I have hiked and backpacked all over the world including a number of our National Parks where grizzlies are found. I appreciate grizzly bears and have observed them in the wild. I live within a few miles of the North Cascades National Park. As a Ph.D. scientist, hiker/backpacker, and taxpayer I support the “no action alternative (status quo)” ostensibly being considered in the Grizzly Bear Restoration Plan/Environmental Impact Statement (Plan/EIS). “Restoration” of grizzlies to the North Cascades Ecosystem is meddling with Mother Nature, has no basis in either public demand or scientific validation, and is fraught with unintended consequences. Here are my opinions why: It sounds like the decision to do this has already been made. “What is the Purpose. The purpose of this Plan/EIS is to determine how to restore the grizzly bear to the North Cascades ecosystem (NCE)…” [emphasis is mine] Your Final Newsletter doesn’t say “if”, it jumps right ahead to “how”. Also in your Final Newsletter, “Objectives. Restore a grizzly bear population as part of the natural and cultural heritage of the North Cascades.” 1 Why are you wasting everyone’s time and taxpayer dollars with this public comment charade? It’s apparent that the decision has already been made and this request for comments is a facade. The “Plan” appears to be driven by government, not citizens/taxpayers. I am unaware of, and you do not report, any documented demand from citizens for this proposed Plan. It appears to me that the “consent of the governed” found in the Declaration of Independence has been ignored. “Don’t mess with Mother Nature”. I am a Ph.D. scientist, a “degree-carrying” biologist, and I’ve personally been involved with “ecology” since 1961. I am quite aware that “Mother Nature” has been adapting, changing, and otherwise dealing with changes since before humans walked the earth. Everything is dynamic and everything changes in natural systems. Humans, as a species, have changed ecological dynamics for other species just as other species have changed the dynamics for humans. That’s all part of the natural process. Artificially relocating grizzlies is not a natural process and will have demonstrable effects and unintended consequences. “It’s not nice to fool Mother Nature”. Just what does “restoration” mean? The term “restoration” implies returning to a previous time. To exactly what previous time are you returning and how was that particular time selected? Why was that undefined time better than any other time in history? There is no way to scientifically document one time being better than another which leaves ideology, not credible science, as the only criterion for selecting a time to which grizzlies should be “restored”. •“Concepts like stability and ecosystem are ambiguous and defined in contradictory ways. In fact there is no such thing as an integrated, equilibrial, homeostatic ecosystem: It is a myth.” (Soule and Lease1995)! 2 •“If there is no stable equilibrium, why bother to conserve? Protecting and restoring endangered species is unnecessary, species go extinct all the time. How do you restore ecosystems when you don’t know what to restore them to?” 2 •“the ecosystem concept assumes that the interactions and feedback loops necessary and sufficient to explain dynamics occur within the boundaries. The problem with this assumption is that the spatial distributions of the component populations may be much larger than the ecosystem boundaries. Indeed, even the home ranges of individuals may be larger than the ecosystem, particularly for predators.” 2 •“The ecosystem defined by a species list is almost always unstable because it rarely, if ever, recovers to the identical list of species.” 2 •“This may be the concept’s most serious limitation in dealing with stability. Natural selection is relegated to a background role causing component populations to optimize or maximize their share of resources.” 2 •“natural selection is assumed to operate slowly. Therefore, its dynamics can be assumed to be constant over the time scales relevant to ecosystem behavior. But the advantage gained may not outweigh the losses. Natural selection is the most powerful predictive theory available to ecology.” 2 •“The ecosystem concept typically considers human activities as external disturbances to the ecosystem.” 2 Effect on other (non-human) species. Grizzlies are, naturally, a top predator, a keystone species. Their “restoration” will begin a cascade of effects on other species that are already established in the NCE. •“grizzly bears represent a keystone predator, having a major influence on the entire ecosystem they inhabit.” 3 •“a grizzly population, through predation and scavenging upon elk, could influence secondary consumers such as coyotes. The same types of relationships would exist where grizzly predation upon salmon is significant (Shuman 1950; Gard 1971). More typically, however, the omnivorous food habits of the grizzly mean that its energy intake sources overlap with many other species. It functions as a browser, grazer, scavenger and predator.” 4 •“they are normally omnivores: their diets consist of both plants and animals. They have been known to prey on large mammals, when available, such as moose, elk, caribou, white-tailed deer, mule deer, bighorn sheep, bison, and even black bears;” 5 •“The relationship between grizzly bears and other predators is mostly one-sided; grizzly bears will approach feeding predators to steal their kill. In general, the other species will leave the carcasses for the bear to avoid competition or predation.” 6 •“Cougars generally give the bears a wide berth. Grizzlies have less competition with cougars than with other predators, such as coyotes, wolves, and other bears.” 6 •“Coyotes, foxes, and wolverines are generally regarded as pests to the grizzlies rather than competition, though they may compete for smaller prey, such as ground squirrels and rabbits.” 6 Grizzly/human interactions. •“Bear experts say more conflicts are an ironic outcome of the steady recovery of the species.” ‘Conflicts are a natural result of the increasing number of bears; the two go hand in hand,’ said Chris Servheen, grizzly recovery coordinator for the U.S. Fish and Wildlife Service.” “And scientists say those conflicts will climb as grizzlies venture into areas that made up their historic habitat.” 8 [emphasis is mine] •“But the omnivorous grizzly ultimately competes with omnivorous man” 4 •“Adverse conditioning of bears is expensive and time-consuming.” 6 •Grizzly bear-human conflicts rise in Wyoming in 2014. “Brian DeBolt, the large-carnivore conflict coordinator for the agency's wildlife division, told the state Game and Fish Commission on Thursday that grizzly bears continue to expand their range. ‘They've far exceeded the expected geographic recovery distribution,"’DeBolt said.” 6 •“The possibility that some old grizzly bears under special circumstances may be potential predators of man is also suggested by the data.” 4 [emphasis is mine] •“The Wyoming Game and Fish Department says it documented more problems with grizzly bears last year compared to the year before.” 6 •“Grizzly bears are no pushovers. They're some of the biggest, strongest, most adaptable omnivores alive, with no natural predators except people.” 9 •“grizzly bears are actively selecting areas where they face an increased risk of coming into conflict with humans.” 8 How many grizzly-caused human deaths and injuries are acceptable to the Park Service? •“The predominant activity preceding a grizzly attack on a human was back-country hiking and riding followed by camping.” 10 Aren’t those precisely the major types of activities engaged in by visitors to North Cascades National Park? 4 •“A grizzly thought to be protecting its cub attacked seven backpackers earlier this month in a remote part of Alaska, one of several recent assaults to make international headlines. Grizzlies also killed two people near Yellowstone last year, and Wyoming's human-grizzly conflicts hit a record of 251 in 2010. ("Conflicts" include attacks on property, livestock and humans.) Not only is that high for one state, but it's 76 percent above average for the entire Greater Yellowstone Ecosystem (GYE), which normally has about 142 conflicts a year. And the problem is expected to get worse.” 9 The concept of “ecosystem” is not understood by grizzlies. Or by government. •“The simple fact is that the ecosystem is not an a posteriori, empirical observation about nature. The ecosystem concept is a paradigm (sensu Kuhn 1962), an a priori intellectual structure, a specific way of looking at nature. The paradigm emphasizes and focuses on some properties of nature, while ignoring and de-emphasizing others.” 2 •“The ecosystem concept is a paradigm, i.e., a convenient approach to organizing thought. Like any paradigm, it is a product of the human mind’s limited ability to understand the complexity of the real world.” 2 •‘‘The classical paradigm in ecology, with its emphasis on the stable state, its suggestion of natural systems as closed and self-regulating, and its resonance with the nonscientific idea of balance of nature, can no longer serve as an adequate foundation for conservation.’’ 2 Actually, it’s no picnic for the grizzlies, either. •“This Wyoming statute requires that, when a grizzly bear is relocated, that the department must notify the sheriff and issue a press release to the media and sheriff. The press release must provide the date and location of the relocation, and the number of bears to be relocated.” •“Relocation is not the ‘silver bullet’ to resolving human-bear conflicts. Although it seems to be favoured by bear control agencies and the general public, current research suggests that adult bears almost always return to their former ranges and generally do so within a month, regardless of the distance they are moved.” 10 •“Relocation is a reactive, public appeasement strategy and does not address the root cause of human-bear conflicts. As such, another bear frequently takes the place of the one that has been removed.” 10 •“Relocated bears seldom live happily ever after.” 11 The “Plan” Conflicts with Revised Code of Washington 77.12.035. RCW 77.12.035 expressly states, "Grizzly bears shall not be transplanted or introduced into the state. Only grizzly bears that are native to Washington state [sic] may be utilized by the department for management programs.” Grizzly restoration will cause temporary or permanent closure of NCE areas. •“Temporary trail closure or public warnings may need to be employed, or mode of access may need to be regulated. Trail re-routing away from prime grizzly bear habitat may be desirable in some instances. Where re-routing is not practical wide trail cuts may be a partial solution in areas where surprise encounters might take place. Campgrounds located in grizzly bear habitat either require special management or they should be closed. Special grizzly bear preserve areas may be necessary in some cases, with the public seasonally excluded.” 4 Such closures will be a deterrent for people to visit the NCE. Isn’t the idea to attract people to visit? Increased NCE operating costs. Certainly, increased liability on the part of the government must be considered when grizzlies are artificially put in closer approximation due to the proposed recovery Plan. To attempt to prevent adverse grizzly bear-human conflicts, a major education program will be required. Again, to diminish potential adverse grizzly-human conflicts increased monitoring, and, possibly, additional rangers may be required. Campgrounds will need to be modified and monitored. Trail closings/reroutings will become frequent in order to reduce adverse grizzly-human conflicts. All of this will greatly increase the operating costs for the NCE and, therefore, expenditure of taxpayer dollars. Much to my surprise, bears apparently do not understand or utilize the anthropogenic measures often taken “in their best interests”: •“In light of these issues, conservation plans often include migration corridors by way of long strips of "park forest" to connect less developed areas, or by way of tunnels and overpasses over busy roads.[126] Using GPS collar tracking, scientists can study whether or not these efforts are actually making a positive contribution towards resolving the problem.[127] To date, most corridors are found to be infrequently used.” 5 Potential for decreased visitors to NCE. If potential visitors to the NCE become afraid or concerned about grizzly bear-human conflicts they may react by choosing not to visit the Park. If restrictions are placed on camping, like requiring campers and trailers instead of tents, as some parks have done, potential visitors may chose to go elsewhere. If personal safety requires hiking in groups of 5-6, instead of solo or 2, many hikers may chose to do their hiking in some other park – there are certainly many to choose from in the northwest corner of Washington State and lower British Columbia. •“And some areas in national parks and forests will require campers and trailers instead of tents, a policy that stems from a deadly campground attack last summer.” 7 •Traveling in groups of six or more can significantly reduce the chance of bear-related injuries while hiking in bear country. 5 What is the “worst case scenario” ? What if we don’t “restore” grizzlies to NCE ? What is the worst thing that could possibly happen ? Extirpation or extinction ? Extremely doubtful given the huge number of grizzlies in Alaska. No; we just wouldn’t have very many (maybe none) grizzlies in NCE. Endangered species ? •This comeback already convinced U.S. officials to "delist" grizzly bears from the endangered species list in 2007, and although U.S. District Judge Donald Molloy later ordered them relisted, the Obama administration is now pushing to have grizzlies delisted once again. "We don't think there was any basis for the decision he made overturning that," Servheen says of Molloy's 2009 ruling. "So that's why we're appealing that decision. The bears are recovered." 9 There are 30,000 grizzlies in Alaska, 16,000 in British Columbia, and 1,500 in the lower 48. (wiki). Grizzlies are not endangered or at risk of extirpation or extinction just because some don’t think there are “enough” grizzlies in the Northern Cascades. SUMMARY: As a Ph.D. scientist, hiker/backpacker, and taxpayer I support the “no action alternative (status quo)” ostensibly being considered in the Grizzly Bear Restoration Plan/Environmental Impact Statement (Plan/EIS). “Restoration” of grizzlies to the North Cascades Ecosystem is meddling with Mother Nature, has no basis in either public demand or scientific validation, and is fraught with unintended consequences. References: ! Final Newsletter North Cascades Ecosystem Grizzly Bear Restoration Plan/Environmental Impact Statement 2 Is it time to bury the ecosystem concept ? Robert V. O’Neill, Ecology 82(12), 2001 3275-3284 3 Peek, J.; Beecham, J.; Garshelis, D.; Messier, F.; Miller, S. & Dale, S. (2003). "Management of Grizzly Bears in British Columbia:4 A Review by and Independent Scientific Panel" 4 Conflicts between Man and Grizzly Bears in the National Parks of North America, Stephen Herrero, Third International Conference on Bears Paper 12 5 Wikipedia 6 Grizzly bear-human conflicts increase in Wyoming in 2014 (trib.com 22 Jan 15 Bob Moen 7 Business and Financial News, Reuters.com 18 Jan 11, L Zuckerman 8 Grizzly bears, roads, and humans, Joseph Northrup, Colorado State University Master’s Thesis 9 Are grizzly bears becoming unbearable? Russell McLendon, 25 July 2011 Mother Nature Network 10 Relocation. Get Bear Smart Society. 11 Living with bears, Linda Masterson, 2006
June 8, 2015