Conservation groups wanting better protection for fish and wildlife in the Northern Rockies filed Objections to the revised Flathead Forest Plan and Amendments to four other Forest Plans in the Northern Continental Divide Ecosystem.
The plan revision and amendments are intended to pave the way for delisting of threatened grizzly bear in the NCDE, which would remove their Endangered Species Act protection.
The groups launched a letter writing campaign in 2016. This resulted in 98% of the 33,744 comments the Forest Service received on its Draft Environmental Impact Statement calling for protection of all remaining roadless lands as wilderness and continuation of the road decommissioning program that agencies credit with improving grizzly bear security and helping restore critical bull trout watersheds.
The revised Flathead Forest Plan instead abandons its road decommissioning program and recommends for wilderness designation only 30% of the areas it found suitable for wilderness. The Kootenai, Lolo, Lewis and Clark, and Helena Forest Plans would similarly be amended to abandon road removal as a primary means to restore fish and wildlife habitat that has been damaged.
The groups rallied around the principles of the Citizen reVision alternative Swan View Coalition and Friends of the Wild Swan asked the Forest Service to include in its DEIS. The DEIS included some of these principles in its Alternative C, which it then assigned the highest marks for maintaining water quality and wildlife habitat connectivity. The FEIS and revised Flathead Forest Plan, however, select Alternative B-modified even though it is assigned "the highest risk of impact to aquatic species" and "is likely to adversely affect" already threatened grizzly bear, bull trout, and Canada lynx!
The Objections were due at Forest Service Region One headquarters in Missoula on February 12. The Region now has ten days to "publish a notice of all objections in the applicable newspaper of record and post the notice online." The Region's responses to the Objections are due within 90 days, unless it grants itself extensions.
Below are links to some of the Objections filed by groups supporting the principles of the Citizen reVision:
Flathead-Lolo-Bitterroot Citizen Task Force, Wilderness Watch, WildWest Institute, Friends of the Bitterroot, Friends of the Rattlesnake, Friends of the Clearwater, Independent Consultant Mike Bader Objection.
The 3,000 pages of FEIS, Forest Plan and Forest Plan amendments can be found here.
Swan View Coalition has issued a critical review of the Biological Assessment of the final revised Flathead Forest Plan, along with Friends of the Wild Swan.
The groups find the Plan wholly inadequate in its protection of fish, wildlife and wildlands. Their review is based on the Flathead's Biological Assessment of the pending revised Flathead Forest Plan.
The Assessment was obtained under the Freedom of Information Act along with other Biological Assessments and Biological Opinions written for recently completed consultations with U.S. Fish and Wildlife Service regarding impacts to threatened grizzly bear, bull trout and lynx.
The Flathead had promised to post the Assessments and Opinions on its Forest Planning web site by December 1, but instead provided them to Swan View Coalition on CD. The Flathead had hoped to release its revised Forest Plan in November and is now hoping to do so in December.
The Flathead is also responsible for writing and releasing Forest Plan grizzly bear amendments for the other four Forests in the Northern Continental Divide Ecosystem, reducing protections for grizzly bear in all five Plans as Fish and Wildlife Service plans to remove (delist) the NCDE grizzly bear from Endangered Species Act protections in 2018.
UPDATE: The Flathead did release its revised Forest Plan and NCDE amendments on December 14, 2017, posting them, the BAs and the BiOps on its Forest Planning page.
Click here for the groups' 12/12/17 press release, which secured us coverage in the following news:
Click here for the 12/15/17 Daily Inter Lake news article.
Click here for the 12/16/17 Flathead Beacon news article.
Click here for the 12/16/17 Missoulian news article.
Click here for the 12/14/17 MTPR radio story.
Click here for the Flathead's Biological Assessment of its revised Forest Plan.
Click here for FWS's Biological Opinion on the revised Flathead Forest Plan.
Click here for the Biological Assessment of the Four-Forest Grizzly Bear Plan Amendments.
Click here for FWS's Biological Opinion on the Four-Forest Grizzly Bear Plan Amendments.
Nokio Creek culvert blowout - Flathead NF photo.
Keith Hammer has issued three Supplements to his "Roads to Ruin" and "TMRD" reports, providing documents showing logging roads must have their stream-bearing culverts removed, then the roads must be removed from the Flathead Forest Road System and revegetated before they can be omitted from calculations of Total Motorized Route Density.
The Flathead National Forest has been violating these requirements that it wrote into its 1995 Forest Plan Amendment 19 based on grizzly bear research. These requirements were intended to improve habitat for threatened bull trout and other aquatic life while securing habitat for threatened grizzly bear and other terrestrial wildlife. The Flathead intends to do away with Amendment 19 altogether in its revised Forest Plan, largely by reneging on/denying the scientific basis for what Amendment 19 requires!
Click here for the Third Supplement. It describes how Total Motorized Route Density evolved from Total Road Density, how it is based in the South Fork Grizzly Bear Study (Mace and Manley 1993), and how in Flathead Forest Plan Amendment 19 it requires that roads be decommissioned, revegetated and removed from the "system" to lower TMRD. It also shows how Mace and Manley 1993 answered the Flathead's questions about how to calculate road densities, showed that Total Road Density must be considered in addition to Open Road Density, and points to why A19 capped the total miles of road that can exist in griz habitat due to the importance of roadless areas to female griz.
Click here for the Second Supplement, which reviews Forest Service and Fish and Wildlife Service documents since 1995, confirming that Amendment 19 requires roads be decommissioned and no longer serve as a road or trail in order to not be counted in TMRD - serving as a cap on the miles of road that can exist in grizzly bear habitat. It also details how the Flathead NF has invented a new category of "impassable" roads to unlawfully substitute for road decommissioning. This leaves the roads available for both motorized and non-motorized use various parts of the year, without being counted in TMRD and hence allowing an unlimited number of such roads to exist in the habitats of threatened species like grizzly bear, lynx, bull trout, and threatened-candidate wolverine!
Click here for the First Supplement to Keith Hammer's "Roads to Ruin" and "TMRD" Reports, which details requirements that reclaimed/decommissioned roads be revegetated and no longer serve as a motorized or non-motorized trail.
Click here for the "Roads to Ruin: The Flathead National Forest Shirks its Road Reclamation Duties," which includes the TMRD report as an appendix.
Click here to read how Swan View Coalition, Friends of the Wild Swan, and WildEarth Guardians have put the Flathead on notice they will sue over its lack of adequate road and culvert management!
Below are links to SVC's comments on the Draft Revised Flathead Forest Plan, proposed grizzly bear amendments to four other NCDE Forest Plans, and their Draft Environmental Impact Statements (DEISs).
We submitted 12 letters prior to the October 3, 2016 deadline, biting off a few issues at a time. We continue to submit more letters as new information becomes available.
For more background on how and why we commented, see our Summer 2016 alert and newsletter!
Click here for our 8/15/16 letter, which provides a photo of ATV damage in Krause Basin and asks that DEIS Alternative C be applied to finally ban ATVs from the old trail system there.
Click here for our 9/7/16 letter, which asks for a refinement and combining of DEIS Alternatives A and C to follow through on past promises of grizzly bear habitat security and increased wildlife habitat connectivity through the protection of roadless lands as recommended wilderness.
Click here for our 9/8/16 letter, in which we ask that all references to grizzly bears having met Recovery Plan parameters be stricken from the EISs due to the lack of legally mandated habitat-based recovery criteria in the Recovery Plan. This letter also details a number of ways in which all 3 DEISs and the proposed revised Flathead Forest Plan will not maintain grizzly bear habitat security at 2011 levels as promised.
Click here for our 9/9/16 letter regarding budgets, products, jobs, income, and associated bias in the DEISs.
Click here for our 9/12/16 letter regarding how the DEISs lie about definitions and requirements for managing Total Motorized Route Density, reclaimed roads, decommissioned roads, and revegetation of those roads. This letter attaches our Objection to the Trail Creek Fire Salvage Project and our 2/7/16 TMRD paper, which help illustrate with photos and facts why this is a big deal for fish and wildlife.
Click here for our 9/13/16 letter regarding the inadequate range of alternatives in the DEIS, the inappropriate linkage to grizzly bear delisting, and the failure to carry forward essential unfinished programs from the current Forest Plan. Included with the letter is our "Roads to Ruin" report that helps illustrate our point.
Click here for our 9/15/16 submission attaching a letter to the Flathead Conservation District explaining how restoring Krause Basin and removing ATVs will have positive effects on downstream private landowners.
Click here for our 9/19/16 letter regarding how the DEIS and its alternatives fail to use the best available science and fail to propose revision and actions consistent with monitoring and evaluation of the current Forest Plan.
Click here for our 9/23/16 letter regarding mountain bikes and their impacts on public safety, wildlife and other forest users.
Click here for our 9/29/16 letter PDF that summarizes and includes four research papers concerning ecological traps, source-sink populations, and the genetic effects of dispersing grizzly bears.
Click here for our 9/30/16 letter as a pdf that attaches documents showing the Flathead must provided grizzly bear habitat security according to the "3 and 7 Rule" until such time as it meets fully its Amendment 19 "19/19/68" standards in each subunit.
Click here for our 10/3/16 letter following up on tidbits and the overall complexity of the planning documents.
Click here for our 11/23/16 letter finding that the DEIS does not adequately address the Pacific Northwest National Scenic Trail proposal, its impacts to grizzly bear Security Core and other wildlife habitat, nor disclose that the Forest Service and National Park Service in 1980 found this proposal to be "neither economically feasible nor desirable."
Click here for our 4/20/17 letter finding there is inadequate regulation of mountain biking and the human use of "stored" logging roads in the NCDE Grizzly Bear Ecosystem.
UPDATE: Swan View Coalition testified on behalf of 15 other groups and organizations at a July 7, 2016 Grizzly Bear Habitat Workshop in Missoula, MT. We submitted more comments in January 2018 when FWS asked for comments, this time on its Draft Supplement to include HBRC in the Grizzly Bear Recovery Plan.
Click here for our 1/3/18 comments.
Click here for our 1/23/18 comments.
All you need to say is that you want grizzly bear recovery based on the promised security of grizzly bear habitat and key bear foods - and that you want FWS to abandon its current plan to instead reduce grizzly bear security in the face of growing human populations and impacts.
Remember, while the grizzly bear population in the entire Northern Continental Divide Ecosystem was estimated to be 765 bears in 2004 and has hopefully increased by a couple hundred bears since then, the human population of Flathead County alone grew by 1,800 people in 2014 and is estimated to reach 100,000 by 2018!
Click here to read Swan View's testimony or to help fine-tune your email to FWS.
Click here to watch NBC's coverage of the workshop.
Click here to read the Missoulian newspaper article about the workshop.
Click here to watch KPAX coverage of the workshop.
Click here (then scroll down) to view a list of links to the 26 documents attached to Swan View Coalition's testimony.
Our Winter-Spring 2016 newsletter releases our new report "Roads to Ruin," describes how our investigations have already helped secure more road decommissioning for bull trout in the Swan Valley, and describes how the report will help us all wrestle with the revised Flathead Forest Plan and Grizzly Bear De-Listing DEISs due out May 27!
Our "Roads to Ruin" report also describes how "collaborative" groups are being misused to promote the notion that the biggest problem in our public forests is too many trees, when research clearly shows the biggest problem is too many logging roads!
Below is our newsletter's table of contents and you can click here to view or download it as a pdf.
We hope you enjoy the newsletter and our new report - and will join others in supporting our work!
Fish, wildlife, wilderness, and people are counting on us - and you!
Your email to the Flathead National Forest will help stop more of these logging road landslides from trashing fish and wildlife habitat!
The Flathead already has 2,000 miles of roads like this one in Sullivan Creek demoted to Maintenance Level 1 Basic Custodial Care, where they don’t receive the care needed to keep their ditches and culverts from plugging and then washing the roads into your trout streams!
(Another 1,400 miles are open to public motor vehicle use and have their own costly maintenance issues).
The Flathead is accepting public comments on its draft Travel Analysis Report, which would simply abandon even more old logging roads rather than carefully decommission them to remove culverts and sediment source problems.
Click here to visit the Flathead’s Travel Analysis Report web page.
Click here to read our comments on the Travel Analysis Report.
Click here to read our additional comments on the Travel Analysis Report, made in light of our discovery of slumps in the Sullivan and Quintonkin Creek roads.
Click here to read the Hungry Horse News Article about our discovery of the recent Sullivan Creek landslide.
Click here to read our press release about the Sullivan Creek landslide.
Click here for our letter to state and federal agencies urging that all old logging roads in Sullivan Creek be decommissioned.
Click here to read the Flathead’s “Assessment of the Sullivan Creek Mass Failure,” which claims it was nature’s fault.
Click here to read our response to the Flathead’s “Assessment of the Sullivan Creek Mass Failure.”
Click here to read the Flathead Beacon’s article about the Flathead National Forest still insisting it is an innocent bystander and intends to ignore this road as it continues to collapse, rather than promptly fixing more potential problems further up the road!
Click here to see our video of the Sullivan Creek landslide.
Swan View Coalition testified before a Federal Advisory Committee on May 29, 2014, detailing how “collaboration” on the Flathead National Forest is being used to marginalize the best available science and those who use it to protect fish and wildlife. Click here to read Keith Hammer’s testimony.
Hammer’s testimony includes links to sources indicating the Whitefish Range Partnership intended to front-load the Flathead National Forest’s Forest Plan revision collaborative by being “first out of the chute.” His testimony and that of F.H. Stoltze Land and Lumber’s Paul McKenzie (a Partnership member) showed that the Partnership’s proposal to nearly double the lands slated for logging in the Whitefish Range was indeed applied across the Forest during the Forest-wide collaborative and involves relaxing standards for the protection of threatened grizzly bear and lynx habitat.