The revised Flathead Forest Plan pledged to maintain the on-the-ground grizzly bear habitat conditions that existed in 2011, in order to be consistent with the NCDE Grizzly Bear Conservation Strategy and plans to remove Endangered Species Act protections from NCDE grizzly bears.
Now the Flathead says it will not maintain those levels of habitat security as it increases human development of bear habitat - and claims it isn't required to do so under its revised (2018) Forest Plan!
Swan View Coalition, Friends of the Wild Swan, and Independent Wildlife Consultant Brian Peck summarize this about-face in their primary Objection to the Flathead's Hellroaring Basin Improvement's Project.
The Flathead admits the HBIP would reduce grizzly bear habitat security in Hellroaring Basin by constructing two new chairlifts, their service roads, new ski runs, and the thinning of forest hiding cover for glade skiing. The Flathead also admits that two mountain bike trails to be built in Hellroaring Basin, among the 28 miles being constructed under the already approved Taylor Hellroaring Project, will also displace bears from their habitat.
The Flathead nonetheless attempts to make it look like this is consistent with its pledge to maintain the level of 2011 grizzly bear habitat security, a 1995 requirement to maintain bear security in Hellroaring Basin on the south side of Big Mountain as Whitefish Mountain Resort was expanded to the north side of Big Mountain, and the revised Forest Plan’s condition to provide increased grizzly bear security in the Hellroaring watershed. It does so by saying it will maintain its 2011 baseline security parameters, but then intentionally not quantifying the additional displacement of bears and not measuring it against those parameters, making it appear the 2011 baseline is not being degraded.
The Objectors find this same "phony numbers" system is being applied to all projects being implemented under the revised Forest Plan, masking the on-the-ground impacts of scores of miles of new logging road construction, the construction of 80 miles of new mountain bike trails, and ski area developments like those in Hellroaring Basin. Objectors list five ways in which impacts to bears are not being included in, and hence limited by, the 2011 baseline security parameters:
1. Allowing unlimited miles of non-motorized trails to be constructed with no trail density standard - or 2011 Baseline parameter - to limit them.
2. Allowing unlimited miles of non-motorized “high-use” trails to exist in the Secure Core Baseline parameter by redefining the previous Plan's Amendment 19 “Security Core” in order to allow them to go undetected in the revised Plan’s “Secure Core.” “Security Core” did not allow such high-use trails.
3. Allowing an unlimited mileage of roads - by not including roads with the entrance simply rendered “impassable” to motor vehicles in Total Road Density, even though the road will be retained as a road and continue to contribute human impacts to grizzly bear habitat. This was not allowed under Amendment 19, which required that roads had to be reclaimed and no longer function as roads or trails, motorized or non-motorized, to be omitted from TRD.
4. By not including Special Use Permit roads that are on Forest Service land, and often simply closed by gates, in calculations of TRD.
5. By allowing road construction and the relaxing of road closure types to diminish the amount of “security habitat” greater than 500 meters from roads simply because that habitat does not already remain in blocks of at least 2,500 acres. This is essentially a license to further fragment already fragmented habitats and further relegate security habitat to higher elevations rather than allow it to persist in critical lower elevations such as Hellroaring Basin.
Objectors ask for a new Environmental Impact Statement to look at the cumulative impacts of the many projects being implemented under the revised Forest Plan, the degradation of bear habitat and security going unaccounted for, and to reinstate the former Plan's Amendment 19 with modifications to insure that it does not allow impacts to bears to go unaccounted for.
The details of the Flathead's admissions are summarized in Objectors' primary Objection and in the Flathead's Project File Exhibits it references.
Click here for our primary Objection to the Hellroaring Basin Improvements Project.
Click here and scroll down for links to the various Project File Exhibits referenced in our primary Objection.
Click here for our supplemental Objection to the Hellroaring Basin Improvements Project (detailing inconsistencies with the Forest Plan and the National Environmental Policy Act).
Click here for our Objection press release.
Click here for the resulting Missoula Current news article.
Click here for the Flathead's Hellroaring Basin, Taylor Hellroaring, and other project documents.
(updated 7/1/19 and 10/21/19)
Dr. Chris Servheen says he opposes the issuance of Special Use Permits for ultra-marathon trail-running races in bear habitat and wants permits for mountain bike guiding to comply with interagency recommendations for minimizing bear-human conflicts.
His comments were submitted to the Flathead National Forest during a public comment period on several such permits.
Dr. Servheen was Chair of the Board of Review investigating the death of Brad Treat when he slammed into a grizzly bear while mountain biking at high speed on the Flathead NF.
The Board of Review, which included two Flathead NF staff, recommends that people not run or bike fast in bear habitat. The BOR based its recommendations on numerous instances of people and bears being injured or killed due to surprise encounters during running and biking.
Dr. Servheen wrote "Issuing such permits will send the public a very conflicting message about how to recreate in bear habitat and send a bad message about the veracity of agency advice about how to recreate safely where there are bears . . . doing so will contradict years of agency educational efforts."
Flathead Forest Supervisor Chip Weber objected to the recommendations of the BOR at the June 25 meeting of the Interagency Grizzly Bear Committee and in an opinion piece to newspapers. He falsely claims that trail running and fast mountain biking are no more likely to cause a human-bear encounter than walking or hiking.
News accounts and Swan View's response to Weber note that the BOR cites substantial research in support of its findings and recommendations.
Click here to read the Daily Inter Lake article "Bear Expert Opposes Permits for Running Events."
Click here for Dr. Servheen's comments.
Click here for the Board of Review Recommendations.
Click here for MT Dept. of Fish Wildlife and Parks' findings: "Increased speed can increase the likelihood of surprising a bear at close range. Even during planned events with numerous participants, negative encounters including fatalities, can and have occurred."
Click here for MTPR's story on the IGBC meeting.
Click here for the Missoulian article about Supervisor Weber's objections.
Click here for Supervisor Weber's guest opinion.
Click here for Swan View Coalition's letter to editors in response to Weber's objections.
Click here for "When Cyclists Collide with Bears," an excellent summary of bike-bear collisions and the research showing fast travel results in increased risk of surprise encounters between people and bears!
Click here for "Who Owns the Wild: Grizzlies or Humans? The fight to balance recreation with wildlife is coming to a head."
Click here for Swan View's press release expressing disappointment in the approval of the Whitefish Legacy Partners and Foys to Blacktail trail marathon permits and the dangerous precedent they set on the Flathead NF.
Click here for more background on this issue.
Dr. David Mattson questions government claims of grizzly bear recovery in this hour-long video and this Report presenting an alternative vision of robust recovery for grizzly bears in the lower 48 states.
Government spokepeople would have us believe that the Northern Continental Divide Ecosystem grizzly bear population continues to grow at a rapid pace, fueling dramatic increases in distribution, and that they know with remarkable precision how many bears are there.
In fact, Dr. Mattson explains, we know very little about the current size and trajectory of this bear population. Moreover, episodes of rapid increase in distribution have more plausibly been driven by changes in habitat and diet than by increases in bear numbers.
Click here for our press advisory that summarizes Dr. Mattson's presentation. It includes a link to the video of his presentation and an annotated, video timestamp index to highlights.
You can also go straight to the video at https://www.youtube.com/watch?v=9pfIBnZtjTw .
(This post updated 6/20/19 to include the new Report).
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.
Click here for a Missoulian article on the 74 Objections filed.
Click here for Montana Public Radio coverage of the 74 Objections filed.
Click here for a Missoula Independent article on Objections filed.
The 3,000 pages of FEIS, Forest Plan and Forest Plan amendments can be found here.
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.
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.