THE TOP TEN (OR 15) REASONS
TO OPPOSE YELLOWSTONE GRIZZLY BEAR DELISTING

1. The current population is too small and isolated to ensure long-term viability. The size of the current population is about one-quarter of what is needed to maintain genetic variability over time. Long-term health of the population can be assured by
maintaining a population of several thousand individuals. This requires expanding where bears can live in Yellowstone, recovering bears in the Selway-Bitterroot, and connecting grizzly bear ecosystems to source populations in Canada.

2. The delisting plan relies on the importation of bears to address genetic problems. The plan requires the importation of two bears every ten years into the Greater Yellowstone Ecosystem (GYE) to address genetic problems. This is not natural
recovery. Further, adding a bear or two is not likely to provide necessary gene flow, considering the low success of transplants in habitat that is already occupied. Again, the long-term health of the population can be achieved instead by expanding grizzly
bear populations and connecting grizzly ecosystems.

3. The delisting plan fails to consider the degree and the pace of habitat change occurring in the region, and their implications for bear recovery. The plan wrongly assumes that the future will look like the past. It calls for maintaining habitat
conditions as of 1998, but 1998 conditions have already changed significantly and will continue to do so.

Specifically, the plan fails to consider the effects of the rapid human population growth in the region, where some counties are doubling in size every ten years. The plan also underestimates the pace and implications of the loss of whitebark pine, an important bear food, due to mountain pine beetles, blister rust and global warming. Recent studies show that whitebark pine loss is escalating from mountain pine beetle infestations - more quickly than US Fish and Wildlife Service (FWS) estimates.
Research has demonstrated whitebark pine's relationship to the reproductive success of females and to lowering human-caused mortality; there appears to be no substitute bear food in the ecosystem. In addition, cutthroat trout spawning in
Yellowstone Park and bear use of trout, another key food, is declining as a result of ongoing drought and the effects of alien Lake trout.

To compensate for the significant changes occurring rapidly in the ecosystem, the agency must protect suitable unoccupied habitat outside the recovery zone, including areas such as the Wind Rivers and Wyoming Range, where bears have been
prohibited in the Wyoming plan.

4. Delisting relies on habitat management plans which are not yet in place. Forest Service has not yet finalized its forest plan amendments. The public cannot be fairly asked to comment on the adequacy of regulatory mechanisms after delisting, if it
does know what mechanisms exist.

5. Forest Service management plans will no longer contain binding habitat standards. Under the new Bush administration rules, forest plan standards will be discretionary, rather than mandatory. That means that the Forest Service will
enforce the rules if it feels like it. Regulatory mechanisms to maintain habitat after delisting are not adequate if requirements are not binding.

6. The delisting plan contains no habitat protections for about one-third of occupiedgrizzly bear habitat. To sustain current population numbers, habitat conditions must also be maintained. But, the delisting plan only protects lands inside the six million
acre recovery zone, and leaves out over two million acres of habitat. Contrary to FWS statements, only 15% of this land is protected as Wilderness, and the rest is open to development. These lands include some of the most threatened habitat in
the GYE, especially by energy development in Wyoming.

7. The plan lacks adequate funding mechanisms and fails to demonstrate agency commitment to implement the delisting plan. The delisting plan requires $1.2 million per year in addition to what is already being spent on grizzly recovery. After delisting, ESA Section 6 funding to the states will disappear, and Forest Service funding is expected to decline. The Forest Service already lacks the necessary funds to monitor habitat, and this problem will get worse. No one knows where the
additional monies will come from to pay for implementation of the delisting plan.

8. The Wyoming plan will result in the decline of the grizzly bear population. Wyoming plans to manage the grizzly bear population down to 500 bears, which will result in an estimated killing of 50 bears annually. This means that the estimates of
current population growth rates in the delisting plan will no longer apply after delisting. The population will decline after delisting, and cannot be sustained without life-support measures.

9. The US Fish and Wildlife Service and the State of Wyoming appear to condone Wyoming county laws prohibiting bears within their borders. Four counties in Wyoming have passed laws barring bears within their borders. Fremont County has
already requested that its county sheriff start killing bears. These counties will have more authority over grizzly bear management after delisting. Recovery goals cannot be achieved if these counties implement their laws as they intend.

10. The plan relies on adaptive management, with no specific thresholds to prompt changes if they are needed. The only specific threshold to prompt a review of the status of the population after delisting is a violation of mortality limits. The plan lacks thresholds and mechanisms to trigger change should habitat decline - which is happening now, and will continue. Scientists have demonstrated that lag-times exist between when habitat is lost and when this loss shows up as a decline in population.
Research has also shown threshold population effects, which could mean that by the time the problem is detected, it is too late to fix the problem.

11. The delisting plan lacks binding motorized access management standards to protect habitat. The 1993 Grizzly Bear Recovery Plan and scientific research have demonstrated that roads kill bears. The delisting plan downgrades current access
management standards on National Forest lands from a management standard to a monitoring tool. This is not adequate to maintain grizzly bear habitat.

12. The delisting plan fails to address issues associated with high, ongoing humancausedgrizzly bear mortality. Most of the grizzly bears that die in the GreaterYellowstone Ecosystem die of human causes, and most are avoidable. While
Yellowstone Park and some communities outside the park have gone to enormous measures to remove grizzly bear attractants, others have not. The problem of mortality of food-habituated bears will only get worse after delisting, when allowable
mortality levels are raised, and resources for conflict resolution are reduced. Because problem grizzly bears are a human safety problem, it only makes sense toresolve the ongoing sanitation issues in the ecosystem before delisting.

13. The delisting plan relies on population measures that have been found to be arbitrary and capricious. In the 1995 Federal District Court ruling on the Fish and Wildlife Service's Grizzly Bear Recovery Plan, the use of females with cubs as the
measure of the population was rejected as arbitrary and capricious, because of inherent biases and other problems. These problems have yet to be fixed. But, the agency continues to rely on these measures to determine whether population targets
have been met.

14. The Fish and Wildlife Service fails to acknowledge that recovery targets have not been met. FWS has repeatedly stated that all the recovery plan targets for Yellowstone grizzly bears have been met. This is not true. In 2004, the agency
violated the level of allowable female-caused mortality. Instead of acknowledging this fact, FWS changed the rules using a method that is only now being reviewed by the public.

15. The Fish and Wildlife Service wrongly assumes that delisting the grizzly bear will build social support and tolerance for grizzly bear recovery and the Endangered Species Act. The research cited does not support FWS's argument that people will be more supportive of grizzly bears if they are no longer federally protected. Indeed, at the recent announcement of the delisting proposal, Senator Larry Craig used the opportunity to call for weakening the Endangered Species Act. Successes in resolving conflicts typically occur because of the ESA, which forces parties to come to the table to solve problems, and provides needed resources.

National Resources Defense Council - Wild Bears Project
P.O. Box 70
Livingston, MT 59047
406-222-9561
wildgriz@aol.com
www.nrdc.org