Mountain-Prairie Region

Grizzly Bear Recovery in the Bitterroot Ecosystem

Final Environmental Impact Statement

March 2000

Chapter 5

Additional Comments and Responses That Provide a Sample of Public Comment

Following are 18 letters from the most prominent or most vocal large private organizations representing the diverse points of view and concerns about the proposal and the Draft Environmental Impact Statement. The letters are responded to in detail as representative examples across the whole spectrum of the commentary and issues raised by the public at large on both sides of the issue.

Private Organization, Friends of the Bitterroot: Letter #22 (1 800 Kb PDF format)

1. Comment noted.

2. The preferred alternative does not preclude linkage areas. In fact, the linkage zone analysis between all ecosystems is a separate task under the grizzly bear recovery plan that will be completed with or without Bitterroot grizzly restoration. The linkage zone analysis will identify the areas where it is possible for bears to move between ecosystems and will outline strategies to maintain such opportunities.

By any measure, the restoration of a grizzly bear population in an area of 5,785 square miles of wilderness and additional thousands of square miles of adjacent public lands increases habitat size and extent for grizzly bears. The majority of grizzly bear habitat in the lower 48 states is not in wilderness areas but on other public lands. Extensive limits currently exist on public lands on activities such as road building and timber harvest due to issues on anadromous fish and elk management. These constraints serve to enhance the value of these lands to grizzly bears as well.

Experimental status does not preclude linkage with other ecosystems, it requires that there be no population of the animal in question present and that the area be geographically separated. The Bitterroot qualifies for experimental status for grizzly bears on both counts. If the Bitterroot is eventually linked to other existing populations, which is desirable and so stated in the Grizzly Bear Recovery Plan, such linkage may be in fact initiated by the members of the Bitterroot population expanding their range toward the closest population, the Cabinet-Yaak population, not the other way around. If that happened, then experimental status would be reevaluated. However, given the fact that none of the more than 550 grizzly bears that have been radio-collared and tracked over the past 23 years have ever moved between any existing ecosystems, the likelihood of such linkage is not a near-term possibility. Thus, placement of bears in the Bitterroot now will allow this population to begin to grow into a healthy population now, rather than waiting for the possible future dispersal of bears from distant geographically separated ecosystems.

3. The proposal to restore grizzly bears to the Bitterroot Ecosystem complies with this treaty and all its intentions.

4. The USFWS was not "forced by the courts" to work on habitat-based criteria for the grizzly bear. The development of habitat criteria is a task in the Grizzly Bear Recovery Plan (task 423) and work on this task has been ongoing for many years. The core area of the Bitterroot recovery is the largest block of wilderness in the Rocky Mountains. This is the area of recovery emphasis. Surrounding public lands make up significant additional habitat that can support grizzly bears and currently supports other species of importance such as wolves and wolverines. Given this, the USFWS believes there is significant habitat available in this area to support a recovered grizzly population. The numerous and varied opinions expressed at the Bozeman habitat workshop were all considered.

5. This is not true. The recovery area is the area of recovery emphasis, not the area where recovery will be confined. Alternative 1 directs the CMC to make management recommendations to accommodate grizzly bears on public lands within the experimental area. The term "accommodate" means grizzly bears that move outside the recovery area onto public land in the experimental area will not be disturbed unless they demonstrate a real and imminent threat to human safety or livestock.

Grizzly bears outside the recovery area will be counted toward the recovery goal if there is reasonable certainty of their long-term occupancy in such habitats outside the recovery area. Also, any revised recovery goal will be established using the best available data based on the habitat available in the recovery area. Additional adjacent areas of public land may be considered for contribution of suitable habitat when the CMC revises the tentative recovery goal, if it is shown to be necessary by the best scientific and commercial data available. Any recommendations for revised recovery goals developed by the CMC would require public review and USFWS approval as appropriate for any revision of any recovery plan.

6. We have available to us the road and trail database that the land management agencies have. The USFWS is not in a position to redo these data layers. Concerns about motorized use of trails or high use roads and how these are represented on the data base of the land management agencies should be taken up with the land management agencies themselves.

7. This area is not "dropped" from the preferred alternative. See answer #5. Several habitat analyses have been added to this Final EIS (Appendix 21) and include areas both within and adjacent to the recovery area (including the area north of the Lochsa River and into the North Fork of the Clearwater River drainage).

8. This is not a grizzly bear issue.

9. The use of experimental status allows more management flexibility, yet grizzly bears are not the only issue that determines land management decisions in the Bitterroot. Extensive limits currently exist on activities such as road building and timber harvest due to issues on anadromous fish, water quality, and elk management. These constraints serve to enhance the value of these lands to grizzly bears as well.

10. This is untrue. There is no "documentation of a radio-collared bear moving south and establishing a den in the Salmon-Selway". Nor is there any documentation that "a small population of grizzlies inhabits the recovery area". See FEIS Appendix 4.

11. See answer # 2.

12. Bears in the experimental population in the Bitterroot would be fully protected against illegal killing under federal law under the ESA. Grizzly bears could only be killed in the Bitterroot in self defense or defense of others (as in all fully listed populations), or, in the special circumstance on private land where a depredating bear was unable to be captured by state or federal management officials, a permit could be issued to that landowner to kill that bear. Otherwise killing of bears in the experimental Bitterroot population is illegal and would be prosecuted under federal law.

13. While there my be "persistent reports" there is no documented evidence of even a single grizzly bear in the experimental area defined in Alternative 1. No grizzly bear researchers have provided any documentation whatsoever of any grizzly bears in the Bitterroot experimental area. A letter from Wayne Melquist clarifying the statements made in Melquist (1985) and Groves (1987) is Appendix 23 in this FEIS. This letter clarifies that no documented grizzly bear observations were or are available to substantiate the presence of even a single grizzly bear in the experimental area. The USFWS would welcome documentation of grizzly bears in the experimental area, but despite continual efforts to obtain such documentation and follow-ups on reports of bears, no documentation of any grizzly bears is available in the proposed experimental area. The commentor seems to interpret the work of Kunkel and Servheen (1991) that, since they could not confirm the absence of grizzly bears, this means they confirmed the presence of grizzly bears. This is illogical. We would welcome documentation of grizzly bear presence in the Bitterroot. We have no such documentation and the commentor produces none.

14. The evaluation of the success of the effort will require continued monitoring of marked bears in the restored population. The USFWS will work with scientists to further evaluate these issues in coordination with the CMC. Evaluation of success is a long-term effort. The initial evaluation effort would occur 10 years after the reintroduction, as a start in process of monitoring success of the project.

15. Agree. The sentence referred to has been deleted.

16. Wording has been added to Alternative 1 relating to nomination of CMC members. It states that governors must include with their nominations, written documentation of the qualifications of those nominees relating to their knowledge of and experience in a variety of natural resource issues and relating to their commitment to collaborative decision making.

To include scientific input in the CMC process, wording has been added to Alternative 1 to add 2 non-agency scientific advisors to the CMC who will attend all meetings and provide scientific data on which to make decisions.

The CMC decisions, management plans and their implementation must lead to grizzly bear recovery. If there is concern over CMC actions leading to recovery, a Scientific Review Panel could be invoked to review CMC actions and decisions and make recommendations as to whether CMC actions, decisions, or processes are in compliance with the Special Rule and are leading to recovery. If the Secretary decides to resume management implementation responsibility, he/she must consult with the Governors of Idaho and Montana before taking action. Under the Endangered Species Act, the Secretary of Interior must retain final authority and responsibility for implementation of the Act. See Chapter 2, Alternative 1 for further information.

17. The CMC would not have authority over public land management decisions. Such decisions are the purview of the National Forests and the processes and public involvement of these forests. The CMC could make recommendations to land and wildlife management agencies regarding changes to plans/policies, but the final decision on implementation of those recommendations would be made by those agencies. If the CMC recommendations would require significant changes to existing plans and policy, and the agencies tentatively agree to accept those recommendations, then the requirements of NEPA could apply.

Most public lands outside wilderness areas within the experimental area are currently subject to the concept of multiple use per NFMA and other national laws and policies. Such multiple use management is supposed to address the needs of both wildlife and human needs to the exclusion of neither, as per NFMA. Decisions about new roads or land developments on public lands are made by the public land management agencies. The CMC does not have authority to "approve or disprove" such decisions. The management of public lands in and around the recovery area is the purview of the public land management agencies, not the CMC.

18. The YE population is increasing and has been so for the last 6-8 years. In the last 3 years in the Yellowstone ecosystem, 204 cubs have been known to be born while 18 bears have been known to die due to human causes. This difference between births and deaths is why this population is increasing. No bears will be removed from any ecosystem in the U.S. if the mortality limits for that ecosystem have been reached or are even close to being reached. In addition, the USFWS will agree to make the decision to remove bears from any ecosystem in Montana or Wyoming only in consultation with the Fish and Game Department of that state. The USFWS has no intentions to allow the removal of grizzly bears from any ecosystems in the U.S. to impede recovery of those source populations. The USFWS will work in concert with the Fish and Game Departments of those states to judge these possible impacts to assure that this is the case.

Contribution of bears from either the YE or NCDE will be based on the current mortality levels for that ecosystem. Mortality data are updated annually and any removal of bears from either ecosystem will be predicated on achievement of the mortality limits. Since these data are updated each year, it is necessary to recalculate mortality levels for both the NCDE and YE prior to making a decision on the origin of any relocated bears. The specific number of grizzly bears that can be obtained from the NCDE or YE is unknown at this time. The female contribution will be designed to minimize impacts on the source population and no female grizzly bears will be removed from within the NCDE or YE recovery zone boundary or from within 10 miles outside the boundary. The male contribution can be a higher number because population increase is affected little by removal of subadult males. Since no bears will be removed from the YE or NCDE if the mortality limits will be exceeded, and no female bears will be removed from within the recovery zone or within 10 miles of the recovery zone boundary of either ecosystem, then the effects on recovery of any removals of bears from the NCDE or YE will be nonexistent. See Chapter 4, Alternative 1 for the analysis of impacts to source populations.

Any bears removed from Canadian populations would be removed under the management constraints on Canadian grizzly bear management which limit human-caused mortalities. We fully support those constraints.

The use of listed members of a species to create an experimental population of that species in a currently unoccupied area is what was intended by Congress in the amendments adding the 10(j) experimental population opportunity (See FEIS Appendix 12). Thus, experimental populations of California condors, blackfooted ferrets, and Mexican wolves have all used animals from listed populations as founders.

19. The wording on "surplus bears" is removed. See answer #18.

20. Disagree. Given that the nearest grizzly population to the Bitterroot experimental area is approximately 40 miles away in the Cabinet Mountains, and that data from more than 550 different radio-collared grizzly bears since 1975 shows no movement between any ecosystems, it is highly unlikely that such movement would occur into the Bitterroot from an area currently occupied by grizzly bears. The identification of linkage zones which will occur under the recovery plan does not mean grizzly bears will use such zones. In contrast to wolves, grizzly bears do not disperse much. In the long-term, the opportunity for bears to move between these ecosystems will improve the health of these populations. In the near term, recovery of a grizzly bear population in the Bitterroot will require placement of bears rather than waiting for eventual dispersal into this area, due to the limited distances of movements of bears outside of existing range to date. The preferred alternative does not preclude movement between systems. It is promoted because the likelihood of natural movement into the Bitterroot in the near term is highly improbable.

21. Existing forest plans are deemed adequate for recovery of the Bitterroot population with recovery emphasized in the 5785 square mile wilderness block as the core of this area.

22. Disagree. This is the best available estimate on the impact of Alternative 4 on timber harvest based on information from the forest that has been the leader in implementation of access management.

23. The discussion of the economic effect of land use restrictions on timber harvest and of road reclamation work is found on pages 4-68 through 4-74 of the FEIS. This discussion attempts to place broad-range estimates of costs, benefits, and job loss and creation on the Alternative 4 actions. It is clear from the discussion and Table 4-16 that a great deal of uncertainty exists as to the short-term employment effects of the Alternative 4 actions. What the Alternative 4 discussion attempts to do is to fairly present the broad range of possible outcomes from Alternative 4 in the form of annual impacts. To do this we relied on the work of Garrity (1996), Power (1992), and information from the USFS. The estimates presented included consideration of changing timber harvest/employment ratios. It should be noted that the discussion of this alternative states that the long-term economic impacts of Alternative 4 may "be significantly more positive than the short-term employment estimates" presented in the document.

24. This number is based on the size of the area proposed for occupancy in Alternative 4 and the expected average density in this area based on best available estimates of expected density.

25. The discussion of how the estimate of potential losses associated with restrictions on black bear hunting were arrived at are found on pages 4-66 and 4-68 of the FEIS. Also noted on these pages is that such losses are dependent on actions being taken by Idaho Department of Fish and Game.

26. Comment noted.

27. Perhaps the best way to answer the question of whether anticipated timber harvest restrictions and habitat restoration activities under Alternative 4 will significantly impact the economies of the local recovery area is to compare the anticipated net employment impacts to the population of the recovery area counties. It is anticipated that the Alternative 4 actions would result in a net annual job decrease over 10 years of between 117 and 1,136 jobs. In the context of an area with a population of roughly 250,000, this job loss likely represents a trivial to small impact on the area economy. Of course, the job impacts, both positive and negative, are unlikely to be distributed evenly throughout the area. Therefore, some localities may benefit or suffer disproportionately from the job impacts. Overall, however, the employment impacts estimated for Alternative 4 are unlikely to seriously impact the economy of the 14-county analysis area.

28. Disagree. The expected values are based on the best available data and estimates of predation rates. The commentor suggests no better method than that used in the DEIS.

29. A viable population is one that has an acceptable probability of survival. Given real world issues, the probability of survival for a population has nothing to do with theoretical genetic issues (no wild population of any animal has ever been documented to go extinct because of genetic problems) and everything to do with the quality and effort of management to address the needs of that population in a responsive and dynamic manner. We believe that the estimates of viability will have to continuously be upgraded based on the best available science and data and that the population will have to be carefully monitored in the future as recovery proceeds to assure that management meets the needs of the bears.

30. The clause that the commentor finds hints at this relationship has been removed.

31. Comment noted but we disagree. The atmosphere at the Salmon, Idaho public hearing was charged, but people holding all views were able to testify.

Private Organizations, Defenders of Wildlife, Resource Organization on Timber Supply, National Wildlife Federation, Intermountain Forest Industry Association: Letter #42

1. Agree. We cannot formally ask Canada for bears until a decision on an alternative has been made. Any bears removed from Canadian populations would be removed under the management constraints on Canadian grizzly bear management which limit human-caused mortalities. We fully support those constraints.

2. Agree.

3. The DEIS and FEIS present information on the expected time to recovery with the introduction of 25 bears. The number of bears chosen for reintroduction in the preferred alternative was a balance between the availability of bears, the ability to capture and relocate a given number of bears each year, and the time to reach recovered population status. While we agree that it would be desirable to place more bears each year both from the standpoint of a higher probability for success and a shorter time to recovery, we do not think it is possible to capture and relocate more than approximately 5-6 bears per year and the availability or more bears than that in any single year is also limited. Thus, we believe that the numbers selected in the preferred alternative will achieve recovery while establishing a target number of bears that can be relocated over the 5-year placement period. Obviously, the more bears placed in the Bitterroot, the greater the population size and the greater the chance for success, but there are limits on how many bears could be obtained. The "minimum of 25" statement allows replacement of bears that may die soon after placement. It allows placement of more than 25 bears should such mortalities occur.

4. The letters from the Director of the USFWS to Governor Racicot of Montana regarding funding are added as FEIS Appendix 24.

5. Agree. A Scientific Review Panel has been added to Alternative 1 (preferred alternative) to judge the effectiveness of the CMC

6. Agree. Such wording has been added to Alternative 1 (preferred alternative).

7. The discussion of the estimation of existence values has been expanded and reorganized in the Final EIS to address the concerns of the relationship between the estimated existence values and money spent in the local communities, and the questions of the validity and usefulness of the value estimates.

Impacts associated with grizzly bear reintroduction in the BE can be measured using different accounting frameworks. The one which perhaps most people are familiar with relates to expenditures; how much more or less money is spent in an area as a result of a management change. Expenditure changes are rightfully of concern to local areas impacted by management actions. Changes in local expenditures impact local workers, businesses, and governments. From a national perspective, however, expenditure gains in one area tend to be offset by expenditure losses in another. Expenditure impacts (particularly from tourism) are largely distributional impacts, benefitting one area at the expense of another. A second accounting framework, a benefit-cost framework, measures not expenditures, but societal benefits and costs. Benefits and costs can be closely, or loosely tied to actual market transactions. In the case of grizzly bear reintroduction, livestock losses are closely tied to market transactions while existence values are less obviously tied to the market.

It is important not to confuse these two accounting frameworks. The estimated annual existence value associated with grizzly reintroduction as reported in the EIS would NOT be characterized by increased expenditures in the recovery area. Rather, these estimates represent aggregate increases in value to people in the U.S. accruing as a result of grizzly reintroduction. A portion (but only a very small portion) of this non-market value would accrue to residents of the local area surrounding the recovery area.

Another concern raised in your letter questions the validity and usefulness of the existence value estimates. While the use of contingent valuation methods to estimate passive use values associated with proposed management changes is not a perfect tool, it is the only accepted tool currently available to economists to measure these types of non-use values. The general approach of using contingent valuation to measure passive-use values has been subject to a court test in a challenge to the 1986 DOI CERCLA regulations (Ohio v. DOI, 880 F.2d 432,474 (D.C. Circuit 1989)). Additionally, in 1992 the National Oceanic and Atmospheric Administration (NOAA) appointed a distinguished panel (including several Nobel laureates in economics) to evaluate the approach in the context of implementing the Oil Pollution Act of 1990. In both instances the method has been judged to be a useful tool for valuation in the context of litigation. For example, the NOAA panel concluded that: "CV studies can produce estimates reliable enough to be the starting point of a judicial process of damage assessment, including lost passive-use values" (Arrow et. al. 1993). It is clear from the above statement that passive-use value estimation using contingent valuation does not produce an irrefutably accurate estimate of value, nor is it claimed to. Rather, the method employed in the EIS provides a rough approximation of the existence value associated with grizzly reintroduction.

8. Appendix 21 on habitat evaluation results has been added to the Final EIS.

Private Organization, Craighead Wildlife-Wildlands Institute: Letter # 48

1. Thank you for your comment.

2. Thank you for your comment.

3. Appendix 21 provides additional information regarding habitat quality in the BE.

4. Thank you for your comment.

5. A linkage zone analysis is currently ongoing and will determine the opportunities for connections from other ecosystems to the Bitterroot. This analysis and report is expected to be completed in 2000. Furthermore Alternative 1 states that linkage zones to the Bitterroot could be considered from management of other ecosystems. Any grizzly bears entering the experimental area from another ecosystem would be considered experimental, though this occurrence is not considered likely and is addressed in Alternative 2 No Action - Natural Recovery. See page 5-86, Friends of the Bitterroot letter #22 response, issue #2, for more information.

6. The answer to this question will be based on the Scientific Review Panel approach added to the FEIS to review CMC progress and provide recommendations to the Secretary as to whether CMC actions and decisions are leading to recovery. All steps within this process must be completed in a timely manner. See Chapter 2, Alternative 1 for more information. We are unable to predict the likelihood of lawsuits or the time associated with court decisions associated with such lawsuits

7. Thank you for your comment.

8. Thank you for your comment.

Private Organization, Idaho Conservation League: Letter #102

1. Thank you for your comments.

2. See page 5-119, Friends of the Bitterroot letter #22 response, issue #2, for more information.

3. The USFWS believes adequate, quality habitat exists in Central Idaho to currently support a viable grizzly bear population. The USFWS has reviewed current land management plans via Section 7 consultation and has determined that current habitat management is sufficient. Future changes in habitat and agency land management plans will be reviewed for adequacy by the Citizen Management Committee. Future changes in the Recovery Plan will be made as appropriate.

4. The USFWS believes the Citizen Management Committee (as modified in this FEIS in response to public comment) oversight will be adequate.

5. Thank you for your comment. The final proposal incorporates your suggestion.

6. Thank you for your comment.

7. The CMC has been modified in this FEIS, taking your suggestion into consideration.

8. The current Recovery Plan for the Bitterroot Ecosystem was developed and written by the agencies you suggested. The Service approved this chapter in September, 1996. Suggested initial goals for the CMC are presented in this FEIS (Chapter 2, Alternative 1).

The CMC may recommend refined interim recovery goals for the Bitterroot Chapter of the Grizzly Bear Recovery Plan and a final recovery goal when sufficient information is available. Sufficient information is currently not available to develop a scientifically sound final recovery goal. As this information becomes available, the CMC may recommend the recovery goal to the Secretary of the Interior and procedures for determining how this goal will be measured. The recovery goal for the Bitterroot grizzly bear population would be consistent with the habitat available within the Recovery Area. Additional adjacent areas of public land may be considered for contribution of suitable habitat when setting the recovery goal if it is shown to be necessary by the best scientific and commercial data available. Any recommendations for revised recovery goals developed by the CMC would require public review and USFWS approval as appropriate for any revision of any recovery plan. Grizzly bears outside the Recovery Area and within the Experimental Area would contribute to meeting the recovery goal if there is reasonable certainty of their long-term occupancy in such habitats outside the Recovery Area.

9. This grizzly bear reintroduction proposal is not a land management allocation decision. This is not within the authority of the USFWS, and not within the scope of this FEIS. See Chapter 1, page 1-12, "Scope of this FEIS."

10. Grizzly bear conservation requires continuing outreach work. The USFWS expects this ongoing information/education need to be addressed and implemented via the CMC. The FEIS has been modified to include a proactive information and education program under the preferred alternative. The first year of Alternative 1 implementation would be focused on outreach, sanitation, and I&E activities.

Private Organization, The Wildlife Society: Letter #111

1. Comment noted. Two additional alternatives have been added in this FEIS.

2. The wording of Alternative 1 has been modified to add two non-agency scientific advisors to the CMC to assure scientific involvement and to provide the CMC with he best available information to make decisions.

3. Management of nuisance bears is envisioned to be similar to the existing management system used in other ecosystems. Bears in the experimental population in the Bitterroot would be fully protected against illegal killing under federal law under the ESA. Grizzly bears could only be killed in the Bitterroot in self defense or defense of others (as in all fully listed populations), or, in the special circumstance on private land where a depredating bear was unable to be captured by state or federal management officials, a permit could be issued to that landowner to kill that bear. Otherwise killing of bears in the experimental Bitterroot population is illegal and would be prosecuted under federal law.

4. Agree. The linkage zone analysis is proceeding and will be completed in 2000. A metapopulation analysis completed for the FEIS is included as Appendix 21C.

5. Agree. The health of donor populations is important as well as the genetic diversity of the donor animals. We will work with scientists to further evaluate these issues in coordination with the CMC.

6. Agree. The evaluation of the success of the effort will require continued monitoring of marked bears in the restored populations. We will work with scientists to further evaluate these issues in coordination with the CMC.

7. Agree. The evaluation of release sites will be done.

8. Agree. The recovery goal will be evaluated in the future by the CMC based on the best available science as stated in Alternative 1, Chapter 2.

9. Agree. Additional habitat evaluations are presented in Appendix 21 of this FEIS.

10. Agree. Careful measures of success and progress are necessary. Such measures of success will be one of the tasks of the CMC with close involvement of the scientific advisors to the CMC. Public review of these measures for success will be available, and we welcome the input of the scientific community in this review.

Private Organization, The Wilderness Society: Letter #112 (4 0 4 K b P D F f o r m a t)

1. and 2. Thank you for your comment, however the agency is not forbidden from fostering connections from other populations to this experimental population in the future. A linkage zone analysis is currently ongoing and will determine the opportunities for connections from other ecosystems to the Bitterroot. This analysis and report is expected to be completed in 2000. Any grizzly bears entering the experimental area from another ecosystem would be considered experimental, though this occurrence is not considered likely and is addressed in Alternative 2 No Action - Natural Recovery.

3. Thank you for your comment.

4. Thank you for your comment. Any alternative chosen will continue to seek involvement in grizzly bear management from the state fish and game departments and the Nez Perce Tribe

5. Thank you for your comment.

6. Road density within the Bitterroot Evaluation Area is described in Appendix 10. Outside of the wilderness portion there was 1,225 square miles of habitat. Open road densities on these lands range from 0.08-0.7 miles per square mile and restricted roads range from 0.01-0.38 miles per square mile. Road management emphasis associated with elk and fisheries (bull trout and pacific salmon) management is expected to limit the growth of road density near existing levels. Road densities in that range were not judged to be detrimental to bear occupation of those areas.

7. Alternative 4 "Restoration of Grizzly Bears as a Threatened Population with Full Protection of the ESA and Habitat Restoration," describes an extensive amount of road reclamation. This alternative was modeled after the Alliance for the Wild Rockies proposal. The Magruder corridor road was designated for closure to secure the core of the population and reduce the mortality risk to bears by eliminating the only motorized transportation route between the Selway-Bitterroot and Frank Church Wilderness Areas.

8. An extensive information and education effort associated with sanitation is part of all alternatives involving reintroduction of grizzly bears. Under Alternatives 1, 1A, and 4A, these efforts would begin one year in advance of any bear releases in the Selway-Bitterroot Wilderness. Efforts would be directed at back country and front country users of bear habitat. Funding is included for upgrading garbage handling facilities to wildlife resistant containers.

Private Organization, Montana Stockgrowers Association: Letter #118 (4 3 5 K b P D F f o r m a t)

1. Thank you for your comment. Additional habitat analyses are presented in Appendix 21 of the Final EIS.

2. Current human population data from all affected counties in Idaho and Montana is displayed in Chapter 3 of the EIS. Bears are not expected to inhabit the more densely populated areas of the Bitterroot Valley (Ravalli County) and bears frequenting highly populated areas will be removed. Though Ravalli county is one of the more heavily populated counties within the principal analysis area, about half of it's 2,400 square miles lie within the 25,140 square mile experimental area.

Under Alternative 1, unless the CMC determines otherwise, private lands outside the national forest boundary in the Bitterroot Valley, Montana are an area where any human/grizzly conflicts would be considered unacceptable. Grizzly bear occupancy would be discouraged in these areas and grizzly bears would be captured and returned to the Recovery Area. If a grizzly bear enters this area, state and federal wildlife management agencies would attempt to capture it immediately and notify the public of its presence as soon as possible. The public would be updated until the bear is caught. Further, any grizzly bear that occupies inhabited human settlement areas on private land within the Experimental Area that in the judgement of the management agencies or CMC presents a clear threat to human safety or where there is indication that it may become habituated to humans, may be relocated by management agencies.

3. The data referred to in your comment are documented conflict situations in the Northern Continental Divide and Yellowstone Ecosystems. This data has been updated in the FEIS. This is the best information available to assess the potential impacts associated with nuisance bear situations on private property in the BE if bears are reintroduced there.

4. Thank you for your comment. The Bitterroot area supported grizzly bears, wolves, mountain lions, and numerous other predators prior to the extermination of wolves and grizzly bears by humans because of livestock concerns during the early 1900's. Predators and prey coexisted in the Bitterroot area for thousands of years prior to predator extermination. There are numerous places in Canada and Alaska where an identical or similar mix of predators and prey coexist. Further habitat examinations have been undertaken and are displayed in FEIS Appendix 21.

5. Grizzly bears exist in many other areas such as the Selkirk Mountains of northern Idaho and southern British Columbia, the Cabinet Mountains of northwest Montana, and the Purcell Mountains of northwest Montana and southern British Columbia without whitebark pine or salmon fisheries. Grizzly bear populations in the Northern Continental Divide and Yellowstone exist without salmon fisheries and appear to be expanding in areas where whitebark pine has declined similar to the Bitterroot. These items could enhance grizzly bear foraging opportunities and in places where

pine stands occur bears are expected to feed on the nut crops. The figures cited for traditional grizzly bear food sources apply to food items consumed by grizzly bears throughout the U.S. and southern British Columbia. The fact that the Bitterroot area contains 60-80% of these items indicates the richness and diversity of the habitat for grizzly bears. See Appendix 21D.

6. Thank you for your comment. Bears that would be transplanted to the Bitterroot would likely be younger animals that have most of their reproductive life ahead of them yet and are more adaptable to setting up a home range in a new area. Bears may be obtained from British Columbia and from the U.S. The removal of males from either the Yellowstone or the Northern Continental Divide has the least potential for affecting either of those populations.

7. Thank you for your comment. Bears will be released in the Selway-Bitterroot Wilderness about 30 airline miles from the Bitterroot Valley in Montana. The Selway-Bitterroot and Frank Church Wilderness areas contain over 5,700 square miles of unoccupied habitat for bears and surrounding lands offer an additional 18,000 to 20,000 square miles of public land in the form of National Forest and Bureau of Land Management administered lands.

8. Thank you for your comment. Annual costs for the first 5 years are estimated to be $433,632 with $193,000 per year in monitoring and management costs.

Private Organization, Alliance for the Wild Rockies: Letter #120 (1 5 1 5 K b P D F f o r m a t)

1. The Bitterroot area is 40 miles from the nearest grizzly population in the Cabinet Mountains. This is "wholly separate". The sightings provided by USFWS are not in the Bitterroot experimental area as defined in Alternative 1 and therefore do not invalidate experimental status. While there may be "persistent reports" there is no documented evidence of even a single grizzly bear in the experimental area defined in Alternative 1. No grizzly bear researchers have provided any documentation whatsoever of any grizzly bears in the Bitterroot experimental area. A letter from Wayne Melquist clarifying the statements made in Melquist (1985) and Groves (1987) is in Appendix 23. This letter clarifies that no documented grizzly bear observations were or are available to substantiate the presence of even a single grizzly bear in the experimental area. The USFWS would welcome documentation of grizzly bears in the experimental area, but despite continual efforts to obtain such documentation and follow-ups on reports of bears, no documentation of any grizzly bears is available in the proposed experimental area.

2. The experimental designation is supported by the USFWS because the reintroduction of grizzly bears into the Bitterroot would increase the probability of maintaining health grizzly populations south of Canada, but it is not essential to maintaining such healthy populations.

3. A metapopulation analysis that addresses this issue is presented in FEIS Appendix 21C.

4. Given that the nearest grizzly population to the Bitterroot experimental area is approximately 40 miles away in the Cabinet Mountains, and that data from more than 550 different radio-collared grizzly bears since 1975 shows no movement between any ecosystems, it is highly unlikely that such movement would occur into the Bitterroot from an area currently occupied by grizzly bears.

5. Further analysis of impacts to source populations has been added to FEIS Chapter 4. Any removals from either the NCDE or YE populations would only be done if such removals would be within the mortality limits for that ecosystem. We disagree with the premise that removals of bears for recovery of a Bitterroot population that would increase the probability of overall grizzly recovery should be viewed the same as removal of bears due to mortality related to a development plan. Nonetheless, any removals will be counted against the human-caused mortality quota for the source ecosystem and no removals would take place if this quota was reached or even close to being reached.

6. Agree with most of this statement except the "takings" section. Bears in the experimental population in the Bitterroot would be fully protected against illegal killing under federal law under the ESA. Grizzly bears could only be killed in the Bitterroot in self defense or defense of others (as in all fully listed populations), or, in the special circumstance on private land where a depredating bear was unable to be captured by state or federal management officials, a permit could be issued to that landowner to kill that bear. Otherwise killing of bears in the experimental Bitterroot population is illegal and would be prosecuted under federal law.

7. A detailed habitat analysis both inside and outside the wilderness areas is presented in Appendices 21(A, B, C, D) in this FEIS. The suitability of the area south of the Salmon River is also addressed separately in these appendices. The reader is referred to these appendices for a full review of this information. While the recovery area is the area of initial placement of bears and of recovery emphasis, grizzly bear occupancy of adjacent public lands outside the wilderness is expected and the CMC is directed to make recommendations to accommodate grizzly bear presence on these lands. Thus, recovery and occupancy is not solely confined to the recovery area. See Alternative 1, Chapter 2 and Friends of Bitterroot letter (#22) response #5, page 5-120.

8. The tentative recovery goal is to be reevaluated by the CMC using the best available science. Any revised recovery goal will be established using the best available data based on the habitat in the recovery area. Additional adjacent areas of public land may be considered for contribution of suitable habitat when the CMC revises the tentative recovery goal, if it is shown to be necessary by the best scientific and commercial data available. Any recommendations for revised recovery goals developed by the CMC would require public review and USFWS approval as appropriate for any revision of any recovery plan.

9. The wording on "surplus bears" is removed. The Yellowstone population is increasing and has been so for the last 6-8 years. In the last 3 years in the Yellowstone ecosystem, 204 cubs have been known to be born while 18 bears have been known to die due to human causes. This difference between births and deaths is why this population is increasing.

No bears will be removed from any ecosystem in the U.S. if the mortality limits for that ecosystem have been reached or are even close to being reached. In addition, the USFWS will agree to make the decision to remove bears from any ecosystem in Montana or Wyoming only in consultation with the Fish and Game Department of that state. The USFWS has no intentions to allow the removal of grizzly bears from any ecosystems in the U.S. to impede recovery of those source populations. The USFWS will work in concert with the Fish and Game Departments of those states to judge these possible impacts to assure that this is the case.

Contribution of bears from either the YE or NCDE will be based on the current mortality levels for that ecosystem. Mortality data are updated annually and any removal of bears from either ecosystem will be predicated on achievement of the mortality limits. Since these data are updated each year, it is necessary to recalculate mortality levels for both the NCDE and YE prior to making a decision on the origin of any relocated bears. The specific number of grizzly bears that can be obtained from the NCDE or YE is unknown at this time. The female contribution will be designed to minimize impacts on the source population and no female grizzly bears will be removed from within the NCDE or YE recovery zone boundary or from within 10 miles outside the boundary. The male contribution can be a higher number because population increase is affected little by removal of subadult males. Since no bears will be removed from the YE or NCDE if the mortality limits will be exceeded, and no female bears will be removed from within the recovery zone or within 10 miles of the recovery zone boundary of either ecosystem, then the effects on recovery of any removals of bears from the NCDE or YE will be nonexistent. See Chapter 4, Alternative 1 for the analysis of impacts to source populations.

Any bears removed from Canadian populations would be removed under the management constraints on Canadian grizzly bear management which limit human-caused mortalities. We fully support those constraints.

10. The use of listed members of a species to create an experimental population of that species in a currently unoccupied area is what was intended by Congress in the amendments adding the 10(j) experimental population opportunity (See FEIS Appendix 12). Thus, experimental populations of California condors, blackfooted ferrets, and Mexican wolves have all used animals from listed populations as founders.

11. The statement concerning genetic diversity of the Yellowstone population in relation to the NCDE population is incorrect. The USFWS intends to complete a linkage zone analysis that will detail the possible linkage areas between the existing ecosystems and between the Bitterroot and existing ecosystems. The linkage zone analysis is a GIS-computer modeling effort that looks at the levels of human impact and activity in the intervening areas between ecosystems and identifies the best linkage areas based on this human activity. This linkage zone analysis is a separate Recovery Plan Task and will be completed regardless of which alternative is selected for the Bitterroot.

Maintenance of linkage zones retains the opportunity for grizzly bears and other wildlife species to move between the existing large blocks of public lands in order to maintain demographic and genetic health. In the long-term, the opportunity for bears to move between these ecosystems will improve the health of these populations. In the near term, recovery of a grizzly bear population in the Bitterroot will require placement of bears rather than waiting for eventual dispersal into this area, due to the limited distances of movements of bears outside of existing range to date. The preferred alternative does not preclude movement between systems. It is promoted because the likelihood of natural movement into the Bitterroot Ecosystem in the near term is highly improbable.

12. Same as #11. We are unaware of a scientifically credible method to predict the probability of movement from populations approximately 40 miles away into and occupancy of presently unoccupied habitats where forest roads have been closed. The issues of "corridors" are addressed in #4 and #11 above.

13. We do not state that the NCDE is growing at an 8% growth rate. This rate is used as an example of the result of such a rate of change. The variance in the expected rate of population growth is wide due to the multiple factors that can influence such change. The examples in the DEIS are just that, examples. As monitoring of the restored population continues, it may be possible to improve these projections on rates of growth. Such efforts will be accomplished as these monitoring data are gathered. To further speculate on future growth rates would only serve to increase uncertainly and we see no need to do so.

14. The wording of the Final Special Rule involving Alternative 1 and the CMC will be consistent with all federal laws and regulations.

15. The DEIS contained alternatives including a wide range of actions consistent with mandate of NEPA and with the comments received during the scoping process. Two additional alternatives have been added to the FEIS.

16. Wording has been added to Alternative 1 regarding the nomination of CMC members. It states that the governor's nominations must include written documentation of the qualifications of those members relating to their knowledge of and experience in a variety of natural resource issues and relating to their commitment to collaborative decision making. To include scientific input in the CMC process, wording has been added to Alternative 1 to have two non-agency scientific advisors to the CMC who will attend all meetings and provide scientific data on which to make decisions.

17. There is much to agree with in this statement. Timber worker productivity has increased dramatically, and the economic base of the region has in general shifted away from resource extraction industries. The analysis of Alternative 4 (pages 4-68 - 4-74), however, deals more narrowly with the somewhat offsetting employment impacts of timber reductions and habitat restoration. We feel that given the large range of uncertainty about future BE timber harvests, we have estimated a reasonable range of possible timber related job losses for the next 10 years. The DEIS notes on page 4-71 that these losses may decline or disappear beyond the 10 year period examined here. Regarding the temporary nature of the habitat restoration jobs, these jobs are described as temporary to be consistent with the assumptions detailed by Garrity (1996). Finally, regarding the potential flaws and unreliability of willingness-to-pay models, notwithstanding any shortcomings, contingent valuation willingness-to-pay models remain the only tool available to economists with which to measure passive-use, or existence values.

18. We agree that careful measures of success and progress are necessary. Such measures of success will be one of the tasks of the CMC with close involvement of the scientific advisors to the CMC. Since there are agency members on the CMC including USFWS, USFS, Nez Perce Tribe, and Montana and Idaho Fish and Game Department members, this will involve significant input and review.

19. We disagree. The alternatives present a wide range of actions as required by NEPA. None of the alternatives are "illegal". See Elmore County Commissioners, #3, page 5-52.

20. Comment noted. The requested additions will not be added as the description of Alternative 4 is sufficient to represent the intent of the Alternative.

21. Comment noted. Th e requested additions will not be added as the description of Alternative 4 is sufficient to represent the intent of the alternative.

22. Garrity (1996) analyzed the economic impact of the alternative proposed by the Alliance for the Wild Rockies (1996), and his conclusions are documented in the 1996 report produced by the Alliance. The economic analysis presented in the DEIS and FEIS for Alternative 4 differs in many aspects from the Garrity (1996) analysis and results.

23. Comment noted and declined since sufficient explanation about the minimal impact of removal of bears from the Northern Continental Divide or Yellowstone Ecosystem, and the cautions that would be used prior to any such removals are already present in the FEIS. See answer to issue #9 above. The requested additions will not be added as the description of Alternative 4 is sufficient to represent the intent of the alternative.

Private Organization, International Association for Bear Research and Management: Letter #476

1. Agree. Wording in Alternative 1 has been changed to require the appointment of two non-agency scientists as advisors to the CMC. These scientific advisors will attend all meetings and will serve to assure that scientific viewpoints are available to the CMC and that the best available science is presented to the CMC on all issues they deal with.

2. The recovery area is the area for initial placement of bears and is the area where recovery emphasis will take place initially. This means that outreach and education efforts with wilderness users will be focused in the recovery area initially. We expect that the population of grizzly bears will be centered in the recovery area and will expand from there as the population grows in future years. There are several appendices added to this FEIS addressing habitat capability in both the recovery area and the surrounding public lands (See Appendices 21A, B, C, D). The CMC is charged with making recommendation to accommodate grizzly bears on public lands outside the recovery area, such as the North Fork of the Clearwater, and we expect grizzly bears will occupy this area as the population expands.

Private Organization, United Paperworkers International Union: Letter #501

1. Thank you for your comments. The USFWS also believes the preferred alternative (Alternative 1) offers the best assurance of both restoring and conserving the grizzly bear, and protecting the lives and jobs of the people who live within and outside of the Bitterroot Ecosystem. We feel strongly that grizzly bear recovery in the Bitterroot Ecosystem can only be accomplished with the support of local residents and users of the BE.

Private Organization, Idaho Outfitters and Guides Association: Letter #559

1. Management of water based recreation would be guided by the Cooperative Grizzly Management Committee. Recreationists in areas occupied by grizzly bears do use bear resistant containers for storing bear attractants such as food. River recreation outfitting successfully takes place in other grizzly occupied habitat such as on the Flathead River in the Glacier National Park vicinity. Although a rare event, sometimes a trail or use area is closed to human use when occupied by a female grizzly with her cubs.

2. The possible additional costs to packers and hikers of reintroduction are discussed in general on page 4-22 of the FEIS.

3. The FEIS states that no changes in black bear hunting are anticipated, but that the CMC could recommend changes if the CMC believes that such changes are necessary to achieve recovery. The Fish and Game Departments in both Idaho and Montana would make decisions and implement any changes. This allows the CMC to be responsive to threats to grizzly bear recovery such as excessive grizzly bear mortality by black bear hunters. We do not believe it is desirable nor necessary to so proscribe CMC management direction by stating they cannot make such a recommendation should they think it necessary.

4. Comment noted. Hundreds of guided and unguided families use occupied grizzly bear habitat in the Northern Rockies and Yellowstone Ecosystem. Special safety procedures enhance a safe and enjoyable wilderness experience. Guide and outfitters in the above areas have considerable experience safely guiding the public in bear country.

5. Thank you for your comments. Committee members would be recommended by respective state governors. We would expect IOGA to work through your governor to assure your industry is adequately represented.

Private Organization, Blue Ribbon Coalition: Letter #611 (2 4 1 K b P D F f o r m a t)

1. The CMC would develop recommendations on existing management plans and policies of land and game management agencies, as necessary, for the management of grizzly bears in the Experimental Area. The CMC could make recommendations to these management agencies regarding changes to plans/policies, but the final decision on implementation of those recommendations would be made by those agencies. If the CMC recommendations require significant changes to existing plans and policy, and the agencies tentatively agree to accept those recommendations, then the requirements of NEPA could apply.

2. The discussion of the estimation of existence values has been expanded and reorganized in the Final EIS to address the concerns of the relationship between the estimated existence values and money spent in the local communities, and the questions of the validity and usefulness of the value estimates.

Additionally, the survey instrument used in the analysis of existence values is attached as an appendix to the final document (Appendix 17A). In addition to these changes in the Final EIS the following comments are offered to address concerns raised about the existence value estimates. Impacts associated with grizzly reintroduction in the BE can be measured using different accounting frameworks. The one which perhaps most people are familiar with relates to expenditures; how much more or less money is spent in an area as a result of a management change. Expenditure changes are rightfully of concern to local areas impacted by management actions. Changes in local expenditures impact local workers, businesses, and governments. From a national perspective, however, expenditure gains in one area tend to be offset by expenditure losses in another. Expenditure impacts (particularly from tourism) are largely distributional impacts, benefitting one area at the expense of another.

A second accounting framework, a benefit-cost framework, measures not expenditures, but societal benefits and costs. Benefits and costs can be closely, or loosely tied to actual market transactions. In the case of grizzly reintroduction, livestock losses are closely tied to market transactions while existence values are less obviously tied to the market. It is important not to confuse these two accounting frameworks. The estimated annual existence value associated with grizzly reintroduction as reported in the DEIS would NOT be characterized by increased expenditures in the recovery area. Rather, these estimates represent aggregate increases in value to people in the U.S. accruing as a result of grizzly reintroduction. A portion (but only a very small portion) of this non-market value would accrue to residents of the local area surrounding the recovery area.

Some DEIS respondents also questioned the validity and usefulness of the existence value estimates. While the use of contingent valuation methods to estimate passive use values associated with proposed management changes is not a perfect tool, it is the only accepted tool currently available to economists to measure these types of non-use values.

3. Thank you for your comments.

Private Organization, Concerned About Grizzlies: Letter #753 (4 2 2 K b P DF format)

1. Under the Endangered Species Act, the Secretary of Interior must retain final authority and responsibility for implementation of the Act. Based on public comment, Alternative 1 has been modified to include provisions to further facilitate the functioning of the CMC, and allow for citizen management to proceed without undue influence from the Secretary of Interior.

If the USFWS representative on the CMC has concerns that CMC actions are not leading to recovery and are not in compliance with the Special Rule, he/she would provide the CMC corrective actions and a 6-month time-frame to accomplish those actions, and would consider CMC input before making a determination that CMC actions are not leading to recovery. If that determination is made, the USFWS representative would convene a Scientific Review Panel to review CMC actions and decisions and make recommendations to the CMC as to whether CMC actions, decisions, or processes are in compliance with the Special Rule and are leading to recovery. This panel of 3 would be appointed by the Secretary, Governor of Idaho, and Governor of Montana. If the CMC rejects the recommendations, and the USFWS representative determines CMC actions are not leading to recovery, he/she would notify the Secretary of Interior. The Secretary would use these recommendations to determine whether to resume lead management responsibility. Further, if the Secretary decides to resume lead management responsibility, he/she would first consult with the Governors of Idaho and Montana to attempt to resolve discrepancies between his/her alternatives and the actions of the CMC. See Chapter 2, Alternative 1 for more information.

2. Figure 1-1, page 1-8 of the FEIS is a Regional Perspective showing the Bitterroot Grizzly Bear Primary Analysis Area. There is not an area known as the management area. On page 2-9 of the FEIS, Figure 2-1 is the Bitterroot Grizzly Bear Experimental Population Area and Recovery Area for Alternative 1. Part of Ravalli County would be within the Experimental Population Area.

3. The DEIS in no way indicates that citizens are second to the grizzly bear. Under the Endangered Species Act, humans that act in self defense or defense of others would be allowed to kill a grizzly bear. Under Interagency Grizzly Bear Committee guidelines (IGBC 1986), grizzly bears posing problems to camps, cabins, individuals and stock may be relocated or removed.

4. Unless the CMC determines otherwise, private lands outside the National Forest boundary in the Bitterroot Valley (private lands lying within the experimental population area and outside the Bitterroot Forest boundary south of US highway 12 to Lost Trail Pass) would be an area where any human/grizzly bear conflicts would be considered significant. Grizzly bear occupancy would be discouraged in these areas and grizzly bears would be captured, destroyed, or returned to the recovery area. If a grizzly bear enters the exclusion area, State and Federal wildlife management agencies would attempt to capture it immediately and notify the public of its presence as soon as possible. The public would be updated until the bear is caught. The purpose of this is to ensure that grizzly bears do not move onto the private lands in the Bitterroot Valley, Montana, where human conflict potential would be high.

5. There is no area identified in the FEIS as a suggested management area. There is an area entitled the Bitterroot Grizzly Bear Experimental Population Area which is bounded on the east by Highway 93. Grizzly bear occupancy outside the Bitterroot National Forest Boundary south of Highway 12 to Lost Trail Pass would be discouraged in these areas and grizzly bears would be captured, destroyed or returned to the recovery area.

6. Three different habitat studies were conducted in the Bitterroot Ecosystem from 1979 through 1991 (Scaggs 1979, Butterfield and Almack 1985, Davis and Butterfield 1991). See Appendix 3. The authors suggested, using an established set of criteria (Craighead et al. 1982), that habitat in the Bitterroot Evaluation Area (BEA) was sufficient to support grizzly bears. An interagency group of grizzly bear scientists reviewed the information and concurred, suggesting that the BEA could support between 200 and 400 bears (Servheen et al. 1991). Further research indicates habitats in the BE are capable of supporting a viable population of grizzly bears (Appendix 21).

Elevations in the center of the Selway-Bitterroot Wilderness are much lower than elevations in the Bitterroot Valley. Moose Creek Ranger Station is 2400 feet opposed to Hamilton, Montana which is at 3200 feet. Where Lewis and Clark encountered and killed grizzly bears in 1806 was near present day Kamiah, Idaho, which is at an elevation of 1100 feet.

The grizzly bear inhabited the Bitterroot Ecosystem in healthy numbers until a major influx of hunters, trappers and settlers at the turn of the century, and later sheepherders, were responsible for direct mortality and elimination of grizzly bears in the BE.

7. Grizzly bears would be at the top of the food chain in the BE. Elk, moose and deer have co-existed with grizzly bears for thousands of years and grizzly bears have little effect on ungulate reproduction.

8. The grizzly bear's absence from the BE has created an ecosystem that is not naturally balanced. Return of the grizzly bear to the BE would result in a more balanced ecosystem. Black bears will not become more confined, but likely more dispersed as a result of a grizzly bear population in the BE.

9. The annual net economic value of recovery listed in Table 4-7 of the FEIS are the values that potential visitors place on grizzly bears. There are two components to this value. There is a value associated with seeing grizzly bears in the wild. The other value is called a "passive use value" or "existence value." Existence value is the value a person associates with the knowledge that a resource exists, even if that person has no plans or expectations of ever directly using that resource (Krutilla 1967). See response to Blue Ribbon Coalition letter # 611, issue #2 for more information on the results and methodology of the economic analysis.

10. The CMC "would be responsible for recommending changes in land use standards and guidelines," not making decisions (FEIS Chapter 2). Recreation impacts in the form of permanent trail closures within the wilderness would likely not occur. Temporary closure of trails may occur in response to a dangerous situation that might result in human injury or bear mortality. Some roads that are open and presently exceeding densities recommended for fish and wildlife management purposes outside the wilderness could also be closed, but not solely for the grizzly bear.

11. Executive order 12630 of March 15, 1988 entitled "Governmental Action and Interference with Constitutionally Protected Property Rights," Section 1(b) states, "Responsible fiscal management and fundamental principles of good government require that government decision-makers evaluate carefully the effect of their administrative, regulatory and legislative actions on constitutionally protected property rights." Section 2 states, "Policies that have taking implications does not include: (4) Studies or similar efforts or planning activities."

12. Section 4 of Public Law 88-577 is a provision of the Wilderness Act of 1964. This FEIS does not affect jurisdiction of any state. This FEIS is being carried out under the authority of the ESA of 1973.

13. Grizzly bears would be released in areas of central Idaho that have low densities of livestock. The analysis on pages 4-9 to 4-11 results in an estimated loss of 4-8 cattle and 5-44 sheep annually when the grizzly bear population numbers 280.

Private Organization, Idaho Wildlife Federation: Letter #754

1. Thank you for your comments.

2. Point noted and we agree that adequate funding is necessary and should be supplied to the states so that can participate in the recovery effort. See USDA Forest Service, letter #763, #4, 5-76.

3. The CMC has been modified in this final proposal and incorporates your concern. A Scientific Review Panel has been added for oversight. See Concerned about Grizzlies, letter #753, #1, page 5-153; and Chapter 2, page 2-5 for details.

4. The USFWS expects the CMC to operate openly and with public involvement. The FEIS has been modified to include an increased level of public involvement in CMC processes. See Custer County Commissioners, letter #2167, #1, page 5-61.

5. Thank you for your comments.

Private Organization, Idaho Farm Bureau Federation: Letter #826

1. Further reviews of habitat capability in the Bitterroot Ecosystem have been made and are included in the FEIS. See Appendix 21.

2. See NMFS Biological Opinion, Appendix 9B. Grizzly Bear Recovery will not conflict with salmon or steelhead recovery.

3. Thank you for your comment.

4. The discussion of the estimation of existence values has been expanded and reorganized in the Final EIS to address the concerns of the relationship between the estimated existence values and money spent in the local communities, and the questions of the validity and usefulness of the value estimates. Additionally, the survey instrument used in the analysis of existence values is attached as an appendix to the final document (Appendix 17A). In addition to these changes in the Final EIS, the following comments are offered to address concerns raised about the existence value estimates.

Impacts associated with grizzly reintroduction in the BE can be measured using different accounting frameworks. The one which perhaps most people are familiar with relates to expenditures; how much more or less money is spent in an area as a result of a management change. Expenditure changes are rightfully of concern to local areas impacted by management actions. Changes in local expenditures impact local workers, businesses, and governments. From a national perspective, however, expenditure gains in one area tend to be offset by expenditure losses in another. Expenditure impacts (particularly from tourism) are largely distributional impacts, benefitting one area at the expense of another.

A second accounting framework, a benefit-cost framework, measures not expenditures, but societal benefits and costs. Benefits and costs can be closely, or loosely tied to actual market transactions. In the case of grizzly reintroduction, livestock losses are closely tied to market transactions while existence values are less obviously tied to the market.

It is important not to confuse these two accounting frameworks. The estimated annual existence value associated with grizzly reintroduction as reported in the DEIS would NOT be characterized by increased expenditures in the recovery area. Rather, these estimates represent aggregate increases in value to people in the U.S. accruing as a result of grizzly reintroduction. A portion (but only a very small portion) of this non-market value would accrue to residents of the local area surrounding the recovery area.

Some DEIS respondents also questioned the validity and usefulness of the existence value estimates. While the use of contingent valuation methods to estimate passive use values associated with proposed management changes is not a perfect tool, it is the only accepted tool currently available to economists to measure these types of non-use values.

5. Any proposals for land use restriction would be considered by the Citizen Management Committee, and undergo public involvement.

Private Organization, Idaho Cattle Association: Letter #865

1. Thank you for your comments.

Private Organization, Water Cooperative Bitterroot Valley, MT: Letter #913

1. Thank you for your comment. The preferred alternative would not place any additional restrictions on access to the National Forest because of grizzly bear reintroduction. Risk of injury related to grizzly bears would increase with reintroduction, but rates of injury would be extremely low possibly in the range of 1:100 million visitor days. See Appendix 11 for more information on Risks to Human Safety.

2. Thank you for your comment. Grizzly bears can be delisted by grizzly bear recovery ecosystem. The Yellowstone ecosystem is closest to meeting recovery goals set by the grizzly bear recovery plan and this will likely be the first area proposed for delisting. When that process is completed, grizzly bear management will reside with the individual states.

Private Organization, The Ursid Research Center: Letter #1305

1. The USFWS has reviewed all of the available data on grizzly bear sightings in the Bitterroot Ecosystem. The last verified death of a grizzly bear in the Bitterroot Ecosystem occurred in 1932 and the last tracks were observed in 1946. Although occasional unverified reports of grizzly bear sightings persist in the BE, no verified tracks or sightings have been documented in more than 50 years. Based on the best scientific evidence available, and the lack of verified evidence for more than 50 years, there appears to be no grizzly bears in the BE at this time.

The USFWS, with the assistance of its agency partners, continues to review reports of grizzly sightings in the BE. A few public comments on the DEIS questioned the USFWS interpretation of some sighting reports, and the conclusion there are currently no grizzly bears in the BE. The EIS Team reviewed the historical sighting records and all literature pertaining to grizzly bear presence in the BE. Based on this review, follow-up inquiries made to individuals who reported sightings, and inquiries made to those respondents who indicated they had knowledge of grizzly bear presence in the BE (including yourself), the EIS Team retained its conclusion there is no verified evidence of grizzly bears in the BE at this time. If the USFWS receives verified evidence of grizzly bear presence in the BE, we will review/revise management plans at that time.

2. The DEIS and FEIS recognize there is a gradient of habitat quality in the BE from the drier southern habitats south of the Salmon River to the more mesic maritime climate-influenced habitats north of the Selway-Bitterroot Wilderness. The entire ecosystem provides suitable grizzly bear habitat, and the varying habitat quality will simply manifest itself is varying densities of grizzly bears. Under Alternative 1, the 25,140 square-mile Experimental Area surrounding the Recovery Area includes the richer northern habitats in the BE, and will be managed to accommodate grizzly bears.

The issues of recovery area size and habitat adequacy for grizzly bear recovery were listed as concerns in many comment letters received on the DEIS. Due to these concerns, the USFWS contracted a Habitat Capability Analysis for the Bitterroot Ecosystem. The results of this analysis have been incorporated in the FEIS, and are located in Appendix 21.

3. Alternative 1 establishes a rigorous procedure for selection of members for the Citizen Management Committee. The members must represent a cross-section of interests reflecting a balance of viewpoints, and be committed to collaborative decision making. The CMC is charged with making decisions based upon the best scientific and commercial data available. And all decisions of the CMC including components of its management plans must lead toward recovery of the grizzly bear. Based on public comment on the DEIS, the FEIS has been modified to include a review process by an independent Scientific Review Panel to monitor progress and functioning of the CMC for the Secretary of Interior. See Concerned about Grizzlies, letter #753, #1, page 5-153; and Chapter 2, page 2-5 for details.

4. Regarding linkage zone habitat protection, even if Alternative 1 is selected and implemented, the USFWS is not forbidden from fostering connections from other grizzly bear populations to the Bitterroot nonessential experimental population in the future. A linkage zone analysis is currently ongoing and will determine the opportunities for connections from other ecosystems to the Bitterroot Ecosystem. The Grizzly Bear Recovery Plan describes this analysis of linkage areas that may potentially connect some or all of the recovery zones. This Geographic Information System-based analysis will evaluate various types of information on land use, human activity, topography, vegetation, and other factors that may influence linkage. Completion of this assessment is expected in 2000. This analysis is independent of the NEPA process for the Bitterroot EIS.

5. The USFWS is open to and encourages the input of independent bear researchers. Much of the information in this EIS is derived from such research. Based on similar comments received on the DEIS, the FEIS adds 2 scientists appointed by the Idaho and Montana Chapters of The Wildlife Society as advisors to the CMC.

6. Thank you for your comment.