl d be cl* rifled. Praewmably thle refere to the faaalaa that would be
tree tint earlier thee year mad eeua vavld h* without cab* er yearling* ae
the fell hunting sseaoa app reached.

flaeee keep u* Informed on the etatne of thla recovery plan. We would Ilka
to receive eay additional draft* which Bay be generated *a wall a* a copy
of the final plan.

Slacjrely, /

Urla L. Rick*
Vtldllf* lloleglat

-184-

LLI/a

ftrveaber 14, 1980

Rovaabu U. 1980

Mr. Don Minnie h —

Regional Director

0.5. rub » midlife Service

USUI • ten 23*86

tant Federal Center

Denver, CO 80223

Ui M--C1-- Smx Crlssly
Recovery PUn

Dmt Mr. Munich!

Ve arc replying to your request for coaments on the
Gristly ieer Recovery flan.

Tha National Wool Growers Association la highly critical
of tha antlra plan, tfa feel far too ouch aaphaala la given to
tha welfare of tha grlaaly over tha lapacta of human and
llveetoek welfare. Tha loaa of one human life ia not worth
the antlra gristly population!

Tha "broadbrueh" approach In designating critical habitat
for tha grlaaly baa extended tha boundaries of all tha six
proposals far Into araaa where human and llvaatock confllcta are
Inevitable.

Va faal that "occupied habitat" ahould not. be conaldered
at "critical habitat" for the aurvlval of tha gristly population.
If one ware to adopt such a philosophy, aa a gristly population
lnereaae and naturally extended lta species Into adjoining
ereae, where doea tha concept of critical habitat atop and reallem
begin. Grlaaly beare are not compatible to praeent day livestock
ami human activities now existing on former alleged grlaaly
habitat. One moat recognise that If a grlaaly population Is to
remain It must certainly be only small Isolated populations In
remote araaa where human and livestock conflicts srs minimal or
nonexistent .

Certainly, tha concept of "Corridors" between grlaaly eco-
awataaa^la(|oa|lately ridiculous, absurd, and unacceptable to any

RECEIVED

W.18'80

NATIONAL WtkJL GROWERS ASSOCIr^QOJ^d^C.

900 Cranoell Building / Salt Lake City, Utah 84101 / (SO , I 3b5m83

The National Wool Orowera Association la especially critical
of eta r amenta throughout tha plan such ss: "Identify end reduce
or eliminate activities which Indirectly limit grlaaly populatlona"
* • • • "ravel oo and apply systematic management guidelines on
federal lands to make timber and grating operetlons compatible
with grlaaly boar apaclal and aeeaonal habitat requirements". . . ,
"Restrict development In occupied rangea of grlsslles via county
aoning, etate regulations, and withholding permits on federal
and state lands". . . We cannot support any of the above concepts.

The National Wool Orowera Association is especially concerned
over tha Inclusion of established livestock grsslng areas, both
cattle and sheep ranges, Into critical habitat for grlasliaa.
This Is totally unacceptable and will not be supported or tolerated
by tha livestock Industry.

The whole concept of attaantlng to manipulate a remnant or
reintroduced apaclaa now classified aa "Endangered" back into tha
former habitat of the species Is ludicrous. The ecosystem that
ones supported these speclea does not exist In tha present land
use patterns of our country. To attempt tha recovery of tha
buffalo back Into lta original range would no doubt be recognised
aa unrealistic. Tha attempt to reintroduce such apeclea aa the
Qrlaaly soar and Hot tiers fcattby Mountain Wolf into lta formsr
range la ltkavlae aboard. Tha ecological niche for theae speclea
dona not exist and recognition of this evolutionary process in
our environment must be acknowledged and accepted.

We appreciate tha opportunity to comment on the Draft Grlaaly
■ear Recovery Plan and would be willing to discuss the issue
further ahould you daalra.

Sincerely,

9om T. Bella, Chairman

Animal Damage Control Committee

HsTIOML VOOL OXOVBKS ASSOCIATION

JTH/fe

(MM <)M .l(X>S
U aereaber 1M0

*.rJuale S^i!fR*Rs
Tcxjam in

..cobgy

i A I I i ,1 Dl
(III H/\l All I s

Sea L. Iron, leases

•rlastr beer xeeeverj Plaa

liasiss lapsrtasB*. or nsk, wildlife * Parka

MM Bast Mb

■alee*, ar SMOl

■ear Sr. Ireva,

I teeeatly has Mis opportunity to rood port of the prellsdnery versles
of the omtDT mM racwaH PUI. To plan la sash detail for so mrj
papa last one aaler auoh diverse sendltlcas sleerly snot her* takes o great
tool of tlmt, thought, ami effort. It Is traefcr laprasslTa, sad aa a felloe
Ho legist l«a( dosuted to pro earring the gristly, I saints you.

although I leak yow breadth of astereteadlBg of tho proa leas la gristly
sesagsaset, tkare ore tas sreaa where Z aey Va able to off or added inslgati 1)
lapasts of Vartlng ami afreets of altered agt-sax olass rotloo oa pepaletlea
eyeaadet, oad I) bear-hwau ecaflleta. Bo I hare orltl«aod the rooueory
plaa ap through ths seetlea sa ska Talleestsas Bristly tear Booey stoat the
•exaeata oad suggested rwrirloae are inslosed. Plsaes take thaw aa they
are lataased, aa aa aid la rerlaUa year plaa, aet as a sign of dlsrsspsst
for tho fiao Job yea here already Sans. It Is aafortanebe that yea hare est
ease aaa of ar findings free the start. I teat seplee of are papers

•spy

■felielaery draft li easlaeed, oad I arlll seed yea a rarlaed Torsion as sooa
" pooaltla. If I sea as of aaw farther esrrloo la helping yaa on fee
Biisesrj Plea, ploooe 1st as kaewi sad pleeoe do kasp aa taf oread of progress.

Uoltoirtljt, there le a oospore tiro pragrea astasia tha nam and the
laetltate of xeelegy for airing Be* logic*) latent, Tm pays the salary, so
•*» as I kaaw, sad the Xweera verks with aa oalrtlaa project. I have applied
for aa latjeraahlp, so if yea sseld arraaga with npta to pat no to aaa,
plsass asks was re(aest far w eerritea to ths addroas Wloe, as soee ss possible.

attention, lolaad W. Dehor, Pre Joe t xeaega?
The laetltate of Be* logy
■aleeBk he search lulldlag, Sat lor adrorslty
TaHesaaalla. baUaaa taaos

•aepaea V. ttrlBghaa '

vBIZZLY KM IBCOVttY PLAN
Ctltlaus

nrfawxTTloa
*o' ' MttttU^

p. 2, psrsgrspt 3t Suggastad ravloloaai

To asaiaas taatStls popalstlaa has "recovered" saaaa to eo unwarranted,
^^esaslderlag tts ovldooco — ar aaca procleslp, the lack of ooldance —
prs seated by loop ot the ASS Beetles. In Modlssa this past Ptbrusry.

During tha oaaer of 1966 I spsnt 6 vssks roaeuig tho bsckeountry of
Vallevotena looking far grlasllas la areas atleh prior to duap doouro
they typically froausated. Tbls laeludss arsss suck so Mt. Ho brae,
Ear free ths duap sites. Tst I nsltber saw a slngls boor nor found
frssh sign. So oil population ostlaatat aside, 1 m tkaptlcal that
as really kaev yet what le happening wit fe test pepulotlon. Convsrsstlons
vlth Dick Kalgkt lsavs ae with the fooling that ba tea It vary roluetant
to put euch faith In currant taforeatlon. Its Just oes hock of a Job
to aealtar thsso a>laels In that kind of habitat , now that they no loner
f request duept, Ss 1 would hops thst la the rstsvsry plan, this
uncertainty sheuld be steted ssplleltly, sad ne uBvsrrsatad aasunptlens
sg "ra co wo rod" ststus ba eede, iff, oa ths stker hand, you have accaas
to facts which I lack, which provide thst warranty , plssss cits whsro
they have baafbbtalnad.

•. Ooals I Oblsctl-ssi

Is It understood, for both legal sad biological purpoaee , that thsao
prlaery sbjoctlvas require ths eubsldlsry ebjsetlvss of tdsntlfylng
how the oodaago rod/thee at seat populations differ free case that are
able to sustain thsasslvss a won under highly adverse condtloaa? If
aet, shouldn't this be steted?

-185-

WCiA*, OtaaltATf * aTjUTIOri Sugrtatad revisions t tMMntl
A. raklei all laforaetUa net directly tilaM to bear.buaa leterectleim
wttb UK m beam r*|U| laart tt ukera yeu u» ban nom fcapns"
uaner tka m» title "KCUL MCuVJlUTlOn MB IBUfia"

VwiIh lk« obMrvttUm (m kktea

«< liltMla fraa otkir kutmi. tuck aa Peareon (197S), ftringha(l*ao)

Tea lihnMla a p. J» about fannies being territorial end accomodating
daughter* applies to bleak bears Lynn logar'e study era 1* Mlnneeeots;
but M Imi not eew to apply to blaak Mar* In *oa otbar araaa, such
aa tba Saoky kaueteln*. Iter do I baa of ay evidence that (t eppllee
to grlaely/Brewa baara la ay habitat i II yan have access to any data
daumatUg web raletloMhtM, plaaM rtta tba a.

c.

tnoaat alt latoratla oa boar-haaa Interactions U a aparate section,
taciadlag. tha (afore at ice presented bar* aad tbat on aortal lty . You
algkt went tkua to include lnfaratlon cat only oa direct eonf llete
tbat ceuee lata to paapli or property , but aaatkattc and otbar kind*
a( Utaraetlaa.

1. Include aa* af tka findings by aarrar* oa frequency ad causation
of attacks, based oa kla aurveye at tbj literature. Pred Daaa and
strlnaoan kava batb vrlttan nape r a oa tbla for tba U.S. Park Sarvlea
la Alaaka, baaad aa ebMrvetlao at Kataal Kctlaal Hoauaaat.
Tba finding* af Stenerev k ttakaa (1*72) art of courao particularly

1. Include aoaa of tka infer net ion fraa tka atodtaa ou attache by
black baara by Jaaa Tata aad ariao* la tinge, raapaettvaly la tba
Oreet taaaaTy Mauntata* aad foMaltt Rational Park*. Batb ara
curraatly atudanta of Mlka Palton at tap Unlvarilty at Taantaaaa.
D. St it om at a oa Individual distance ara aarlouoly la naad at revision.

HI. CrAwtfaTT DIimgUTlOk t SUTM

a. aa 1 recall fraa taep'a Bra Mutation at tba klndlaaa baar watlnga,
tkla part rabruarr, tkara ara aatlactas at Ul Yellevrtonr. population
far lever tkaa that.

»m * iu muiTuti

A, Wh«t li tha aourca of tba quota on p. 23 at tba btglnnlng of this faction?
Of what possible valua la It to average structures of populations living
In such dlvarae conditions without at laeat providing standard deviations ;
a table of values would be ova* batter, such as that given by itrlnghaa
(19»0iJ5»). a* la that paper, teeta of significance should be applied
whan ceaaarlng hunted Vs. unbunted populations,

i. »ji MttB

1. Data on captive gristly/brown beers reveel a highly significant
(P< .00)) predoalnanca of aalet at birth (Strlnghaa, in prate)

2 Thla Is substantleted by field dote froa Yellowstone (Crelgbeed st
lei*

al 1974); altho the Craighead detections Is too eaell In oMple
slia for significance to be attained, the trend le clear up through
agaa 34* yeort old. Indeed, significance le attained whan all
eubadulte ara conatdarod (McCullougb In press; StrtnghM In prees) .

C. Iiatal Ity

Strlnghaa (I960, In press) daala attentively with tectore controlling
aetellty rate. TBom fladlnga should aot be Ignored, particularly etnca
thay relate natality to hunting pressure , and could thus be crucial for
dote raining tolerable levels of harvest. Mote that the se enelyaet
produce tubttantUlly different reoulto then that of HcCullough (In press).

1. In what papuletlMS denonly 20 to SOX of cube survive to breeding
agar Under whet conditions?

2. taring*** (1960) preilaap a MS at of ct»p*rleg rcprodoct tee potentials
bataaaajapepulaalM-s (rstewtlel natality ladtaj

9»\ f. 2» yet atata ajjt "pbvleuely , ... aaalanta protest la far
faajli i la aaaaatlal to op m vary" , la addltloa t* shorten l»g tka
sentence aa Indicated by tba "l..",»ou eight wish to cite tba
following observation* by Strlnghaa (I960, la prate) 1 Neither
coaparlaan aaong 6 populations, nor that aaapg 12 years Oar
tba Yellewotono papulation, revealed a relationship between
abundance of edult tMelet veraua their reproductive performance
— although auch a reletloashtp alght be teuad under ether
conditions or If the fecal varleblea had bean laaa unlfara. Indeed,
tor white-toiled dear (HcCullough 1979), reproductive parforaance
It Invaruly related to ebundanca of adult taaalaa. So reproductive
rata far that species la neither aaalalMd nor optoalaed by providing
aaajBua pratactloa for adult taaalaa. That la cenilateat with
find tags by Submit (1971), Ottat (1*71> , Strlnghaa1 » ftibanlk (1973)
on other ungulate! .

NaaUCaBSaB HPWAUTf

1. » tt, lla* I, aerd *, and laaa l>\ »»rd SI 6vbtrtlt .t*"8eg**det!ee'' and
•degtaaihg" naphetlvaly *" Vtilai" and "eroding".

2. ». paragraph 2i Sugaaeted revlaloai

CaavarMly. In laactuarlae waera baara *M. MtLkypiaa llporsrgaptMd by
paaple. ot»»r autre* Mad to be taken to assure that tba bears retain
tbalr reepect towards humane. Whet ha r a baar la aa frightens a Br
aonjlsees ti) by baaana that It attack* than "unprovoked", or eo locking
respect tbat It coats* dangerously cloaa while Moklng food (cap food,
Meee-tMd pollsts, garbage, ate.), both humane and bears can be
SHeBgatrcc (set Jookel » Servheea 1*77) Strlnghaa 19S0)'f *oth"bad"
end "good" habits can be tranatttad froa aether ta cubs, and perhape
aaaag stetr associates (e.g., anting pair*), aad over a period of
year s baaaa'larroaatafly eoaatoB la a papulatlaa. So It la lapalratlve
that we aaaag* p*tpH>baar Interactions la war* <*ioh *Heit autal
respect vltheut undue feer or ataaalty.

Ketlenal perks prrrlaa sett lags where baarlbaaaencpi hi baas kiiaaa
oaatearaa tinaltai Ivaa taaaa. aoa oaVl>-t^ tka auaaap af alilbott
U aai Saate taaeiaaaalj, bat lavaelM at backceuntry bear habitat.
PartleaUrly aha the hikers art time or In part*** of two or tbr**
paran*. tba nuabar of oeaf rontetlone with baara can be eapacted to
Inert see proportionately. How thle pattern can be reverMd la at
pretext not 'leer. Sea biologists advocate a retraining progra
for problea bears to Instill e respect for aa ad an aversion to bin
food aad etar property! but to data tare hae bean little roMerch
la tkla direction, (e.g.. mo Strlafka 19*0)'
S. Tka following paragraph U good la gaattrali but tt* ending elao could
uaa revisUn. shitting eaa«a*l* tra bears flaring people, to reepactlng
tka. This dlff*r*no* ca be critical for bear-huna co-eelatence
t* be sur* . under eaa clrouMtanoe* , fear daaa auaent respect* but
under otbar eeadltlona. It proartea aggrttttoa by tba baar. So tba
teat isabsaoas night be revUed ee fallewei

Ftoplt wka Impair tka reepect af baa* far aa, tar lMtaea by providing
unnatural toad sources — elteet acoideetly, foolishly, or latantlonally —
akara In tba responsibility far ay future ate of daege or violence
ceaaUated by grin lies.

opposed to feer
Mm aw* d*fMdlaa

WjaaiaM.

k "aaepaat" eight be ceaaldarad \ka feer to '.r snsgresrf at
af being treaagreeaad una. Ca*ldar nan of tea It baa
tkalr yeaag fra aaaareat danger wbUk baa tad ta bvaa

Tt. Itimt COkDlTlON

*• focd i auggeeted revisions of paragraph 1.

Tka brad bletorlc distribution of gristly beers euggeete adaptive
fleaablllty that l* reflected in the food habitats of tha different
populations. Saara are oanlvoroua, aad capable of adjusting to a
■Ida diversity of food*. Morphologic*! adaptation* Include crushing
alert ad the grseteet lata *< Ut*ekln*l length relative to body
length of ay carnivore (He*l*y 1973). althengh gtttaliaet la >M
araaa ara alaa*t tntlraly he rblvoro-js , MatMattM; - ittoaaab nar
tba Lee cue ca boat tka raalnellne alerobaa tbat would be aceeaary
fa dlaatloa of callulaa. Coaaaojuaatly, baara fttd prlaarlly on
uiaal or vegetable aetter ..."

Oalt last tentence In paragraph 4 at page 33, which now reade "Or Its 1 its
ara oaalvereue feeds n capable at adjusting ta a wide dlvesslty of food
esurces". elan It be coats cadaadat If tba above re-talent are aada.

m. rajBuio

4. p.*0, paragraph 3i auggaatad nvtalaai

Tba unavailability of toad, daap enow, aad la ablant air taaaaraturee

appear to aha wlatar sleep eeeeatlal ta baara* aurvlval (...).

Whan radante ad baa htberaete, they bteaa pal.lUltJ/ polkllotheralc .

leak (1*60) described that type at htbarnatlw ae follower "... ■

periodic pfcenoMnon In wbleh body taaparature telle to a low level

a pa re timet Ing ablest i heart rtta, atafcolle rate, aad physiologic

function s tall ta a correepeodlng alalaua level". By coot rest, beers

sre heaaa-kypotbaralc klfcaraatoro wka** body teaparetur* drapa

aa aera tba '**C be lev normal, aad la aatatalaad thai* laaaflaltaty-.

T>1* Is acccapanUd bf a radyetla la Iratawef laMplrataaa aaahkaatt

baa. (Crpta**aad *> OtaifajMli l*St(vfalki«t.«l. !*?«),

Day length ad Inclement we etna r .... (terser 1963, In He Arthur 1*79).

with Mtmal fat roMrvee, baar* a* capable af fatlag fat < Bath*

mlak only slight reduction* In body wttgbt.

nu. MgSBUSM EStSS SBSS

a. p. *»i I tame 1U and lUi auggattcd revisions

151. laanttty tatera dlfaatly tapalrtag reproduction ar survival,
•186- 1U ladlraatly ..

7

6

fill. •. P. *». M k 33.

Ill Identity end reduce MMI 4«<ltml o( reproduction k eurvlvel.
23i .. ladlrect

ii. M9Qfp» *V»

A, mtowwoi* auau ■» (coaryrt".

I. Although the etetletlce ueed, froa Crelgbead .t .1.(1974) and
Anight «t (1. (int) aey be adequate for »be pwrpeeee of tbla
recovery plea, •* *»••* u oaa Junction with the population aodel
derived by (better (1<7B), I this* the plee would ba nueh rounder
If It eocoapecoed tka flndlrejn by Strlagfcae (1«70, 14(0)' concerning
kow rataa af repreduotloe and eurvlvel very aa functlone af adult
ealo ernradanee. If tha* la Indeed a a a jar controlling variable,
IpitUi it would ba very rlaky — uajeatlf lably aa. TMe la
particularly relevoat with ralatUn to hunting Ineeete. for
laetaaae aa dlacueeed wader point till aa page 54, and III] oa
page 39 (a, I., Sou Id huatlog (ecUltete recovery! If aa, ahould
vary eeleetlve hunting ba pa raited botcto recovery la eehlaved?)

1, Mortality af feaela grlealy baarai rte»t.I3Ui (aa ay ceaaeenta
an t. ». <*•• I*-C-».

J. p.«l, Itaa 121*1 1 91a oa wa da >at hove a copy of tha "Ouldellnee",
wa aauot critique tkalr edequecy at epplleeblllty, hence, tha
eVldellnei' akeuld ba reviewed by MA aaabara bafera aVi appro m 1
la (1*** t0 th* hacovery Plan.

». P. <1. Itaa 41331, llaa )i Did you plaa ta have a calaa "i" aftar
tka ward "approval"?

I. p. dl, Itaa 43331, llaa •, ward *i oueotltute " grlealy" la place of
-tkalr".

d. p. «3, Itaa 43361 I PerMeoleroyvatl. written.

7. P. *i, Itaa ta, llaa 1, ward Ii aufcetltute "varaua">l* place of "aad".

d. p. aa. Itaa fill, Tka "eaaekeark" rtetletloal paraaatata 1 la tad

(a nil ara by aa aaaaa odeauate to aaaltar oaodltlaa of tho population,
tltaeugs tkay ara oartalaly critical far a vlaw of eurraat atatui.
Ta axMrataad tha iigalflcanca of current atatua la terae at paat
aad future, and predict cc anger, oaa naada interaction oa a variety
of ether paraaatata too , Including leoeo Uatad balowi

i, A. d, a. Indlcoo of Keproductlcoi and Bocrultaont

1) Abundance k propartloa of adult ffeaeloo with va. without
llttara of eubo va. yeerllhge va. tve-yoer-olde, otc.

3) Llttar ataaa (praaatally aad at varlaaa ogee poatnatally)

1) latorvala batwaaa blrtka af aucooaalva llttar. aad cub aga
at weening.

4) Ago of aatkara ralot.d ta llttar tlaa, aurvlval of cub.,
aaa ratio of oxiba, Uur.llttar latarvala, ate.

3) Agaa at pubarty aad flrat raproductloa (o.g., fir rt llttar for a 5).

d) Llttar alee, cub aurvlval, ate, relettva to parity of aotbar.

7) Abundaaca, durlag eeeb yoax , In each population, of cube va .
yaarllnga, va, 3-yrar-olds va. older laaaturee va, adult a .

e) laeruttaaat of aaok yaaa-eUaa eahart ta aaaaatf Ive.agee
froa coneaptloa through adulthood

•> MartalltUa, t alfvttdoAgr adapt loaa .

b. Pooalble Coetta HIm Tar labia i to be Monitored

1) Abundaaca af adult eel a a and adult feaalaa

3) Tetel alea/deaatty af the population

1) Aga- oat cleat etruoture ef tka papulation (Including
prenatal aad porta at. i aaa retire)

A) lad loo a at per eeplta nutritional mode, ee tola varlee

with afe.aoe, reproductive atetue, etc, to that rHe relet lorteMpe
ef "dear Ity" to "carrying capacity" relative to varleue
raaourcea eaa' ba eeefclete* aboa preclaely end reliably.

3) Indlcaa of nutrltlenel atatua, laoludlag but not Halted toi

a) body dtea A weight

b) ekull alaa

c) tet (apatite (a.g.i erouad kldneye k ebdoalnal eeeenterlee,
ead rebcut aaaouoly )

d) .pacific gravity ef hide-free earcaaaee or of apeclftc organe
a) feaur narrow

f) blood oeaponeata (free tatty aclda, ketone bodlee, etc.)
d) Indlcaa of f aad ahead anew .eat ouatdty and avellablllty
7> Indlcaa of aoelal atrlt*

a) frequency and tntaaalty ot cere bet: protease of wounda k eeart
(related ta reason and teetoeterorte levela, eacag other tactera)

b) frequency at eaa-ceabative eggreaelve eaeovatare

c) terrltarlallty, eoelualve boaa reagea (apatlelly or teaporally),
or privileged aooaee to Halted raaourcea (e.g., by adult
aalee ta garbage or ftek)

7) Indlcaa ot dlapereloa (e.g., do they crowd to feed at duape ?)

() Indlcaa of patkegea Infeetatloa (e.g., ectopereottee)

»> Indlcaa of legal aad Illegal killing by kuaaae ear) of Indirect
huaen (actor a wklak lawar vtaMllty at Udlvldual baera or
pone'ettaae (e.g.. pallutlaa er dleturkeaea)

1*. A. 9. p.71, ltea fdlll. kovlelena ot tbla peregraph aVuld be aede In

accordance with ay coaaamta on p. A, Purtheraora, tbo goela of the
progrea ahould not be ee tightly focueod on avoiding "aecond eacountore"
while no wore then two aey be deeaad "tolereble" If they oauoe human
Injury, we auet reoogalae that aore then two "training aeeeloae" aey
be aacoeeery to appropriately aodlfy e Doer', behavior. Thle la not
tha tlaa to outline e plea far relating training to eeverlty of
encounter a, ate. Out 1 would ba glad ta partlolpeto In dovlelng
evek a plea.

10. p.71, ltea 461l3i 1 under. tend way you epeclfy "ualng nulaence
beare for ttrenaplantetloe. ahould be dlacouraged unloee
rehabilitation tralalag la proven to he uaeucceeeful ." However,
who weata a probloa bear In ble"back yerd"? So I auggeet that tbla
be rapkraaad to Indicate tket tr aaa plant lag la eacouaagaeVel lowed
aaly where tea beer la ualUely to cauee rutkar probleae, either
by virtue ta rehehllltetton or pographlc laalatlon, etc. It la
gulta likely tket e degree of ret redoing can he achieved which
will bo adequate for traaeplaatet loa to araae like tea Mttarroot-
eelway Wllderaeaa ovea whoa net adequate tor relocation within
Tollowatone or Olaoler,

p.71, Itaa 71, Daaa "eeatrol
kttot thU net ha better root

Include aaly daath or trenaplantatlaa?
ad eaeatklag ILkei
Ceaeeralag all grlaaly he ara that hove a doeaaaeted hlatary of
aeleance ectlvltlea , aad which eaaaet be edeqoetely rehebllltetad/
ratralaod to alatalee tkeae aetlvttlea ta with la aa aaeaptakla
level i Coatrol or r aaaaa tea a oa all lead a . oltkla reeareaeaded
aartallty levela (...).*

p.71, Itaa Td3t aaat ta aa eaaaplo af aa "uaeeoal dieter ken ee"i
what would e -ueuel dloteTbeaoo" be?

p. 71, Itaa Y«li (evade (aad.

Id

P.7A, ltea* b k ci Coaalderlng hew heavily the Yelloweteoo grleely
population nay have depended on garbage aa feed. It la queatloneble
whether tka acoeyetea oaa aaw aappart aa klgk a doaetty or yeild
eueh high rataa a* repre duet lea , If nutrient aeeda par eeplte ere
no lawar thai they vara free Kse.ua? Canvaraely, now tket the
dwaaa hove boon oleaed aad tha heera dljperaed , aoc lal etrlfo
Induced pkyalelogleal ttroea aey kava dlalalaaad oaeugt. to lover
autrltleaal aeode aaaagk or ta etkerwloe lawar phyelalogleal etraee
eaeegh froa traee fee tore ta oaaataraet day Ire reoeed autrltleaal
at reaa/de f lei t . (eaa atrleakaa IMO)

p. 7A, Itaa di Aa yev any bava already acaaloerad, a "atabla"
pepulatlaa aay not ha alt her poealble ar eoalrahla , a von en a
elavyear aearafi. (a aaalyaid at tka Craighead (1974) date
(ttrtajtuai la areaa) revaalt a leVyaar eye la U rapradoatloe
aa etaklllty, u aeeUakU, atght km ta be everoged ee a 13. veer
heala. fortunately, year ewyeor let or eel eaUoldee nlealy.

, p. 73, Itaa 3»i Ck-eateX, "all etker fan tare being oovAl tka
population with tka lower '■• valoo la laaa raallleat to perturbatleaa
Aa for eeaae whore evrvlvel rata varlee aa a f unci lea at t,.la tket
alao true? he-eaalyele ot the Cralgkeod lim) dote aad aa«aar lean
between peewlatteae (Strlagkra 1X0, u preee) tadUata that
res rat tat at le, paalalvaly a or at le tad with roproduetlve robe.

-187-

School of Forestry

University oi HlentarM
iTIlesewla, mutant imu

April 15, 1981

Mr. Don Brown, Lender

Crlnly Bear Recovery Plm

Hont Dept. of Pish, Wildlife, end Parka

Helen., MT 59601

Dear Don:

In ganaral, I thought that you did a great Job In preparing the agency
draft of the CrliEly Bear Recovery Plan. I've Itemized small errors for
you In the past, and xerox coplaa of several pages which you may have
already corrected are attached.

My final comments are In fact worda of caution for all reading or
Implementing the Plan. Ua have not reached even the minimum threshold
in data compilation for grtzzliea — our sample sites are far too small
to make population eatlmatea, our data on reproduction Is far too
Influenced by artlf lcally-inf luanced population segments. Any long-term
or final decisions are premature. In particular, I wish to comment on
the fol lowing:

1. Hale bears are far more vulnerable to mortality of many types
throughout their lives (from the time they leave their mothers
until death). This means that the real sex ratio of any population
(even the unhunted North Slope population at 27:50) is predominant
to females All of our data (hunting, trapping) are biased and
Indicate more males in the population because the male* that

are present travel more and are thereby more vulnerable. None of
the current population calculations account adequately for this
anomal ly .

2. Until a proper aerial survey of numbera la done with at least a
25 percent coverage of spring range, we are only making wild
gucaaee at population numbers. Grown people should know better —
the agencies should quit playing grizzly games and fund the
necessary research.

3. The ability of brown bears to survive and reproduce when below
currently-accepted population levels for the grizzly Indicate
strongly that bears have an unknown ability to cope with the
problem of low numbers In terms of reproduction and population
maintenance (it is probably behavlorally based).

4. People tend to over-react to numbers, and therein lies a real
danger for bears, because they always occur In relatively low

densities, and In snail total populations. As the dominant
carnivore, that simply la the way their reproduction/survival
rates have evolved. People more familiar with other species
suffer a real problem In grasping this principle. Conversely,
bears live for many years, and s non-reproducing population can
axlst in an area long after that population is "reproductlvely
dead."

5. The habitat "Is the species;" a killed animal will be replaced, but
a dead habitat cannot support any grizzly bears. The over-attention
to grlztly population numbers not only is invalid because our data
base is inadequate, but it also allows land management agencies to
Ignore grizzly habitat needs. Since habitat occupied or frequented
by too many people either leads to Che death of the resident
grizzlies, or encourages habituation to people, gristly habitat
needs are becoming an extremely critical issue (e.g., the Cabinet
Mountains, etc. ) .

6. Overall, grizzly management should center on wild, back country
grizzlies which fear and flee from people and their activities —
only extensive areas of Inaccessible habitat can allow management
for this type of bear over the habituated, secretive bears that
live near to people. Hunting Is an essential element in keeping
bears wary, but It must be carefully established and managed

under the quota system. Road management is of paramount Importance)

7. Sear condition and the productivity of certain, key bear foods
should be monitored annually in order to predict the bear/people
and bear/livestock conflict potential.

8. Regional cumulative impacts on grizzlies and grizzly habitats
must be measured and documented beginning immediately. Until
Impacts are documented, quantified, and projected, the application
of gristly biological data is Impossible. Land managers Bust
initiate such studies now; all ownerships must be studied/
evaluated. Mitigation for Impacts must be borne by the dominant,
fcderul land management agency re^a rdless of where or'whose
ownership the impact occurs. Land- owner , county, state, Indian,
and federal co-operation Is imperative, or the efforts of one
agency are negated by the neglect of the other.

9- Management directives under the Plan must be kept open-ended to
allow annual adjustments as new data are obtained. A federal/
state/Indlan/county monitoring committee should meet annually
to consider and implement new data.

10. Research to obtain adequate population, reproduction, habitat use,
biological, etc., data for several geographically distinct areas,
and each distinct ecosystem Is necessity. Present extrapolations
of data arc dangerous to grltxly survlvnl, and are upon to ptihltt-
crltlclsm. Budgets listed are too low.

Equal Opportunity In Education and Employment

11. The population goals as re-drafted are still very tentative;
their only real value lies in the fact that they cannot be
achieved with the present research/management effort, and
therefore the grizzly will remain listed as threatened. This
topic deserves s major research focus In terms of sample sites,
better sampling methods, etc. The budgets listed are inadequate.

12. An "umbrella" research approach aa offered by BCP, and which
provides long-term continuity In the studies, s sharing of funds
and equipment, etc., should be encouraged over one-shot, short-
term studies.

t could list fsr more detailed comments and research needs, but until
agencies indicate a real willingness to invest In gristly recovery, the
points srs moot. Personally, I have had to spend so much time trying to
obtain research funding the past 6 months, that I have had little time for
data analysis, report preparation, and field planning. This Is a really
poor way to carry out research oecessary to gristly racovery. When I see
vast amounts of money being spent at the same time on needless travel,
unneeded bridges, harmful roads, and a multitude of administrative mire
by the funding agencies, I really question whether there Is an Intent
for gristly recovery.

Respectfully,

Chat. Jonkel, Director
BCP

Chairman, Border Crlttly
Technical Committee

-188-

APPENDIX C

Response to comments received on Agency Review
Draft of the Grizzly Bear Recovery Plan.

-189-

U.S. Purest Service

t. Comnt« noted snd clarification Mdi In final plan. Refinement of
population obleetlve* can only follow a determination of what constitutes a
vinh]», s* if-eustslnlng population In each ecosystem.

A clear definition uf what would conetltute a recovered population In
tttrm* of total number* of bears for aach ecosystem waa a major topic of
diecusslon at each of tha workahopa. Agreement waa never reached. What
reeearchere did SRres upon waa Co uaa monitorable population parameter* to
Indicate population atetua.

"The parameter* may not be the beat, but they are what researchers could
aRree to. This agreement on and the uta of population parameters >s recovery
goala la the major contribution of this plan. They provide the first.
If crude, baala for population goals that have ever bean formalized for
gristly bears. Reaearch is now focussd on these parameters; It is a
place of beginning snd one from which to Improve parameters and goals.
Researchers are aakiid Co develop a system CO monitor parameters for the
simple reason that they ars docuasnctbls, total numbers srs not (Meeley,

pan. cov. 1901)".

From the YORE data, we Identified population parameters for s population
that waa at able to Increasing during the 1939-67 period. Numbers of
bears In the ecosystem during that period are a reflection of the parameters.
Likewise, population parameters from the data collected over a ten year
period by Hartlnke In Glacier National Park were used to determine
populatlnn goala for the NCTJCBE simply bacauae they ere the beet available.
The reason for dividing tha Rscovary Plan Into different aectlons la to
recognise different population characterletlce for the dlffsrent grizzly bear
ecosystems.

"Rach grlr.zly hear ecoaystea has Its own unique net of population parameters
re F lot t Inn different habitat conditions. The whole principle of our
derivation of population goals was that such goala reflect the documentable
characteristics of the population In that area. Ho ecologlat should
asaart that a population with YCBE parameters would constitute recovery
In the NCDOBB simply bacauae there la no factual relationship between
NCDCBE habitat and the YCBB population paraneters (Mealey pers. comm.
1981)".

DlscuHsions st various workshops led to sn agreement that at least three
populations were necessary to assure survival of the species In the
contcralnouH 48 states. Although there are no reliable population data
for the Cahlnet-Yaak Crlzzly Bear Ecosystem, It was chosen by the group
to he the third srea needed for the species survival In addition to the YCBE
and the NCDciBK Without area epaclflc data, we decided to use a hypothesis
developed hy Sheffer (1976) concerning minimum viable populations (see CI
for explanation) to determine the preliminary goal.

The highest eat (mate of Shaffer's minimum viable population of 30 to 70
bears was chosen simply bscsuse s leaser or minimum number would assume the
very best of hsbltat conditions, minimization of man-csused perturbations,
and no man-causs mortality — a baar refuge. Under the circumstances , we
believe It Is justified.

2. Estimating population numbers baaed on land ownership Is taking liberty
with bear denslt las .t hat arc only estimated — not known. Assigning numbers
hy acrea or square miK» of ownership from theae estimates Ignores home
range size and aeasonsl use patterns; e.g. grizzlies on the Front, in any
numbers, msy not survive if private lands did not provide an early spring
food supply that Is not available at higher elevations on Forest Service
lands. Conversely, they cannot survive outsld' the Forest for the entire
season — both wessons 1 lisbltats are Important in their survival.

One ecosystem, with component parts on s variety of ownerships thst are
all necessary at least aeasonally to the survival of the bears, precludes
assigning any carrying capacltiea until more specific data are available;
e.g. In early spring most of ths bears slong the Front may be entirely
dependent on lowland riparian habitata, many of them are not on public lands.

3. Your preferred management direction for the Selkirk grizzly population la
based on an extrapolation of the density of bears used se a goal for the
Cabinet-Yank ecosystem. An extrapolation of densities from one ecosystem

to another should not be made without the benefit of first corductlng a
habitat evaluation to determine the similarities and dissimilar Hies .
The SelkirkB may have the potential to support s grester density of grizzly
hears than the Cabinets.

4. Public hearings at the time o( placing grlzzlv bears on the threatened
list Indicated a public concern to save the species and halt snv further
decline In their numbers development of a recovery plan Is s step In
that direction. Hopefully, your "necessary public input to comply with
NEPA" will be representat Ive of the entire nation. It Is our belief thst an
BIS Is not called for In this situation. The purpose of any recovery plan la
simply in provide guidance to cooperating agencies on actions they are already
sujndaied to carry out under the Endangered Spcclea Act (ESA) (i.e. conserve

threatened and endangered apecles). In this case, the policy/plan which
would be impacting or affecting the human environment is the ESA Itself.
The Crlzzly Rear Recovery Pl<\n does not require the Forest Service to do
anything, but nlnply preeenta them with what plan preparers believe in the
beat way to achieve coneervatlon of the speclea, as mandated by the PSA.
It la possible however, that In the future an BIS will be required on
implementation of npeclflc tasks outlined In the plan.

5. Mapping criteria waa most recent sightings of grizzly boars or indication
of their prcaence or use of the area. We believe they are less confusing
than the wide variety of interpretations used In designating "Eaaentlal
Habitat" by your agency. Questions at every workshop indicated ench Purest
Interpreted the "Criteria for Designating Bsaentlal Habitat" In a different
manner. Specifics were discussed at workahops but not resolved.

6- Noted and used.

7. Instructions In Recovery Guidelines sre specific. I am certain socio-
economic conelderatlona will be dealth with adequately in the Implementation
proceaa.

8. Little, If any, scientific data on avaralve conditioning of grlzrly bears
is available. Several bear blologlats believe the theory should be researched.

9 and 10. Corrected. 11. Noted and added.

12. Entire section waa rewritten. 13. Noted.

14. The "specific coneequencee of timber harvesting, positive and negative"
are Implied in the "Cuidellnoa". Hopefullv, the Forest Service, Region 1
will addreaa t hem In their planning process.

15. Unaware it exlated ~ time constraints precluded sn ln-depth review
uf all bear literature.

16. 2nd paragraph: Noted and checked.

Ird paragraph; Chonged par request, What is the etrat if icat ion
of the sxrluded flrea7 Do we add It back to occupied territory
if bears paea through tha area/

17. Qualification of the 1939-1969 population parameters was made. We
believe the Interagency Crlstly Bear Study Team, If adequate^ funded,
will determine population charac tertat lea that will describe the current
condition of tha population.

2nd Paragraph: See pages 1-1 t, Ylll, Y121, snd footnotes at end of chapter.

18. Correction made. Limiting mortality to six may expedite recovery, but
11 la the average documented mortality. You are assuming a man-caused
mortality of six Is necessary for recovery — can you support this assumption?

19. Corrected. 20. Deleted as recommended.

21. A species manager manages species, and the battle still rages on who
manages which npecles. The species sre Implied to be animal — specifically
bear** .

22. Noted and words added that Region 1 will address habitat management
for grizzly bears In their planning effort (See Y4).

23. A review la recommended as there is a difference of opinion among
beer blologista.

24. Iheee acreagea will be under conatant change aa data becomes available
to warrant a change.

25. Noted and corrected. Hopefully, any HS1 and MS 2 acreage designation
changes will reflect the needs of grizzly bears.

26. Noted and may do ho if time permits. 27. Added.

28. Comment noted snd modification made. We believe site specific data are
needed for decision making in most cases; If data are available disregard.

29,30,31,32, and 33. Changed.

34. Everyone has limited euthorlty on private lands. We believe the
Forest Service will be mora Successful than any other agency in making
recommendations to private landowner* within Forest Service boundaries
(good neighbor concept).

33. The Forest Service has been cooperating in the IGBST effort —
a continuation of thla effort la intended in Y511, Y521, and Y531, at
lavela recommended by the IGBST Steering Committee (both management and
research) .

36, Th« Plan Identifies what must bo dona — research will Indicate how

It can be done. e.fc. a wildfire, access road to s clcarcut, ond the clcsrcut may

all he negative value* to beara in 1983; tan yeara later they may have

some positive value*, to grizzly bears. The evaluation must indicate whether

grizzly bear habitat Is ahrinklng In quantity or quality, remaining

stable, or being enhanced.

37. If not expropriate, delete It — the general idea waa to have
Individuals and corporations that will benefit from the invasion uf
grizzly bear habitat fund the data gathering and monitoring needed to assess
the effect of their exploitation.

36. Deleted.

-190-

U.S. National Park Service

We certainly aftree with the two points you identified that the Plan
neede to stress and believe that both have been stressed repeatedly In
the final Plan.

Page 22: Noted and changed.

Page 23i King (1938) aaid It; not I.

Page 33: See Y61111. Several blologlata attending the workahopa believed
the theory la worth some reaaarch effort.

Pagu 34; Both aides of the laaue are theoretical argumenta. There Is
no herd data available on either aide.

('age Jll n. iieta presented for the 1939-67 period wua not n declining
population but Increasing at an eatlmated alx bears per year.

b. They are the only population paranetere available lor s
healthy recovered population in this ecosystem.

c. Total annual Mortality was 17-19X| nan-caused mortality
vsa 6-81 for that period. Knight's 5Z mortality (sum-caused) could be

10Z to 20Z, depending on which of hla eatlmated total population figurea are
uaed. Knight estlinsted 300-330 beara in January, 1979; 200-400 In November.
1980, and 200 plua In December, 1980. The ICBST la now refining these figures.

Page 32: Thero la no reason to assume that the man-caueed mortality of U
beara reported by Knight (probably lesa than 51 of population) is any leas
relleble than the 18.889 reported by Craighead et . el. (1974).

Page 33: See Y6U11.

Page 39t The term "nulaance bear" Is carefully defined in the "Yellowstone
Guidelines".

Page 79: Noted and changed. There la a range of 0.324 to 0.676.

U.S. Plah and Wildlife Service

1. Corrected.

2. The worda "recovered population" era uaed becauae a viable sulf-nuatalnlng
population may not be at a level that la conaldered aafe for de-llatlng.

I. e. a population of 30 beara may be a viable and eelf-euetalnlng population
(nn one knowe) but unacceptable from the atandpolnt of being recovered nnd
eligible for de-llitlng.

3. a. Corrected b. Hark L. Shaffer 1b correct.

4. n. Notvd and clarified,

b. Noted nnd delated reference to "non-biological aapecta".

3. Noted and changed.

6. Wa do not believe any work to clarify the taxonomy of grizzly beara
or brown beers will help recovery.

7. Convent noted. 8. Noted and changed.

9. a. See Current Distribution/Statue. Our discussion was limited hy
the lack of information available. The Plan recognlxea that all grizzlies,
wherever found, are protected. The Colorado grizzlies were not considered
neceaaary for the survivsl snd recovery of the epeciee.

b. Noted and changed.

10. No difference; just a nostalgic thought.

II. Noted and changed (aae N-9 - CY-9) .

12. Not directly, hut Interchange may he possible In Canada.

13. tend managers are notified In the Plan that maintaining the integrity
of corridora la an important planning component. Reeearch will have to
Identify how It can be achieved. Maintaining gene flow between the Yellowstone
ecoayetem with other ecosystems did not aurface at the workehope as
neceaaary for thle population's survival. If reeearch deema It critical —
tranalocatlon Is one solution.

14. See C211122 Part II and III.

13. Noted and changed. Careful planning will be neceseary to avoid
compounding the effects of each area cut over.

16 and 17. Noted and changed.

18. A minimum viable self-sustaining population was not considered
adequate for recovery in the YCBE and the NCDC.bE.

19. Noted and changed.

20. a. Item 33 waa deleted ea the subject la addreaaed In habitat
stratification and management direction.

b Added under N9 and C9.

21. Noted end changed.

22. Monitoring and management must be preceded by eone Initial status
determine! Ion.

23. * and b. and 24. Noted and changed.

23. A recovered population la the goal — a viable and eelf-auatatning
population may be one at minimum levela that from the standpoint of being
recovered and eligible for delletlng la unacceptable. See new working In
Ylll, Nlll, and Clll.

26. a. Noted and changed.

h. We assume this will be done when jobs 311 and 321 are initiated.

27. e. Noted and changed.

b. Population modeling Indicates that the cub-sex ratio la Important.

28. At this point It is only a theory, beaed on "averslve conditioning".

29. Noted and changed (partially). See Part III. It will be another
determinant of habitat quantity and quality.

30 and 31. Noted and changed- Criteria for determining grlttly bear

nulaance status and disposition of nuisance bears sre found In the 'Yellowstone

Guidelines" ond sre recommended for other areas.

32. Moat rodent control programs will be United to private lands —
not heavily uaed by grizzlies- The toxicant chosen depends on the species to
be controlled. The disturbance la to keep bears from frequenting the area for
three daya -- research atatea moat carcaaaca of polaoned animals will be
unavailable to boars after that time period.

33 and 34. Noted and changed (34); Item 13 added Part II and Part III.

35. Noted. We muat AUHurae that the Coordinator and/or the research and management
personnel Interested In hears will be constantly reviewing all methods.

36. Noted. We helleve this will be under conatant review and could he very
argumentative.

37. Noted and c I winged.

38. 201 beora - 20 femalon with cubs 9 1.78 cubs per female - J5.6 cuI>h
In an aaaiimed atable population; therefore, mortality and emigration ■
35.6 bears; 35.6 - 201 - 17.81.

39. See footnote after N121 and footnote 1/ at end of chapter.

40. a. EPA is only recourse on private lands (moat control involves
primarily private lands).

b. As acknowledged by your office, It haa not been policy of the FVS to
reimburse livestock owners for livestock losses. The PWS Is not suthorlzed to
pay such compensation. To operate auch a program, funding would have to be
authorized/approved by Congreaa.

41. We arc agency specific commenta may or may not be of value.

42. S, NC end SB populations nut Included In areas necessary to recovery
of the species, thus we believe the atatea and land management agencies
will protect And manage grizzly beara In thees sreaa until data becomes
available to set the direction for further actions.

43. The literature citation section was reviewed for sccuracy snd appropriate
changes made. Summery: The responae of the species to recovery efforts as
manlfeated through the population parameters, will be the best indicator

that all other factors and regulatory mechanisms sre being implemented.

Pish and Wildlife Service Assistant Regional Director, Federal Aaslstance,
Region 1

Page 34. Comment noted

Page 57-58. Ue assumed that for the few times that rodenticides are applied
In areas that may be frequented by grizzly bear?, a little extra effort to
prod the applicator Into compliance may be moat expeditiously and least
expensively handled by the closest ADC employee - If he is too busy, I nn>
certain State wnrdena and blologlata would assist him In order to ssve a
few bears.

-191-

Men and Wildlife Service, gfljlg 1

Cowtnti notrd The ecosystems have been prioritised In the final plan.

Fish end Wildlife Service. Acting gaglonal Director. Ration 6

1. C«rrsctsd 2. Noted 3 and 4. Corrected

5. Notad and changed. ft, 7,8,9, 10, and 11. Corrected

12. Sat N 1 1) end 14. Corrected. 1). Notad

16 and 17. Corrected IS. Noted 19. Corrected.

20. Noted and changed. 21. Notad

22 and 21. Noted end dlacuaaed. 24 and 25. Noted

26, 27, and 28. Changed. 29. Noted and dlacueaad 30. Many do not

31. Estimates range from 200 to 400 but no one le willing to be quoted.

32. They are not necessary tor recovery In the lower 48 Statee.

13. Changed 34. Noted and dlacuaaed 3). Corrected
36. Noted and dlecusaed.

Bureau of Indian sffalra (Cotenlaa loner of Indian Affaire; Abb 1 at on t Aran Dl r rctor ,
Kiiourcci, Superintendent, Flathead Agency

The Recovery Plan la a reromamndatlon of thoae actlona neceasary to
recover the grizzly bear and the eetlmated coat of thoae actlona. It
la not a funding commitment. It nay be an area covered under the Flah
and Wildlife Aaalatance to Indians Policy when the Recovery Plan la
approved by the Director. However, future reeource commitment a made
under the above policy to achieve thoee goala would be determined by
future funding level*, appropriation, and reeource availability.
Cloaa cooperation with the Tribe* and BTA will be maintained.

jjgvtr onnanta_l_ Protect ion Agency

Modem ic idea tn*y be used for pocket gopher control In reforestation programs
and for the control of several species of ground equlrrele (uauelly on
private landa) found along the foothill areae whare grizzly bear* may be
found In Hprlng and early summer . Very little data are available on the
acceptability of gristly beare to rodenticldes . We believe that the
recommendations mad* are valid precautionary maaeurea. We have no knowledge
of the typee of peatlcidea or herbicides being ueed In occupied grizzly range
and their potential hazard to grlrzly beara. It la the reaponalblllty of
tha federal agency ualng the materiel or authorizing Ua uae to assure
that It won't Jeopardize the grizzly.

A alight knowledge of grizzly beara would have made the plan easier for
you to understand.

Pagae 2, 15, and 28. Changed.

Page 31: Noted. The dlaperaal of eub-adulta must he atudled extensively.

Page 41: Changed. We agree an edit orial lzat Ion of the agency review draft
plan would hava been deelreble — funding limited thin addition. EPA' a review
appears to he from o Journallatlc viewpoint. Commente on content for purpoaee
of improving the plan for recovery of the apeclea would seem to be more
appropriate.

Your final statement leada me to believe you may have missed s basic reference
on beara, Southey (1847).

Hon tana Department Flah, Wildlife, and Parke

The grizzly bear population in tht Yellowatone Grizzly Bear Ecosystem
wae assumed to hnve declined during the period of the late 1960'a and
early 1970'a, during the period of cloalng Che garbage areas. There
has nnt been editqunte Information to dattrmlne If the present population
la viable end eelf-auatainlng or not; therefore, for recovery we imposed
the following U> art Ions neceeaary to bring the population hack ti)
ItH last known level of viability, and (2) determine If this population
level ie in fact a viable and eelf-euatalning population under present
condltlona.

Data on the Northern Continental Divide Criszly Bear Ecosystem are limited
to a few small study areas In the peripheral zone of the ecosystem and
data from Glacier National Park. If the population was viable and
•elf -sustaining in 1974 when placed on threatened status and/or is
viable and self-sustaining now, all we need is enough data to be reasonably
certain that we are monitoring the trend of the population correctly in the
future. If the population waa declining at the time of listing, there
have been additional perturbations and habitat deterioration that would
reasonably reject any assumption of a reversal of that trend.

On ull other ecosystems, although data are lacking, it seems reasonable

to assume that they may well be in danger of surviving because of low numbers

and increasing pressures.

Paragraph 4. Kecovery ot the population in the conterminous 48 states

seems to get confused with recovery of each ecosystem. The goal Is

to have at least three populations, two at levels known or assumed to be stable

or Increasing during the last two decades, and a third population at

least at the minimum population level described by Shaffer (1978).

Paragraph 6-10. We agree with your analysis of real numbers versus
rates and have passed the information on to the BCP and IGBST.

Paragraph 11. We agree with your concerns of logging, roads, and
wilderness fires and believe you will find those concerns well documented
in the plan.

We appreciate the level of support the Montana Department of Fish, Wildlife,
and Parks is making to grizzly bear research, and alncerely hope the
land management agencies increase their commitment.

Idaho Department of Fish and Came

Changes were made In accordance with suggestions made by you and your staff
at meatings in Boise (January 15, 1961) and in Denver (March 13, 1981).

Wyoming Department of Came and Fish

Paragraph 1. The abbreviated outline Is broken down into subsequent sections.

Paragraph 2. A clear definition of what would constitute a recovered
population In terms of total numbers of bears for each ecosystem
was a major topic of dlscua.iton at each of the workshops and agreement
was never reached. What reaearchera did agree upon wnu to uae monitorable
population parameters to Indicate population atatutt.

"The parameters may not be the beat, but they are what researchers could
agree to. This agreement on and use of population parameters as recovery
goala le the mal-.r contribution of this plan. They provide the First,
If crude, boals for population goals tliot have ever been formal lzr.l for
grizzly beara. Research Is now focused on thcae parameters; It I* n
placu of beginning and one from which to Improve parameters and goole.
Researchers are asked to develop a system to monitor parameters for the
simple reason that they are documentable, total numbers arc not
(Meeley. pers. comm. 1981)".

From the YGBE data we gathered population parameters for a population

that waa atable to increasing during the 1959-67 period. Numbers of

bears In the ecoaystem during that period are a reflection of the parameters.

Likewise, population parameters from the data collected over a ten year

period by Hartlnka in Glacier National Park were used to determine

population goals for the NCDCBE simply because they were the best available.

The whole reason for dividing the Recovery Plan Into different aectione

Is to recognize different population characteristics for different

ecosystems.

Each grizzly bear ecosystem has its own unique set of population parameters
reflecting different habitat condltlona. The whole principle of our
derivation of population goala wbb that auch goals reflect the documentable
characteristic of the population in that area. No er.ologiet ahould
assert that a population with YGBE parameters would conatltute recovery
In the NCDCBE almply because there le no factual relationship between
NCDGBE hebliet and the YGBE population paremetcra (Healey pers. comm.
1981)".

Diacnaelons nt various workshops led to an agreement thut at least three
populations were nert'SHery to assure survival of the spuclos In the
conterminous 48 stales. Although there are no reliable population data
for tho Cablnet-Yesk Crlzzly Bear Ecoaystem, It wae chosen by the group
to be the third area, In addition to the YCBE and the NCtXiBE . Without
sree specific date, wo decided to use s hypotheale developed by Shoffar
(1978), concerning minimum viable populations (ser C 1 for explanation),
to determine the preliminary goal.

-192-

The highest estimate (30 to 70 beara) was chosen simply hecauae o
l«*e*r or minimum number would iiium the very best of hubltst con.lltlons,
minimization of man-caused perturbetions and no man-caused mnrtuUty —
a beer refuge.

Paragraph J. We agree.

Paragraph 4. Y2U3-Y2113J. We believe your action* will suffice.

Y21134. Wyoming Game end Flah would be expected to
authorise only personnel they had confidence In, and
that person would be ualng the aafeat proven technitjuea.

Paragraph 5. Y2U4. We agree. The method muet be carefully designed and
appropriate Federal and State regulatlona aligned.

Paragraph 6. Coata — We estimated coets to Wyoming to continue at present

Wyoming Cooperative Fish end Wildlife Unit

1. Protected public use sites designed to assure that bears could readily
he seen by the public would probably Involve an artificial food source --
not presently acceptable to rm>« agencies.

2. Your threw question* arc the major thruMt o( present research.
Management will sttpmpt to respond when your questions have, answer*.

). We certainly agree.

4. Change* in the plan now recommend emphasis on the larger populations
of bears.

State of Washington, Department of Came

Paragraph 1. There ie no intent on my part to separate the Canadian and
U.S. populatlona.

Paragraph 2. The primary goal la to remove the grlzrly bear from threatened
status In the 48 mntermlnoua states. By general agreement at the workshops
attended by persons most knowledgesble on grltzly besrB, it was decided that
at least three populations must be viable and self -sustaining to assure
recovery of the grt*zly hear. The three areaa chosen were YCBli, Nl'DCAF,
and the CYGBE; the other three or four ecosystem- with documented or suspected
grltzly populations ore without basic data on which to establish any recovery
goals. Wo hope for the continued protection and aurvlval of theae relict
populations. If success is achieved in recovering the bear In the three
major areas, wo con look to a plan for the other areaa.

Paragraph 3. This Is a recommendation only and made on beat authority
available. We commend you on the work you are doing.

Page 2.

(1) I hope you are right

2

(2) I'm sure the available habitat greatly exceeds the 403 mi .

(3) This was a citation from one source for which the study waa a short time period.

(4) Noted and changed

(5) Comment noted (6) None Known

(7) Comment noted

(8) The other 44 (46) states will have a voice in the matter
(°) Comment noted (10) Comment noted

(11) Ihe minimum home range of bears in Washington is not documented to the best
of my knowledge

(12) Crlzzlles ore programmed for extinction by whom — man? Society In
apparently interested In a reprogrsramlng and disagrees with you.

(13) This Implies thuf Washington lans support protecting grizzlies — good I

(14) Granted — two dozen people die each year from bee and wasp
atings and we accept it.

(15) Maybe the plains grizzlies had to program their actions to fit their
needs. Lewis and Clerk found the plains grizzly In cover too.

(16) Comment noted

(17) Comment noted and aorae wording changed per your suggestions.

interagency Grizzly Beor Study Team. Dick Knight, Leader

Paragraph 1. We need to know the number o* bears necessary for a viable
•etf-austalnlnK population, and look to the IGBST to document that
number or the population parameters that Indicate viability. The degree
of difference or similarity between the above and the 1959-67 population
will be history.

Peragraph 2. Craighead i
your comment added.

si. 1974 used five million

and 229

Paragraph 3. Comment noted and corrected; your data added.

Total mortality should not be confused with :

Paragraph 4.

mortality.

Paragraph 5. Noted and changed.

Notrd. Yuu have presented evidence thai some "lsavr
n approached by humans and othcru are apparently
not moving out with roads, activity, and people within

Paragraph 6
the country" wh
comfortable and
a few hundred yards.

Puraitraph 7, See last page of the Forest Service review comments. Several
others commented that the TCBST and BGP are funded by the agencies and
guided by a steering committee. Therefore, responsibilities should be
delegated to the agencies. We certainly intended that if the IGBST is
funded, they should be doing a lot of the research — especially those
dutlea outlined In Y511, Y521, and Y531.

US DA Interaountaln Forest and Range Experiment Station, Ogden, Utah
Roger Ray, Station Director

1. Noted and clarification made. 2. Noted

3. The percentage of females with cubs in the Yellowstone population Is 8.42
when ualng an estimated population of 178, making it comparable with the 10Z
used in the NCX8E.

Techniques are

5. The priority system i
YCBL, NCDCBE, and CYC BE.

e but we are certain they can be developed,
changed to reflect the importance of data a

6. Corrected.

7. Time constraint!
costs. None of the
80, and 81.

and accounting procedures precluded estimating some
estimates include coets of inflation for yearn 1979,

U3DA, Rocky Mountain Forest and Range Experiment Station

Your comments ore appreciated and we fully agree. The Selkirk Mountains,
North Cascade Mountains, and Selway-Bltterroot Grizzly Bear Ecosystems have
been removed from recovery requirements for the apecles in the conterminous
48 states. We believe a lot of preliminary work on present status of the
populations, limits of their habitats, aa well as the socio-economic
limitations need further review before a recovery plan for these areas Is
prepared .

Beer Biology Association

Paragraph 3. Comments noted and changes made. We have presented all of

the data that was made available to us at workshops and through the literature

Chat has been made available to us.

Paragraph 4. See footnote 1/ NCDCBE.

Paragraph 5. Budgeting for the short term is In accordance with the

Fish and Wildlife Service's guidelines for .recovery plan formulation. Whet

alternative funding sources do you recommend'

for

; within the limits of

Page 4, Paragraph 2. Noted and changed.

Page 19, Paragraph 2. Noted and changed. Page 24, Paragraph 2. Noted and

Pag* 25, Paragraph 2. Noted (error) and changed.

Page 32. Paragraph ). 1 wa* unable to obtain Russell's paper.

-193-

Page 18. Noted and paper mentioned citation fur discussion on

MlfcjMt not found.

Fan* 51. According to Knight, ha does not have data which are a mure
accurate reflection of the response of bears to their dependence on a
natural food supply. Th« Craigheed data, which Indicate a atablc or lncreaelng
population from 1^59- 1967 . are the only data available for a viable self-
sustaining population (recovered) In thta ecosystem.

Pa** SI. The viable eel f-euatalnlng population during the 1939-1967 period
wee nuatelnlng an estimated tote 1 Mortality of 18.65X (Craighead et al. 1974)
(corrected by Shaffer to 17.101 ualng data corrected by Coven). Knight
recommends no more then i<1 annual man-caussd mortality end makes no estimate
for totel annual nortallty.

Pagea 51-52. 1 auggaat that the Bear Biology Aeeoclatlon carefully conelder
and evaluate the number of females with cube obeerved under Che two conditions
end then draw some conclusions thet could be applied In estimating dcnaltlea
ao ae to arrive at a totel population estimate. Everyone seems to agree
thee eeelng en average of 12 females with cube/year under preeent dispersed
ccmdltlone repreeence more beere than occurred when an average of 14.889
females with cube were obeerved at the dumps. However, no one will eay It
for the record. Hy opinion le Irrelevant.

Page 14. Noted and Included.

Page 57, There appaare to be vcrloue oplnlone on the eubject — all
equally authoritative- Perhaps certification requirements would beat be
est up by the Bear Biology Aeeoclatlon.

Page 85. Noted and recommended to Montana Depnrtment of Fleh, Wildlife, and
Parke.

Page 116. All priorities have been re-evaluated In accordance with your
euggaetlon.

Montana Wildlife Society

Paragraph 2. The terms are self-explanatory In context of the entire plan.

Paragraph 3. The guldallnee prepered for YC.BE ere available from the Forest
Service. Guldallnee for NCDCBB end other ecoeyeteraa are not prepared
and we believe interim guidelines (prior to being addressed In Foreat
planning 1983 or 1984) ahould be prepered and uaed. Very few changes
from the Yellowstone Cuidelinee would be required.

Paragraph 4. The job description for the Grlnly Bear Recovery Coordinator
le available from PUS.

Paragraph 5. The priorities are being re-evaluated under e new set nf
guldallnee.

Page 2, Paragraph 1. Comment noted. Paragraph 2. Comment noted and we agree.

National Wildlife Federation

Part Tt. Acquleltlon te dlecueead end recoanended when other alternatives
do not atop habitat deterioration.

Mortality:

The recommended goal for man- induced mortality in the YCBE Is xaro.
The current average man-Induced loae of beara le 11. The population
appeara to have lncreaeed einca the loae of the early 70'e while
eueteinlng thla known average annuel loee. Research will determine what
the population can eusteln when population perametere Indicate che trend
of the population. We cannot ba sore conservative than to recommend
aero.

Page I, Paragraph 1. State ar.d Federal cooperation are mentioned repeatedly
and their authority le by law and regulatione.

Paregreph 2, See page 59-61 "Guldallnee".

Paragraph J. The actions mentioned are more dependent on cooperation

and will be more successful through thla method than by makinR it etotutory.

Paragraph 4. The cooperation of private landowners hae been reliable In

many areae where grltaly beers still roam acquisition may be neceaaary

aa trouble spots appear on a caae-by-ceee baale.

Paragraph 5. The recovery plan can only make recommendations. N<rwhere do
we have the authority to include the etrlngent fixed schedule you denlre.
Congreee, via appropriation to agencies, will determine when the plan will
commence .

Page 4, Teregraph I. We cannot recommend lend acquisition funds until
wa can determine where they are needed. Research or management have not
identified ell of the areae necessary for grizzly bear survival.

Paragraph 2. Arees of significant conflict are not yet identified.
Statee have agreed to address the problem when areae of conflict can be
Identified.

Peragraph i. The plan recoeaunda elimination of fond aourcee that may
habituate bean*.

American Wllderneee Alliance

The Racogery Plan recommends conaiderat ton of the Impact of Land u»*
allocations on Rrlsely bears. The Endangered Species Act aleo requires
Federal aganclce to review their activities and progress to determine If
they will affect the grlsily and if eo, consult with the Pieh and Wildlife
Service.

State of Montana - Department of Agriculture

Your commence are noted and wa will keep you Informed1.

State of Montane Department of Natural Resources and Conservation

Coejneoce noted end they will be paeeed on to the Grlisly Bear Recovery
Coordinator.

Burlington Northern Resources Division. Lor In Hicks, Wildlife Biologist

Paragraph 1. Your attendence at workshops was solicited.

Paragraph 2. Oily through good will and private landowners cooperation.

Paragerph 3 (1). We request thet bealc dete be gathered In thla area ae

the EIS Indicates that grlitllee may need Co be a consideration In this area.

(2) 14.889 wax the imoiher of females with cubs ac a population cenaus
efficiency of 77. It. fn a population nf 229 ae Indicated by Cralghosd et al.
(1974), the number of females with cube would have totalled 19 or 20. If
we aeeume Cowen (1975) la correct in nil analysis there would have been over
2} females/cubs. In the population. We do not know why it Is over 8.4X In the
YCBE and 1.5X higher In Glecler Netlonel Perk.

(30. Noted end changes made.

(4) . If we knew how many beara are required for a viable self-austelnlng
population we could heve used it in either or both ecosystese. However, a
viable self-sustaining populstlon may noc be at a level thet le considered
eafe for delisting. I.e. a population of 30 beara may be a viable and self-
sustaining population (no one knows) but unacceptable from the etendpolnt
of being recovered and eligible for delieting. A MVP requlree that all
actions favor the bear and total refuge le In order. Recovery in our
definition brings the bear back Co aome level prior Co lletlng In eech
ecoeystem. When renearrh develops s method to monitor a viable population
we will assume It waa developed on self-sustaining population that Is stable
or increasing but not declining. Subsequently, research mey want to teat
the vleblllty of a smaller population In eech ecoeyeces if that Is che will
of the people. No reel confusion; thoss who want less besr opt for minimum
viable population. Others wenc optimum or maximum vlsbls populations.

(5) Your opinion, not mine. Limited shooting of males may benefit che
population. We presently assume that in areae where grltely bear hunting la
sllnwed moet eportemen do not shoot females with cubs which, If they did,
would be In violation of state lev. Sub-adulta are more likely to be In
groups then adult males. Thus, the beat chance to harveet males and minimize
the hunting mortnllty to females Is to shoot besra thst sro traveling alone.

-194-

elation Animal Damage Control , . ConmlUjeej

Paragraph L. The plan la to benefit grizzly beara. Humana , with llveatock
under their control, can be educated to minimize loaaaa of hunan Ufa,
llveatock, and beam. Two dozen people die eech year from bee nnd wnap etinge.

rltlcal heblta

Paragraph 2. DealgnatJ
not precede It .

Paragraph i i . Your phlloeophy la recognised, but It It m
ell peraone interested In grizzly beara.

Paragraphe 3 i 6. Comments noted.

Paragraph 7. Some recognize your viewpoint end eoM do not.
Paragraph S. We are available for dlecuaelon anytime.

.ended to f oiler

I. Y. Strlnghaa. Graduate Pro^raB.ln Ecology. University of Tenneeaee

I. A. Page 2. Paragraph 3. Craighead et al. (1976) were working with a
stable, viable, and at lf-auetalning population from 1959 through 1967. It
la generally agreed that It declined. He do not know et thle time If It le
vlebte or not below deneltlea recorded during 1959-67. If the populetlon
comes beck to 1959-67 levela, why could we not eseuae a recovered, viable
aelf-auatalnlng population.

6. Agree

II. A. Noted; dlaegree
6. Noted and changed

C. 1. Stringent tine conetralnta precluded me f mm researching all
evalleble data.

2 . Sane

D. Noted and revlaed.

ultl

f population estimates have been
hould be the moet valid.

The

la

Noted. I doubt that an adequate population "ample
avntlablc If the one hy the Crelghead'a la ton anal
The citation la not available.

1. A range acquired from all Mologlete who would <
2 4 3. Noted

1. Noted and changed

2. Cood point

3. Noted and changed

4. Noted

VI. A. Noted and changed.

VII. Commonte noted.

Noted. Hunt inn preeentl
Noted.

Coplee of the "Yrlloweto

Pore'

vLcs

4. Noted and changed.

5. Noted end changed.

6. Noted

7. Noted end changed.

8. Noted and many polnte

9. 10, 6 11. Noted

12. Noted end changed.

13. Noted

14. Hopefully, further r
IS & 16. Noted

red In rewrite.

galraagj Border .Crlziily Technclal Committee

We agree that populetlon data are ineuf f ic lent . We have aet goala that are baaed

on current data ae Interpreted by the beat expertise available. Pinal declalona will

rely on future research.

1. We agree; but data to Identify sen retloa neceaaery for a viable population were

spring range would be adequate

2. We aeaiune that you htlleve a 25 percent coverage
to determine e population trend.

3. Thle wav noted In the plan.

4,5,6,7,8. Wc agree and believe they a
emphaele to what haa already been eald.

9. The) pie
Justify.

open-ended and doea

11. The plan recommends that reeearch develop an Intensive monitoring syatem for
determining population eetlaatee and trenda In the population over time. Budget
eatlmatea were made from estimates of bear experta without any inflation factors

12. Your recommendation is Included in the plan for NCDGBE.

-195-

I )
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( )

( )

( )

( )

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( 5"
L U

#

( )

U'.i;£0 5r^ni Departmen- •
forest -;ERVicr.
P.O. Box 2h\l
dash i r:g ton , D . C .

20013

-TURE

JAN 1 9 -580

2670

. Lynn A. Greenwalt

rector, Fish and Wildlife Service

S. Department of the Interior

^ j^Vjash i ngton , 0 ..C

202A0

vjDear Mr. Greenwalt:

This letter contains Forest Service comments on the agency review
draft of the Grizzly Bear Recovery Plan. After this plan is
approved, the Forest Service will prepare an action program to
implement appropriate parts of the Recovery Plan.

The Recovery Plan presented information in Tables 2, 3, and *4, maps,
and written text, which depicted current occupied grizzly bear
habitat, current grizzly bear populations, and recovery goals.
We have extrapolated from this information to estimate population
numbers by ownership or management units. We feel that these
preliminary estimates will be useful in establishing Forest Service
objectives during planning processes. We would like to work with
you to refine these population objectives. Our specific comments
on the draft plan are as follows:

U The disparity in our extrapolated" bear numbers and densities
Koetween the Yellowstone Grizzly Bear Ecosystem (YGBE) and the
Northern Continental Divide Grizzly Bear Ecosystem (NCDGBE) is
confusing. The two ecosystems are almost identical in area, yet
meeting the population parameters established for recovery results
in 306.bears (1/28 sq. mi.) in the YG3E and 650 bears (1/13 sq. mi.)
in the NCDGBE. The matter is further confused by the indication
that 70 bears would be considered a recovered population in the
Cabinet-Yaak Grizzly Bear Ecosystem (CYG3E) (page 108, Recovery Plan).

While not questioning the recovery objectives set forth in the Plan,
we would like to see a better biological explanation of why population
parameters resulting in such widely varying population numbers
■^ within each ecosystem v/ere selected as the recovery goals.

2. Each of the ecosystems has a variety of 1 andownersh i ps
(Tables A-D) . The NCDGBE is particularly fractured with 1 1" owner-
ships. How were the carrying capacities of the private, State, and
Indian Reservation lands considered in the determination of
population parameters needed for recovery?

Mr. Lynn A. Grcenwalt

3. Table D indicates that less than one-third of the area
needed to support a minimum viable population (MVP) of 70 bears,
is available on public lands in the United States portion of the
Selkirk Mountains. Irrespective of ownership pattern, a popu-
lation of bears does still exist in the Selkirks. Given the
ownership patterns, there appear to be three options for managing
the United States portion of the Selkirks:

a. Disregard the grizzly population.

b. Maintain United States habitat in a condition to
support a density of one grizzly per 26 square miles, in hopes
that management on Canadian and private lands would maintain a
similar capacity, and a MVP would be maintained.

c. Intensively study the current grizzly population and
map habitat, with the goal of manipulating habitat to increase
bear densities to the greatest extent possible.

It appears to us that the Selkirk popul-ation is peripheral in the
United States and we do not control adequate habitat to achieve
recovery. Therefore, we would recommend a management scheme per
item b above.

We are concerned about the lack of public involvement or use
of the NEPA process in development of this plan. The U.S. Fish and
Wildlife Service (FWS) contends that a recovery plan simply prescribes
what must be done to achieve recovery and recommends that various
agencies implement the plan, and that it is not a decisionmaking
document. ^

We believe the Recovery Plan is a decisionmaking document in that
it sets a goal in terms of population parameters resulting in
numbers of bears and it delineates occupied habitat, or the area
necessary to achieve the goals.

The proposal to increase current numbers of grizzly bears ? s a
highly controversial matter and can have significant effects on the
human environment. This is evidenced by the outcome of formal
consultations, relative to the grizzfy bear, on timber sales on the
Gallatin National Forest, hard-rock mining on the Kootenai
National Forest, road construction on the Flathead National Forest,
and oil and gas leasing on the Lewis and Clark National Forest.
In each of these consultations, a jeopardy opinion was issued,
resulting in significant changes in the original management plans
for other resources. Comments (letters) we have received from the
general public and newspaper articles indicate that grizzly bear
management is a controversial subject and not everyone wants more
bears.

Mr. Lynn A. Grccnwal t 3

•

The 1976 FWS proposed rulemaking to delineate 13 million acres as critical
habitat for the grizzly bear was extremely controversial. The recovery
plan proposes a recognition of some 12.3 million acres as occupied grizzly
habitat. We believe that such designation will be highly controversial,
especially if it is not explained and the public is not allowed to comment.
Some factions of the public might perceive that we have delineated de-facto
critical habitat without going through the proper procedures as outlined
in Federal Register Vol. kk , August 15,. 1979-

A careful review of the following portions of £EQ regulations seems in
order: 1502.3, 1508.3, 1503.8, 1503. 11, 1508.1A, 1503.17, 1508.23
and 1508.27.

Regardless of whether the FWS feels that the Recovery Plan is in compliance
with NEPA or not, the Forest Service, through, the land management planning
process, will achieve necessary public input and comply with NEPA as
programs and actions identified in the Recovery Plan are implemented.

5. Occupied habitat, as delineated in the Recovery Plan, was developed
at various meetings. The Forest Service objected to the lack of mapping
criteria at several of these meetings, to no avail. Although several
Forests disagree with the Recovery Plan's delineation, the Forest Service
will officially accept these delineations. We wish to go on record,
however, as being strongly opposed to the lack of mapping criteria.

6. Page 1. It may not be possible to "remove" the limiting factors,
as stated in objective 3. Perhaps "regulate" the factors is a more
realistic objective.

7. Page h, paragraph 2 of the plan states that social, political,
and economic (nonb iol og i ca 1 ) factors were not considered in plan
development, and such nonbiological aspects will have to be dealt with
by administrators. We fear that not addressing these nonbiological
aspects may be a serious impediment to implementing the Recovery Plan.
As stated above, this is a highly controversial subject. If the plan
does not consider and incorporate social, political, and economic factors,
it will likely receive resistance from the public.

8. Page 9. Since the stepdov/n portion of the Recovery Plan (Y61111)
calls for research on aversive conditioning of bears, it might be useful
in this section on Behavior to summarize existing information on this
subject .

9. Page 12. The most current citation on the grizzly studies in
Teton Wilderness, Wyoming, should read:

. Hoak, J.H., T.W. Clark, and J.L. Weaver. I980. Grizzly bear
ecology in Br i dger-Teton National Forest, Wyoming. In
C; Meslow, ed. Fifth Intern. Conf. on Bear Research
and Management. In press.

10. Page 19, line 19- Should "relative" read "relevant?"

Mr. Lynn \ . jreenv.alt ' k

11. Page 26. In the section on Natality, there is no information
presented on litter sizes. It is particularly important to provide
such data because this is one of the monitored population parameters.

Also, in the section on Natality, it may be useful to cite H. Picton's
paper relating decreased precipitation in the Yellowstone area during
the past lOyears to decreased litter sizes for grizzly bears during
this same period.

12. Page 30. The section on Mortality jump.s right into the specific
case of mortality in the dens. A more logical sequence might be to
proceed from a general discussion of mortality causes and rates to more
specific cases.

13. Page 33. The questions raised here, regarding aggressive behavior
of bears and conditioning possibilities, are a good addition to the Plan.

• Would it be more appropriate to place them in the section on Behavior?
Also, in line 7, "aggressive" is misspelled.

lA. Pages 39 and *+0. The discussion on timber harvesting should be
expanded to explain the specific consequences of timber harvesting,
positive and negative. Also, the consequences of the associated factors
involved with timber harvesting, such as road construction, should be
discussed separately.

15- Page k} . Why no reference to Knight's work on denning which is
the most up to date?

16. Page 50. Our records show very few reports of grizzly bear
sightings south of Bitch Creek. None are^ recorded as far south as
Leigh Creek. Therefore, we recommend that occupied habitat for the
Targhee National Forest be shown only as far south as Bitch Creek
(North Fork of the Teton River).

Also, for table 2 (page 66) the acreage summary should.be:

Occupied Habi tat

MS 1 ' 180,000^
MS2 1 59,680^'

A correction on this master map was made in 1 980 by the Shoshone National
Forest and has been provided to Don Brown, Recovery Plan Coordinator.
The acreage figures in Table 2, page 66, reflect this revision but the
1979 map used in the plan does not show the correction. We suggest the
updated map be used to avoid confusion and to accurately represent occupied
habitat on the Shoshone National Forest. A copy of the correct "map
(Enclosure 1) is enclosed for reference.

— Mt. Two Top and Winegar Hole
2/

— Moose Creek Plateau (Reas Pass to Robinson Creek)

Mr. Lynn A. Grcenwalt

5

17. Paqe 51, Y111. We reccqnize the need to establish a reference
point for a recovery target. However, we recommend the parameters that
represent the population of the period 1959 to 19&9 ^e presented in the
Plan v/ith qualification. The parameters reflect a population that was
heavily dependent on an artificial food source (dumps). Therefore, it
is possible that with the more natural conditions of today, a population
demonstrating the target parameters may not be obtainable.

We recommend this point be emphasized in' the Plan and that an action item
be written that describes the need to continually evaluate the parameters
used to describe a recovered population. The Plan should document that
the target parameters may change as more information is gathered. It
may be most appropriate to discuss this matter on page 2.

18. Page 5^, Y 2 1 1 . The listing of three separate figures (11, 6,
and 5) as the maximum limit to man-caused mortalities is confusing and
unnecessary. We recommend the number offered by the recovery planning
group (6) be used.

19. Page 5't, Y21111. We suggest the law enforcement arm of the
Forest Service be specifically identified as a cooperator.

20. Page 60 , Y2221. The sentence "Supplemental guidelines for
MS - 1 and MS-2 lands have been prepared and are available (Mealey
pers. com. I9S0)" should be deleted. This statement does not belong
in the Recovery Plan as the supplemental guidelines have not been
reviewed or agreed upon by the parties to the approved "Guidelines."
If and when these supplemental guidelines would be used, they could
be incorporated into the revised or amended "Guidelines."

21; Page 61, Y2251 . The last sentence refers to "species managers."
What are "species managers?" This term should be clarified to assign
responsibility to the proper agency.

22. The section on "Assumptions," page 63, leaves .the connotation
that Region 1 is doing nothing relative to management of grizzly
bear habitat outside of designated essential habitat. We would like
to see a statement added which recognizes the ongoing Forest planning
process. For example, "Planning, as per the National Forest Management
Act, is now underway on the Gallatin and Custer National Forests.

This planning effort is addressing management of grizzly bears and
their habitat."

23. Page 6^, Y^22. Past records indicate bears have occupied this
area, but habitat quality does not justify MSI. No recent sightings
have been made in this area.

2*4. Page 65, item khk).. The Forest Service has accepted the
acreages as .presented in the Recovery Plan.

Mr. Lynn A. Greenwalt

6

25. The naps indicating occupied habitat in the recovery plan are
difficult to read because of the small scale. However, it appears there
is an inconsistency between the acres of occupied habitat on the
Custer NF indicated in Table 2 (page 66) and the area delineated on the
map. The acres in the Table are correct, but the map seems to be in
error. We have enclosed a Forest map (Enclosure 2) with the correct
area scribed.

In addition, the 156,500 acres of occupfed habitat' on the Custer NF
should be broken out as follows: MS 1 32 , 000 .acres ; MS 2 12^,500
acres. These designations are considered interim to completion of the
Forest Plan.

26. We suggest the Tables depicting occupied habitat in the plan
indicate square miles as well as acres, since the text refers to
densities of bears in square mile terms. It would also be helpful
if the acres and square mile figures were totaled.

27. Page 71, Y612. Also, the following should be inserted at the
end of Y612: ". . ., per the critieria and steps provided on pp. 59~62
of the Guidel ines."

28. Item Y65 (page 72) may be unworkable, and the need for such a
requirement is not clear. It may be unworkable in that other laws
and regulations may preclude a 2-year delay between permit requests
and the decision as to whether to allow the activity (e.g. 1 832 mining
law; 1922 oil and gas leasing law). In addition, the past work done by
the Craigheads, current work being done by the Interagency Yellowstone
Grizzly Bear Team, and habitat mapping being done by the Forests, has
brought together a considerable amount of information on grizzlies

and their habitat. The wording in Y65 seems to imply that site
specific information is needed. These same thoughts apply to items N6**
(page 103) and C 63 (page 12*0. In some cases baseline data may need to
be collected but, in others, sufficient information may be available.

29. Page ~Jk, I tern C. The referenced figure should be 3 rather
than 1 .

30. The last sentence in the first paragraph on page 92 is incorrect.
The Lolo National Forest addressed grizzly bear management on 162,181
acres in their Draft Forest Plan (April I980). The final plan will
consider bear management on all acres identified in the Recovery Plat)
All other Forest Plans will do likewise.

31. The figure given for "Acres Stratified by Grizzly Use" for the
Kootenai NF in Table page 121, is incorrect. The correct figure

is 51'4,75^.

32. Page 137, Y22^1. Under Estimated Cost column, the statement
should read the same as in Y 2 2 3 1 two paragraphs above. The statement
as written does not apply to Federal lands.

Mr . Lynn A . G reenwa 1 t

33. Page 138, Y2251 . This action does not agree with the text as
written on page 61. The Action should be to apply the "Guidelines" in
occupied ranges rather than "restrict" or "withhold" permits. Certain
permits and/or types of development may not impact the grizzly bear.
The option to permit, restrict, or deny should be left open pending

an assessment of the proposal.
*

34. Page 139, YMl , Y^21, Y*»31 ; Page \k0, YA^3; Page \h\ , Y*»51 .
These plan items assign the Forest Service as having lead responsi-
bilities for making recommendations on private land relative to
conservation of the grizzly bear. The Forest Service has limited
authority for such a role but will be happy to cooperate. This may
be more appropriately assigned to the State wildlife agency and the
U.S. Fish and Wildlife Service.

35. Page ]k2, Y5H, Y521, Y531. This Action item should be expanded
in order to clarify how and who will do the actual monitoring of the
parameters. Monitoring the status of the grizzly bear is the basic
responsibility of the Fish and Wildlife Service and the State wildlife
agencies. The Forest Service would have basic responsibility for
monitoring hab i tats on National Forest System lands and some responsi-
bilities under the NFMA regulations for monitoring the bear in
cooperation with State agencies and the PWS .

36. Pages \kl and H3, Y532, Y5321, Y5322, Y5323, Y5324. These
actions and the supporting text on page 69 are vague and are not clear
as to what should be done. Y5323 calls for establishment of benchmarks
of present habitat values to measure the cumulative effects of actions.
This is not consistent with other sections which speak to habitat
components. We suggest that benchmarks b^e established for habitat
components rather than values.

37- Page 1^5, Y65 and Y66. The statement in the Estimated Cost
column, ". . . should include cost in permit fees," should be deleted.
This is not a- legitimate cost to be passed on to a permit applicant.
It is an administrative cost incurred the same as any environmental
analysis report on any proposed permit or project. Furthermore, the
Forest Service has no basis for passing such a fee on to the applicant.

38. We have a concern about the Interagency Grizzly Bear Study
Team and duties inferred upon them by the Recovery Plan. The Study
Team can complete many jobs and collect much of the information
called for in the Recovery Plan. However, the Study Team is a
representative of member agencies and must serve the agencies'
needs. The Study Team must not unilaterally be assigned or under-
take responsibilities without agreement and direction being provided
by the Study Team Steering Committee and its member agencies. -

Mr . Lynn A. Greenwa 1 t

3

At this time, we do not believe the Draft Recovery Plan should designate
any duties for the Study Team. Either the Recovery Plan must delete all
references to the Study Team in Section III and the job implementation
and budget section or the Steering Committee and member agencies must
agree to the actions the Study Team will perform before the Plan is
finalized and approved. The first option would expedite approval of
the Recovery Plan.

We believe it would be best if the Recovery Plan did not refer to the
Study Team, other than to recognize their technical capabilities.

We certainly appreciate the opportuntity to review this draft of the
Grizzly Bear Recovery Plan. Mr. Don Brown and others who contributed
to the plan have done a commendable job. The Forest Service will assign
top priority to those actions needed to achieve the recovery of this
magn i f i cent an ima 1 .

S i ncerely ,

Enclosure

i

TunrliTOKY

U/ J

United States Department of Agriculture
forest service

R-2

. i . . .!.«!• * . ....J

REPLY TO:

SUBJECT:

2670 Threatened and Endangered Plants and Animals
Grizzly Bear Recovery Plan

DEC 5 m -,/L/<M'

TO: Chief

We have reviewed the Agency Review Draft of the Gri zzly/'Bear Recovery _(

Plan and will limit our comments to the portions pertaining to Region 2.

Page 50, Figure 3. - A correction on this master map was, marie "in" 7980

by the Shoshone National Forest and has .been provided to Don Browri7 '

Recovery Plan Coordinator. The acreage figures in Table 2, Page 66,
reflect this revision but the 1979 map used in the Plan does not show
the correction. We suggest the updated map be used to avoid confusion
and to accurately represent occupied habitat on the Shoshone National
Forest. A copy of the correct map is enclosed for reference.

Page 57. - The "Guidelines" are footnoted as 4/, but no indication is
given as to where to find footnote 4/. We suggest that the footnotes
on pages 74 and 75 be moved to the page where first noted or a
reference be provided as to where to find the footnotes.

Page 60, Y2221. - The sentence "Supplemental guidelines for MS-1 and
MS-2 lands have been prepared and are available (Mealey pers. com.
1980).," should be deleted. This statement does not belong in the
Recovery Plan as the supplemental guidelines have not been reviewed
or agreed upon by the parties to the approved "Guidelines." If and
when these supplemental guidelines would be used, they could be
incorporated into the revised or amended "Guidelines."

Page 61, Y2251. - The last sentence refers to "species managers."
What are "species managers?" This term should be clarified to assign
responsibility to the proper agency.

Page 74, Item C. - The referenced figure should be 3 rather than 1.

Page 137, Y2241._- Under Estimated Cost column, the statement should
read the same as in Y2231 two paragraphs above. The statement as
written does not apply to Federal lands.

Page 138, Y2251. - This action does not agree with the text as written
on page 61. The Action should be to apply the "Guidelines" in occupied
ranges rather than "restrict" or "withhold" permits. Certain permits
and/or types of development may not impact the grizzly bear. The
option to permit, restrict, or deny should be left open pending an
assessment of the proposal .

Chief

2

Page 139, Y411, Y421 , Y431 ; Page 140, Y443; Page 141, Y451. - These plan
items assign the Forest Service as having lead responsibilities for
making recommendations on private land relative to conservation of
the grizzly bear. The Forest Service has no authority for such a
role and should not have it. This would be more appropriately assigned
to the State wildlife agency and the U, S« Hsh and Wildlife Service.

Page 142, Y511 , Y521 , Y531. - This Action item should be expanded in
order to clarify how and who will do the actual monitoring of the
parameters. The Action appears to suggest there will be an interagency
study team to develop the system and do the monitoring. We do not
agree with this, per se. Please see our discussion concerning the
study team later in this memorandum. Monitoring the status of the
grizzly bear is the basic responsibl ity of the Fish and Wildlife
Service and the State wildlife agencies. The Forest Service would
have basic responsibility for monitoring habitats on National Forest
System lands and some responsibilities under the NFMA regulations
for monitoring the bear.

Pages 142 and 143, Y532, Y5321 , Y5322, Y5323, Y5324. - These actions
and the supporting text on page 69 are vague and are not clear as to
what should be done. Y5323 calls for establishment of benchmarks
of present habitat values to measure the cumulative effects of actions.
This is not consistent with other sections which speak to habitat
components. We suggest that benchmarks be established for habitat
components rather than values.

Page 145, Y65 and Y66. - The statement in the Estimated Cost column,
". . . should include cost in permit fees ," 1 should be deleted. This is
not a legitimate cost to be passed on to a permit applicant. It is
an administrative cost incurred the same as any environmental analysis
report on any proposed permit or project. Furthermore, the Forest Service
has no basis for passing such a fee on to the applicant.

All in all, we have few critical concerns with the Recovery Plan. We do
have a critical concern about the Interagency Grizzly Bear Study
Team and duties inferred upon them by the Recovery Plan. The Study
Team can complete many jobs and collect much of the information
called for in the Recovery Plan. However, the Study Team is a
representative of member agencies and must serve the agencies' needs.
The Study Team must not unilaterally be assigned or undertake
responsibilities without agreement and direction being provided by
the Study Team Steering Committee and its member agencies.

At this time, we do not believe the Draft Recovery Plan can desigaate any
duties for the Study Team. Either the Recovery Plan must delete all
references to the Study Team in Section III and the job implementation
and budget section or the Steering Committee and member agencies must
set down and agree to the actions the Study Team will perform before
the Plan is finalized and approved. The first option would expedite
approval of the Recovery Plan.

Chief

3

We believe it would be best if the Recovery Dlan did not refer to the
Study Tean, other than to recognize their technical capabilities.

C^CRAIG W. RUPP

Regional Forester

Enclosure

cc: Shoshone NF

Unitf.d States Dr "ARi MrhT of AnmcuLTlinr
roRr.si SCR VICE

324 25th S» ) cot
Ogden, Utah 8440]

PDr. Roland H . Waver

Steering Committee Chairman

Grizzly Bear Study Team

Natural Resources Division

National Park Service
Ll8th and C Streets, N.W.

Washington, D.C. 20240

Dear Dr. Waver:

It appears that the official recovery plan for the grizzly bear will
be finalized in the near future. At that time, the burden fur recover;
and maintenance of the species will be in much sharper focus for Lhe
land managing agencies.

In order to be ready for our more specific responsibilities, ns defined

in the recovery plan, we have formed a task force to explore management f.

options, in addition to the Grizzly Guidelines. Presently this I lsk

force is made up of John Drake, Supervisor, Gallatin National Forest; ::

John Townslcy, Superintendent Yellowstone Natfcuial Park; Ray Hall, r

Supervisor, Shoshone National Forest; and Held Jackson , Supervisor oi

the Bridger-Teton National Forest.

Since 1973, we have depended heavily on the Grizzly Study i e i"1 to gather
data and for consultation and advice. They have performed well and have
been our main source of knowledge for guidance to management. We commend
them for their assistance and patience. We still need their help and
would like our "management direction" task force to "pick their brains"
as we plot direction to be more responsive to the recovery plan. The
task force also plans to consult with Don Brown, author ot the draft
recovery plan.

o 1

One of the questions unclear in the draft recovery | 1 an is th
monitoring — '..ho should have the responsibility to sc.- that tin maintenance
of the species is in accordance with the recovery plan? We would like
your thoughts on this question. We also plan to cops. ill with the affected
state agencies on this question.

.erne oi

As we firm up management direction, we '..'ill provide you •■■<[
the direction we plan to take and inform you of some of Lhe unknowns
which could form the basis for further research Vvh i ch may iet re'st you
and be of value to us.

fiZOSI-1 I (1/69)

2

With the publishing of a recovery plan, wo feel .1 njgn.iri.cnnt increase in
the responsibilities of the Land manager. We are preparing for this
responsibility and intend to manage our affairs with the total habitat
of the grizzly in focus and not be fragmented by Fedora J land ownership.
We hope to be able to work with the states and other interests with this
same objective.

Sincere] y ,

Jeff M. Sirmon

Jeff M. Sirmon
Regional Forester
Intcrmountain Region
USDA Forest Service

Torn Cos ton
Regional Forester
Northern Region

USDA Forest Service

Craig Rupp
Regional Forester
Rocky Mountain Region
USDA Forest Service

Lorraine Mintzmyer
Regional Director
Rocky Mountain Region
Na t i o n a 1 Pa rk S e rv i c e

i

UNITED STATES DEPARTMENT OF AGRICULTURE
FOREST SERVICE

Shoshone N.F.

REPL Y TO:

2670 Threatened and Endangered Plants and Animals

October 23, 1980

SUBJECT:

TO:

Regional Forester

Grizzly Bear Recovery Plan

The following is the Shoshone National Forest response to the
above Draft Recovery Plan for consideration in the coordinated
Forest Service response.

Item - Page 50, Figure 3. A correction on this master map was
made in 1980 and is in the possession of Don Brown. The acreage
figures in Table 2, Page 66 reflect this revision but the 1979
reduced map shown does not. We suggest the updated map be used
to avoid confusion and to accurately represent occupied habitat
on this Forest. A copy of the corrected map is enclosed for
reference.

Item - Page 60, Y222l.The sentence "Supplemental guidelines for
MS-1 and MS-2 lands have been prepared and are available (Mealey
pers. com. 1980)." should be deleted. This statement does not
belong in the recovery plan as they have not been reviewed or
agreed upon in the approved guidelines. If and when these supple-
mental guidelines would be used, they could be incorporated into
the revised or amended guidelines after the annual meetings on
revisions "as needed" were held.

Item - Page 74c. The referenced figure should be 3 rather than 1.

Item - Part III, Yellowstone Grizzly Bear Ecosystem. Action tasks
should be numbered in sequence for easier reference for future
accomplishment and reporting.

Item - Page 137, Y2241. Under Estimated Cost column, the statement
should read as in Y2231 two paragraphs above. The statement as
written does not apply to Federal lands.

Item - Page 138, Y2251. The Action should be to apply the guide-
lines in these occupied ranges rather than restrict'1 or "withhold"
permits. Certain permits and/or types of development may not have
significant impacts on the grizzly bear to deny the proposal.
Accumulative impacts are covered in other action items. Irregardless ,
the option to permit, restrict, or deny should be left open pending
an assessment of the proposal.

-2-

Item - Page 142, First Action item on page. This Action item
should be expanded upon to clarify how or who will do the actual
monitoring of the parameters. This appears to suggest there will
be an interagency study team to develop the system and do the
monitoring. Also, if this is the case, the IAGBST should be listed
as a cooperator, either as existing or newly formulated. It appears
to us that the IAGBST would be the logical monitoring group.

Item - Page 142 (bottom) and Page 143 (top) . This Action is too
vague to adequately evaluate. Bench mark of present habitat values
and quality indexes, if needed, should be developed by an inter-
agency team. We question the need for this action item in light
of the other parameters being monitored.

Item - Page 145, Y65 and Y66. The statement "... should include
cost in permit fees" should be deleted. We do not believe this is
a legitimate cost to be passed on to a permit applicant. It is
an administrative co9t incurred the same as any environmental
analysis report on any proposed permit or project.

This response deals with those portions of the Recovery Plan that
pertain to the Greater Yellowstone Area and Shoshone Forest only.
Other ecosystems were not addressed.

Randal! R. Hall

RANDALL R. HALL
Forest Supervisor

Enclosure

JSanders: lhd

c

c

Shoshone National Forest
P.O. Box 2140
Cody, Wyoming 82414

August 7, 1980
2600

Mr. Don L. Brown

Grizzly Bear Recovery Plan Leader
State of Montana
Dept. of Fish and Game
Helena, Montana 59601

Dear Mr. Brown:

We have reviewed the draft of the Grizzly Bear Recovery Plan and are
submitting some edits (in pencil in the Plan) and minor changes for
your consideration for incorporation into the Plan as it pertains to
the Yellowstone ecosystem.

Pages 12 and 13; As the references are so far removed, we suggest
adding page numbers after the references; i.e., Figure 4 - page
59; Figure 6 - page 102; Figure 7 - page 103; etc. Also, Figure
5 - page 101 should have a map of some kind even though definition
delineations have not yet been made.

Page 14; We suggest a legend for Figure 2 (see pencil example in
the Plan).

Page 26; Suggest rewording of (3) and (4) to be less abrasive:
(3) livestock management, including non-disposal of dead livestock;
and (4) the insidious erosion of habitat from various development
projects and activities.

Page 30,31, and 32: Cover - we suggest adding on page 32: As the
grizzlies' activity is primarily nocturnal, open areas and parks
may be of greater importance than some of the literature suggests.
Aerial night tracking and locations determined from radioed bears
is needed to determine a more desirable ratio of forage to cover
area requirements for the bear.

Page 38, Figure 3, Map: This reduced map looks like the one done
prior to some minor revisions made at the meeting with Mealey,
Sanders, and yourself at Cody. The revised acreages are correct
so we are assuming the revised reduced map will be the one in the
final plan. (Note pen and ink correction in the SE quadrat of the
map.)

Page 42, Y211: There seems to be three recommendations here: 11,
6, and 5. We suggest using man-caused mortality of 6 bears or
less to expedite recovery.

r c

Page 2

Pages 42, A3, and 44: We suggest the rewording of this section to
be an investigation team with the State agencies and the FWS as
the law enforcement personnel on the team. If written in this
context with cooperation and assistance provided on the administra-
tive jurisdiction involved, we would see no need for an interstate,
interagency agreement and the actual law enforcement authorities
of each agency would not be tread upon.

Page 50, Line 6; Should read Shoshone, Bridger-Teton, and Targhee
rather than Custer and Gallatin National Forests.

Page 51, 746; Should have Y461. None.

Page 55, Y6113: We doubt that we will ever designate areas for
new populations if the intent here is for reintroductions into
areas not previously occupied (otitside of the green line) . Those
areas designated for relocation in the guidelines could be used in
this subtitle rather than "new populations".

Page 57, Footnote: Subadults should be 24.7% to equal 100 but
Craighead is cited page 21 as 23% subadults and 45% adults.

With regard to determining a recovered population in terms of Craighead's
data (dump bears versus dispersed populations) we would suggest using
the same numbers; i.e., monitoring 15 females with cubs of the year.
Even though the bears were coming to Craighead1 s, we now have more
intensive monitoring and could probably locate 15 females in the dis-
persed population to an equivalent extent that Craighead did with his
concentrated population study. We see no reason to alter the parameters
by stating that 12 females located now equates to 15 females then, etc.
If we are in error in this assumption, then at least we have erred in
favor of the bear.

We would like to commend the work of the Grizzly Bear Recovery Plan
team on the creation of what should be a significant effort in the
conservation of the grizzly bear.

Sincerely,

RANDALL R. HALL
Forest Supervisor

Enclosure
JSANDERS: tjp

United States Department of Agriculture
forest service
Rocky Mountain Region
1 1 1 77 West Eighth Avenue, Box 251 27
Lakewood, Colorado 80225

Mr. Don L. Brown

Grizzly Bear Recovery Plan Leader
State of Montana
Department of Fish and Game
Helena, Montana 59601

Dear Don:

Thanks for the opportunity to informally review the Technical Review
Draft of the Grizzly Bear Recovery Plan. We compliment you and your co-
workers on its quality. We have a few very minor comments and two of a
more serious nature (marked with an asterisk).

Page 3, second full paragraph - This is the appropriate location for
first reference to the Colorado bear, not page 11.

Page 10 - Can't help but believe the ^950 Grizzly country map is too
inclusive of areas in the Rocky Mountain States, thus giving an
unduly drastic impression of geographic decline since then.

Page 12, first full paragraph - We recognize the significance of
what is being pointed to but to say that the Northern Continental
Divide Grizzly Bear ecosystems include a "strip of the Great Plains"
is taking a somewhat loose and misleading interpretation of the
Great Plains ecosystem in my opinion.

Page 15 - We would suggest that the Continental Divide north from
Yellowstone does provide a fairly adequate travel corridor for
grizzly bears at best as far as the Anaconda-Pintl ar Wilderness.
... Certainly, it is the most promising and least disturbed and should
be viewed for those qualities.

Page 26 - Man-Caused Mortality - You should rewrite this to more
clearly state what the problem is with dead livestock, if any. The
phrase "failure to properly dispose of dead livestock" is subject
to challenge and a lot of argument and perhaps legality.

2670
JUL 2 2 1980

/

«200-11 (1/69)

V

2

*Page 42, Y21111 - There is a purpose and value in having a coordinated
team effort on grizzly bear harassment (not just kills) but we strongly
emphasize that law enforcement, per se, should and must be the respon-
sibility and function of the respective states and the U. S. Fish and
Wil dl i fe Service.

Forest Service involvement in this should be held to a matter of coop-
eration and assistance. If this section is not rewritten to reflect
the differences between agency responsibility, we suspect that you
will have trouble gaining Forest Service acceptance.

Page 49, Y312 - We assume "management stratifications" are with ref-
erence to the Yellowstone Area Grizzly Bear Guidelines. Clarify.

Page 50 - It appears the wrong Forests have been cited here. You
apparently meant to refer to the Shoshone, Bridger-Teton and Targhee
National Forests.

*Page 53, Y491 - The Forest Service and Bureau of Land Management would
accept a certain responsibility for encouraging landowners to eliminate
problems. However, the greater and unavoidable responsibility falls on
State wildlife agencies and the USF&WS. This should be clearly pointed
out.

Thanks again for the review opportunity.

Sincerely

v

Director, Range and Wildlife Management

i