November 8, 2023
North Cascades National Park Service Complex
810 State Route 20
Sedro Woolley, WA 98284
Subject: Draft Grizzly Bear Restoration Management Plan
Dear Superintendent Striker:
I write on behalf of more than 2,500 members of the Coalition to Protect America’s National Parks (Coalition), who collectively represent some 45,000 years of national park management experience. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. Among our members are former NPS directors, regional directors, superintendents, resource specialists, park rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.
Our members and supporters appreciate the long history of grizzly bears in the Pacific Northwest and controversies over whether and how to return that species, listed as threatened under the Endangered Species Act (ESA), after its being functionally extirpated for decades. Many of our members have had previous experience in North Cascades, as well other parks where grizzly bears remain, such as Glacier, Grand Teton and, like you, Yellowstone National Parks. We are familiar with the considerable challenges associated with living in bear country and with the perpetual commitment that is needed to manage the animals and humans for the safety of both.
Yet we respect that National Park Service Management Policies outline the affirmative responsibility “to strive to recover all species native to national park system units that are listed under the Endangered Species Act…and both proactively conserve listed species and prevent detrimental effects on these species.” The North Cascades Ecosystem grizzly bear recovery area, as noted in the draft plan, has sufficient habitat to support a viable reproducing population, although it has lacked verified sightings of the species for thirty years or more.
We support the plan’s preferred alternative C, which would reintroduce a small number of grizzly bears over five to ten years under Section 10(j) of the ESA, which permits flexibility for managing a ‘non-essential, experimental population’ to address conflicts such as may occur over livestock grazing, timber harvest, and mining operations. The inclusion of maps showing where those activities occur near the proposed restoration area are especially helpful. Alternatives B and C both take care to address concerns for wilderness values, nesting birds, and other species that could be affected by aircraft noise or other disturbance needed to accomplish restoration and associated monitoring. The ongoing commitment to no net loss of grizzly bear habitat and steps already taken to enhance campers’ safety, such as the placement of bear-resistant food storage boxes, will help ensure low levels of human-bear conflicts. Importantly, alternative C would permit proactive relocations of bears to prevent conflicts or habituation of the animals to human presence and activities and to address livestock depredations. Experience in other grizzly bear-occupied ecosystems demonstrates that this option can be vital in securing tolerance, if not support, for bear recovery in balance with maintaining other public and private values. We also appreciate that, after certain conditions are met, the plan calls for adaptive management, and that robust discussions with cooperators, park neighbors, the State of Washington, and Tribes have occurred and will continue.
We offer a few comments for you to consider in a final plan. Future success of the program may require consistent food storage orders across North Cascades National Park and the adjacent national forests; we encourage adaptive determination of dates for which such orders apply, even though a June 1-November 15 time period may be sufficient under current conditions. Based on experience on other parks, some of our members, suggest that the cost estimates for implementation listed in Table C-1 are conservative, especially with regard to annual costs for sanitation. The cost of bear-resistant food storage boxes, trash cans, and dumpsters have risen considerably in recent years, and it is unclear whether costs for shipping and installation are included. Also, even though costs are anticipated to be ‘project-based,’ such equipment requires cyclic maintenance and repair, which should be included, as should funds needed to ensure that concession and administrative facilities are bear-resistant through such means as fencing off trash or recycling areas and sewage lagoons, if they exist.
In several places, the plan references the 1986 Interagency Grizzly Bear Guidelines, which have provided a tested framework for managers in other grizzly bear-occupied ecosystems to determine management actions for nuisance bears and bear-human conflicts. We support the use of the Guidelines, but we suggest that managers and the public would benefit from clarity on how your proposed ‘Management Zones 1-3,’ defined on page 36, would relate to their application. The proposed Management Zones are clearly of larger scale, although there is some similarity in the definition of Management Zone 1 and the IGBC Guidelines’ Management Situation 1, as both refer to areas where bear recovery is of primary concern. Since management options outlined in the Guidelines often depend on where a conflict or nuisance bear occurs in ‘Management Situations 1-5,’ we infer that areas within each Management Zone would be further divided into Management Situations (such as park developed areas, which would likely fall into Situation 3). If the proponents have had or anticipate discussions with the U.S. Fish and Wildlife Service as to specifically how the Guidelines would apply to different locations within the North Cascades Recovery Area, we believe sharing this in the plan would reduce confusion over potential control actions that could occur within North Cascades National Park and surrounding lands.
The cited information on grizzly bear diets (page 73 of the plan) may minimize the potential influence recovered bears could have on non-vegetative food sources; while the animals are indeed omnivores, the higher energy content gained from bears eating ungulates and fish is noted in more current publications such as Gunther, et al.’s Dietary Breadth of Grizzly Bears in the Greater Yellowstone Ecosystem (Ursus 25(1),2014.pp 61-73) and Fortin, et al.’s Dietary adjustability of grizzly bears and American black bears in Yellowstone NP. (Journal of Wildlife Management 77(2), 2013. pp170-181). We question whether it is your and the U.S. Fish and Wildlife Service’s intent to abide by item number 5 on page D-5 of the Appendix, taken from the 1986 Interagency Grizzly Bear Guidelines, specifying that, in the case of a grizzly bear death, mortality reports and all bear carcasses would be sent to the Montana Department of Fish, Wildlife and Parks lab in Bozeman, Montana, for examination and subsequent disposition, as opposed an appropriate facility in Washington.
Overall, we compliment you and your partners for completing a thoughtful analysis of a contentious issue. We know that grizzly bear restoration, should it occur, will continue to require considerable time and attention by the park as well as Tribes, individuals, and other state and federal agencies. Nevertheless, it is exciting to consider the potential for the return of this long-missing species to the park and surrounding ecosystem. With continued attention to public awareness, we believe that your preferred alternative action can contribute to the recovery of a threatened mammal, add to integrity of the North Cascades’ natural and cultural resources, and provide enhanced visitor appreciation with minimal added risk to human safety and other values and interests of people in the area. We appreciate the opportunity to provide comments on this plan.
Michael B. Murray
Chair of the Executive Council
Coalition to Protect America’s National Parks