Download Wyoming Wildlife Advocates Position Paper

Wyoming Wildlife Advocates believes removal of the Yellowstone grizzly bear from federal Endangered Species Act protections (i.e., de-­‐
listing) would be premature and short sighted and would likely result in the re-­‐listing of grizzlies in the not-­‐too-­‐distant future. This species remains fragile and continues to face many existing challenges as well as additional challenges in the future. The Yellowstone population of about 750 grizzlies already has lost two primary food sources. More important food sources could collapse as we experience increasing climate change. Because these changes in food sources cannot be predicted, we believe it would be prudent to continue protections until we are certain the bear can adapt and thrive under the most recent changes in food choices. Considered an “umbrella”1 species, grizzlies help maintain the dynamic equilibrium necessary for long-­‐term ecosystem health. Like other large carnivores, grizzlies cull the sick and weak of prey species, which results in healthy herds of elk and other animals. By moving these herds around, grizzlies help prevent over browsing of the vegetation on which other species rely. Without the presence of large carnivores, the fabric of an ecosystem begins to unravel, depriving important plants and animals of the habitat they need and the benefit they provide to other species. Without continued protections and a sound strategy to insure genetic diversity through linkages to other grizzly populations, we would likely be condemning the species to eventual extinction. Many credible scientists outside government — and not influenced by political pressure — believe much larger distinct populations and viable linkages between these populations are essential for overall long-­‐term survival. Numerous government grizzly bear conservation strategies and other plans repeatedly mention the importance of connectivity for the five individual populations in the Lower 48 states. In fact, the concept is enshrined in national policy. The Endangered Species Act makes clear that the goal of this policy is not just to prevent species extinction, but also to conserve as much of the grizzly’s historic range as possible. Grizzly bears naturally roam great distances to find food and mates. They should not be relegated to isolated geographic islands. It is our duty to do everything possible to insure that wide, connecting corridors between populations are kept as wild and free of human development as possible. Federal and state wildlife managers should agree on a plan that achieves and maintains a robust, connected population in the lower 48 states. To hunt this vulnerable species for sport while ignoring its needs and potential threats would violate the spirit of the ESA and abandon any concern for preserving an important part of the American heritage for future generations. Below are the reasons we oppose delisting at this time and insist on a sound plan that will ensure survival of this species in perpetuity and ensure that our children’s children have the same opportunity to view grizzlies that we do. 1993 recovery plan out of date • The US Fish and Wildlife Service 1993 grizzly recovery plan for the Lower 48 is outdated; science on grizzly bears and their habitat potential has evolved while the plan has not. The US Fish and Wildlife Service itself stated in 2011 that the plan “no longer reflects the best available and most up-­‐to-­‐date information on the biology of the species and its habitat.”2 It would be careless management and irresponsible to the American public to proceed with delisting and state management of the grizzly using old science. The FWS stated in its 1993 recovery plan that it would complete an assessment of linkage zones between populations, for example, but that has never been done. Not sharing information • The IGBST has not shared the science behind its claim that the bears will adapt following the loss of two critical food sources. Many expert scientists who should be selected to peer review the science have not been invited to do so. Peer review is employed “as a means of self-­‐
regulation by qualified members of a profession” and is employed to “maintain standards of quality, improve performance, and provide credibility”.3 Counting methods suspect The IGBST has changed the way they count living grizzlies as well as those that die each year. A shift in the area in which they were counted has resulted in fewer dead bears counted. The team also has increased the number of over flights used for counting the bears. Simultaneously, the IGBST has adopted a new statistical model that shows a larger population than historic annual counts revealed.45 Politics • The delisting process is largely politically driven. The history of government scientists and managers pressured by politicians to ignore the best available science is well documented and attested to by the many successful legal challenges to “government science” over the past few years.6 Given this history, and given the lack of transparency and peer review, we cannot trust that delisting is justified or that Wyoming will properly manage grizzlies with transparency and accountability. The IGBST needs to share its research and have it peer reviewed by respected, credible experts outside government agencies. Numbers will be reduced • Once management is turned over to the state, political pressure likely will result in grizzlies being managed to their lowest legal minimum, similar to the way wolves have been managed. The smallest legally allowable population, of probably 500,7 will be even more vulnerable to collapse should unforeseen circumstances such as loss of additional food sources occur. Grizzlies have one of the lowest reproductive rates of any terrestrial mammal in North America. Any of a variety of circumstances can put the population at risk and go undetected until it is too late for a small population to have the capacity to recover. Any management plan needs to build in a population buffer to insure population resilience. Population at maximum and not problematic • The Yellowstone grizzly population has stabilized at approximately 700, since it has fully occupied its limited island habitat. Any negative impact this population is causing now is as bad as it will get. Generally speaking, many of the negative effects caused by grizzlies can be prevented or are so minimal that they do not rise to a level where drastic action is needed. The lack of “acceptance” of this large carnivore originates primarily from hunters and hunting outfitters who see the bruin as competition for prey or as a nuisance to their business. The livestock industry also considers grizzlies a nuisance and a threat to their livelihood. Unfortunately, much of these fears and assumptions are false or exaggerated. Real potential problems can be addressed with preventative measures. In some cases, a truly problem bear can be removed. Programs are now in place to reimburse ranchers for their losses. Bear in mind that most visitors to Wyoming say they want to see a bear. These visitors contribute more to the state’s economy than ranching and hunting combined. The bears should be managed on public lands for the benefit of all of the public, and not solely for special business interests. Wolf management example • The state of Wyoming has not shown that it is capable of properly managing a species once it is removed from the protections of the Endangered Species Act. Its original wolf management plan, for example, was rejected by the USFWS as too hostile to the wolves, and not a plan that would protect them at secure numbers.8 The state plan eventually was approved, but a recent lawsuit forced wolves back under federal protections because of flaws in the state’s management plan. Careless management • The recent handling of Grand Teton National Park Grizzly 760, which was relocated after it wandered from the park and later euthanized, is an example of the careless management we can expect after delisting.9 The WGFD and representatives from the USFWS failed to follow their own guidelines for relocation and removal of this bear. If the WGFD was so cavalier in handling a species still under federal protection, how will the agency handle the bear when it loses those protections? Incidental takes • The arbitrary increase in “incidental takes,”10 or the number of grizzlies allowed to be killed in various areas of the GYE, without adequate scientific support, is another good indication of how future management will proceed. “Incidental take” as a regulatory mechanism has proven to be utterly toothless; when an incidental take limit is reached, a new higher incidental take is granted by the US Fish & Wildlife Service as a matter of course. This renders the whole incidental take process meaningless. Unless managers diligently support with full transparency their decisions for allowing an increase in these takes, we cannot trust that their decisions will be sound and safe for the grizzly. Genetic viability/Isolated populations • Yellowstone grizzlies are a genetically isolated population, which has experienced no genetic interchange with other populations for 100 years. Reducing or holding current numbers will concentrate the gene pool and doom it to eventual inbreeding and extinction.11 They should be protected at a higher population level to increase the potential for individual bears to connect and breed with bears that travel from other populations. Some experts contend that the Yellowstone population should be allowed to disperse beyond the current recovery zone and that the optimum population target should be 2,000 to insure genetic viability. Credible scientific experts contend that an interconnected population of 4,000 to 6,000 bears is necessary for long-­‐term viability across all six populations in the lower 48 states. Most bear biologists recognize the importance of expanding or maintaining “linkage zones” between isolated populations.12 The other closest grizzly recovery area, to which Yellowstone grizzlies can connect, the Selway-­‐Bitterroot area of Central Idaho, is 250 miles away. Unfortunately, the FWS has never followed through with a 2000 plan to reintroduce 25 grizzlies to that area.13 Biologists believe that habitat can support as many as 600 bears. Government biologists have suggested transporting bears from one population to another will ensure an adequate level of genetic diversity. We don’t believe this is the best way to maintain healthy populations and healthy, functioning ecosystems. Habitat fragmentation and development • Loss of important food sources, combined with habitat fragmentation and encroachment of human development will force bears to disperse as they adapt. When they disperse, we know conflicts with humans will be more likely. This will include encounters with panicked hunters as well as vehicles as they attempt to cross roads. Encroaching development at the urban interface will increase the likelihood of conflicts. Approximately 80 percent of grizzly deaths are the result of conflicts with humans.14 We need to preserve habitat by preventing development that threatens grizzly survival. Management agencies also should aggressively implement comprehensive conflict–prevention plans. They should include everything from highway crossing structures to quickly removing carcasses on ranches near developed areas to prevent attracting bears to those areas. These agencies also should begin the widespread use of bear dogs to chase bears from areas where they are likely to get into trouble and possibly killed as a result. Available habitat and potential population size • The vast majority of remaining bears are confined to the Greater Yellowstone and North Continental Divide ecosystems. Yet the other recovery areas identified in the FWS 1993 recovery plan are 50 percent larger than Greater Yellowstone and North Continental Divide combined. Across the northern Rockies, there is the potential to create an interconnected meta-­‐population that provides greater security for the species as a whole and a buffer against the projected adverse effects of climate change and nonnative species. Thousands of additional square miles of suitable habitat throughout the West can and should support grizzly bears.15 Loss of important food sources • Yellowstone grizzlies have almost completely lost two important food sources —cutthroat trout and whitebark pine nuts — in recent years as the climate warms.1617 These two food sources are of very high quality providing high levels of protein and fat and alternative foods are of lesser quality. While government scientists claim the bears can adapt, we have no conclusive proof that grizzlies have adapted to suitable substitutes or whether those food sources can be at risk of collapsing in the future as well. Adaptation can lead to greater risk of mortality for grizzlies as they venture farther in search of alternatives. They will cross more roads and come closer to development. One adaptation, a switch to more meat in their diet, raises the potential for increased conflict with humans, especially during hunting seasons.18 •Climate Change • Climate change played a large role in the loss of whitebark pine, as pine beetles and the disease blister rust were able to thrive in increasingly warmer temperatures. Climate change is likely to compromise and disrupt additional food sources as temperatures rise, placing the population in an even more precarious position.19 We should more carefully analyze the potential effects of climate change on plant and animal species in grizzly bear habitat. Healthy populations for healthy ecosystems • The presence of grizzly bears and other large carnivores on the landscape promote balanced, healthy ecosystems.20 As an “umbrella species” it is widely acknowledged that managing for a healthy grizzly population provides benefits to many plant and animal species overlapping the grizzlies habitat. Grizzlies, wolves, cougars and other large carnivores disperse prey species, prevent overgrazing and control the spread of disease through herds. With overgrazing comes loss of habitat for many species such as beaver and songbirds, which in turn provide benefits to other interconnected species. Grizzlies and other carnivores cull elk and other herds of the sick and weak, leaving herds healthier. As Chronic Wasting Disease spreads across the West, the role of grizzly bears in removing diseased animals from the population will become even more important. Carnivores such as grizzlies should be managed for this value and for their long-­‐term survival. 1
Noss, R.F., H.B. Quigley, M.G. Hornocker, T. Merrill, & P.C. Paquet (1996).
Conservation biology and carnivore conservation in the Rocky Mountains. Conservation Biology
10: 949 963.
2
U.S. Fish and Wildlife Service, Grizzly Bear Recovery Office, Missoula,
Montana, 2011, Grizzly bear 5-year review: Summary and evaluation.
3
Wikipedia, peer review defined,
http://en.wikipedia.org/wiki/Peer_review
4
Daniel Doak and Kerry Cutler, 2013, Re-Evaluating Evidence for Past
Trends and Predicted Dynamics of Yellowstone Grizzly Bears,
Conservation Letters, Vol. 7, Issue 3, p. 312
5
High Country News, 2013, “New study questions how Greater Yellowstone
bears are counted.”
6
Center for Biological Diversity, 2014, Petition for a Recovery Plan for the
Grizzly Bear Across Its Native Range in the Conterminous United States, p. 17
7
Interagency Conservation Strategy Team, 2007, Final Conservation
Strategy for the Grizzly Bear in the Greater Yellowstone Area, p. 26.
8
Wyoming Tribune Eagle, July 7, 2011
http://bit.ly/1chdfWX
9
Wyoming Wildlife Advocates, 2014, The Short Life and Unnecessary
Death of Grizzly 760
http://bit.ly/1N0b23l
10
http://www.fws.gov/ENDANGERED/permits/index.html
11
Haroldson, M. A., C. C. Schwartz, K. C. Kendall, K. A. Gunther, D. S.
Moody, K. Frey, & D. Paetkau (2010). Genetic analysis of individual origins
supports isolation of grizzly bears in the Greater Yellowstone Ecosystem. Ursus
21: 1–13.
12
Chris Servheen, John Waller, Per Sandstrom, 2001, Indentification and
Management of linkage zones for grizzly bears between the large blocks of
public land in Northern Rocky Mountains, University of California, Davis.
13
Chris Servheen, US Fish and Wildlife Service, 1996, Grizzly Bear
Recovery Plan Supplement: Bitterroot Ecosystem Recovery Plan Chapter.
14
Mattson, D. J., S. Herrero, R.G. Wright & C.M. Pease (1996a ). Designing
and managing protected areas for grizzly bears: How much is enough? Pages
133-164 in R.G. Wright, editor. National Parks and Protected Areas: Their Role
in Environmental Protection . Blackwell Science, Cambridge, Massachusetts.
15
Center for Biological Diversity, 2014, Petition for a Recovery Plan for the
Grizzly Bear Across its Native Range in the Conterminous United States, p. 11.
12. 13.
16
Romme, W.H., & M.G. Turner (1991). Implications of global climate
change for biogeographic patterns in the Greater Yellowstone Ecosystem.
Conservation Biology 5: 373-­‐ 386.
17
Yellowstone Lake, lake trout management
http://www.nps.gov/yell/planyourvisit/upload/fishar9-18.pdf
18
Interagency Grizzly Bear Study Team (2009). Yellowstone Grizzly Bear
Mortality and Conflict Reduction Report. Interagency Grizzly Bear Study Team,
Northern Rocky Mountain Science Center, Montana State University, Bozeman,
MT USA
19
Rocky Mountain Climate Organization and the Greater Yellowstone
Coalition, 2011, Greater Yellowstone in Peril; The Threats of Climate
Disruption, p. 24
20
Balanced ecosystem defined
http://bit.ly/1J3tsMg