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in the FEIS – see page 494) and incorporate the best available science on motorized recreation’simpacts on grizzly bears.4. Population ObjectivesThe Draft Conservation Strategy states its objective is to maintain “habitat conditions that arecompatible with a stable to increasing grizzly bear population.” USFWS 2013 at 36–39. However,this objective is questionable. First, given a complete lack of long-term, ecosystem-wide habitatresearch, management agencies do not have a firm grasp on what current habitat conditions are.Second, the population objectives, survival rates of independent females, and mortality rates ofindependent males as outlined in the Draft Conservation Strategy all tend toward managing thepopulation downward from current levels, not towards a “stable to increasing” population asdemanded.For example, although the current population estimate is roughly 960 grizzlies in the NCDE(Costello et al. 2016), the Draft Conservation Strategy goal is for 800: a 17% decline in thepopulation. USFWS 2013 at 37–39. Additionally, the current survival rate of independent femalesis 95.2%, while the goal of the Draft Conservation Strategy is for only 90% survival. Id. And, thecurrent mean annual mortality rate of independent males is 13.8% – 15.6%, but the DraftConservation Strategy allows for 20%, importantly, with no scientific reference for this dramaticincrease in allowable mortality. Id. While the Draft Conservation Strategy, and Forest Planamendments based upon it, make the mistake of assuming that the 3% growth rate made possible bythe protections afforded NCDE grizzly bears by the ESA and Amendment 19 will be possible afterhabitat standards are weakened and hunting potentially allowed, nothing could be further from thetruth. Indeed, the FEIS admits the current best available science indicates a 2% growth rate andadmits mortality on private lands (essential to establishing connectivity amongst populations) isincreasing.The Forest Service notes: “[t]he trend in grizzly bear mortalities on NFS lands is downward, but thetrend on private lands is upward.” FEIS at 496. Because the Forest only controls the mortality onNational Forest Lands, the Forest must ensure that the private land mortality trend does notundermine a positive trend on the Forest. In accordance with this knowledge and the PrecautionaryPrinciple, as well as with the acknowledged 2% (not the DEIS’ 3%) growth rate, the Forest must beconservative in its estimates. Indeed, if trophy hunting of grizzlies is allowed in Montana (the stateis quite far along in developing its framework for trophy hunting seasons and is clear it intends toallow for trophy hunting) mortality on private and Forest lands are both likely to rise considerably.Additionally, the Forest should include bears translocated to other recovery areas in its assessmentof “mortality” since those bears, like dead bears, are permanently absent from the NCDE.Proposed Solution: Engage in long-term ecosystem wide habitat research and establish a viablebaseline. Check assumptions against current population estimates and account for the futureproposed lack of ESA protections and failure to comply with Amendment 19. Revise the EIS tocomply with Amendment 19 and the ESA listing and delisting criteria. Ensure the EIS contemplatesthe impacts of removal of ESA protections and lack of adherence to Amendment 19 in allassumptions.5. Management Zone 1The Draft Conservation Strategy designates a Management Zone 1 around the perimeter of thePrimary Conservation Area (“PCA”) with the following claimed characteristics: (1) “The objective inWildEarth Guardians, Western Watersheds Project, Sierra Club Objection to the Flathead and NCDE Draft RODs5

Zone 1 is continual occupancy by grizzly bears but at expected lower densities than inside the PCA”;(2) “In these areas, habitat protections on Federal and Tribal lands will focus on limiting miles ofopen roads and managing current roadless areas as stepping stones to other ecosystems”; and (3)“Attractant storage rules would be implemented on Federal, Tribal, and most State Lands” withinZone 1. USFWS 2013 at 4–5; DEIS at 15.These objectives are concerning, however, because they do not readily demonstrate how grizzlieswill be ensured “continual occupancy” within the management area. First, open road limitationsthat are based on the new 2011 baseline standard have no basis in science. How can the agencyknow that “continual occupancy” based on this standard will indeed be achieved without theunderlying scientific bases to support its assertion? Second, under the new Kootenai Forest Plan,Inventoried Roadless Areas (“IRAs”) are systematically denied Recommended Wilderness status,with most designated as Motorized Backcountry instead. USDA 2015a. This designation clearlyallows for increased levels of motorized use than if the more protective Recommended Wildernessdesignation were adopted. Third, management control of food-conditioned grizzlies (attractants) isamong the leading causes of NCDE mortality. Costello et al. 2016. Accordingly, this source ofmortality must be duly considered as applied against the “continual occupancy” objective. Andfurther, the State of Montana manages over 500,000 acres in the NCDE, yet it has thus far refusedto control attractants on its lands. Again, this renders the “continual occupancy” objective of Zone1 questionable at best.Proposed Solution: Revise the Forest Plan to take into account impacts of the portion of theNCDE managed by other agencies who do not require food storage and other attractant controls,take into account the mortality cause attribution of Costello et al. 2016, reject the flawed 2011baseline and revise using the best available science. Protect key linkages and corridors withWilderness designations. Comply with Amendment 19.6. Management Zone 2The purpose of Management Zone 2, as described in the Draft Conservation Strategy, is “to providethe opportunity for grizzly bears, particularly males . . . to move between the NCDE and adjacentecosystems.” USFWS 2013 at 4–5. However, the Draft Conservation Strategy also states: “there areno habitat standards specifically related to grizzly bears” in Zone 2 “because the objectives in thesezones do not require them.” Id. The Draft Conservation Strategy further notes that Zone 2’sobjective “is to maintain existing resource management and recreational opportunities and allowagencies to respond to demonstrated conflicts.” Id. In fact, these are some of the very activities thatimperiled NCDE grizzly bears and placed them under ESA protection to begin with.Thus, it is clear that the Draft Conservation Strategy, and any Forest Plan amendments based uponit, intend to manage Zone 2 as a mortality sink, not a population link, as claimed. While the movementof males provides for genetic connectivity amongst other ecosystems, only female movementactually results in the demographic connectivity that the Draft Conservation Strategy claims, but failsto provide. The solution to this problem is clear though: the agency should base the management ofZone 2 on the known security requirements of grizzlies – and particularly female grizzlies – insteadof basing habitat objectives on land manager preferences.Proposed Solution: Revise the Forest Plan to manage zone to ensure female as well as male grizzlybear dispersal and reproduction. Ensure that Zone 2 is managed to protect grizzlies, notrecreational or political interests.WildEarth Guardians, Western Watersheds Project, Sierra Club Objection to the Flathead and NCDE Draft RODs6

7. Independent Female MortalityAlthough the Draft Conservation Strategy’s Standard No. 3 states that independent female mortalitywill not exceed 10% (USFWS 2013 at 38–39), it contains absolutely no timely consequences fordoing so. In fact, despite the fact that grizzlies are one of the slowest reproducing mammals inNorth America, rendering female mortalities as especially serious, the Draft Conservation Strategythrows the Precautionary Principle completely out the window. For example, the DraftConservation Strategy’s standard might allow mortality thresholds to be exceeded (or on the cusp ofexceeding) for over a decade before even looking into the problem: “As an example of theapplication of the management review triggers, if independent female survival was between .89 and.90 for 12 consecutive 6-year intervals, such as 2014–2025, a management review would betriggered.” USFWS 2013. That does not mean that it will be twelve years before corrective action istaken, it means twelve years would lapse before any investigation of the mortality causes is evenlaunched. This is plainly unacceptable.Proposed Solution: Revise the Forest Plan to include clear, enforceable triggers and consequencesfor female mortality levels based on the best available science. Institute management review ifmortality thresholds are exceeded in two consecutive years.8. Temporary Increases in Motorized Use and Reductions in Security CoreThe Draft Conservation Strategy allows NCDE forests to “temporarily” increase Open MotorizedRoute Density (“OMRD”) by 5%, increase Total Motorized Route Density (“TMRD”) by 3%, andreduce Security Core by 2%. USFWS 2013. These figures are derived from an analysis of theimpacts of six national forest projects between 2003 and 2010 (five on the Flathead and one on theLolo). USFWS 2013 at 51–52. Since these projects occurred at a time when FWS stated that theNCDE grizzly population “is known to have been increasing,” the Forest Service concludes thatthese figures must be adequate as applied across the entire ecosystem. There are a number ofconcerns with this approach.First, according to Dr. Richard Harris, neither population nor trend was known at the time the DraftCS was developed. USFWS 2013, Appendix 2 at 9. Thus, how could the Draft ConservationStrategy accurately state that these figures increasing temporary motorized use and decreasingsecurity core are indicative of assurances that allow for an increasing population to be maintained?Second, it is worth noting that none of the national forest projects upon which these figures arebased were identified so that the data might be verified and the impacts truly revealed. Third, five ofthe six projects considered occurred on just one forest, which is hardly representative of the entireecosystem. Fourth, such “temporary” increases in motorized density and “temporary” decreases insecurity core for “temporary” projects can span a fully five-year period, with yet another year forrestoration (with limited exceptions). USFWS 2013 at 52. Displacing grizzlies, particularly femaleswith cubs, from important habitat for over five years can hardly be considered “temporary,” andwould necessarily have serious consequences for both survival and reproduction.Proposed Solution: Revise the Forest Plan to eliminate all “temporary” increases in motorizedactivity. Identify all projects on which assumptions are based. Comply with Amendment 19.Recognize and incorporate the impacts of climate change on motorized recreational use, particularlyin the denning and rearing seasons.WildEarth Guardians, Western Watersheds Project, Sierra Club Objection to the Flathead and NCDE Draft RODs7

9. Reliance on the Draft CS is in ErrorWe are disappointed that the public has still only been provided with a Draft Conservation Strategy,while actual recovery criteria and habitat standards for NCDE grizzly bears will eventually be basedupon the best available science included in a yet-to-be-published Final Conservation Strategy. It iswholly inappropriate for the Forest Service to base these significant Forest Plan revision provisionsand amendments pertaining directly to the recovery and future management of grizzly bears withoutthe final facts properly vetted and adopted based upon consideration of the best available science.The Forest Service should consider that it cannot finalize the revision and amendments process in amanner that will ensure “adequate regulatory mechanisms” exist such that a potential delistingprocess for NCDE grizzly bears can proceed absent publication of a Final Conservation Strategyupon which to base its revisions and amendments on. The proper public process would be to firsthave the Final NCDE Conservation Strategy affirmatively in place, and then to revise the NCDEnational Forest Plans accordingly.Proposed Solution: Revise the Forest Plan once adequate regulatory mechanisms are in place,including a final Conservation Strategy and final HBRC. Comply with public notice and commentrequirements for those revisions.B. Comments on the Draft Revised Flathead Forest Plan as it Pertains to GrizzliesIn our DEIS comments recommended that the Flathead National Forest adopt proposedAlternative C – with modifications as outlined below – to ensure proper habitat conditions aremaintained, and increased, to adequately protect the forest’s imperiled grizzly bears. We continue tomaintain it is the only viable option for this decision. While Amendment 19 to the current FlatheadForest Plan still represents the best available science on grizzlies and motorized access impacts – andtherefore should have appeared in all of the proposed alternatives – the remainder of the alternativescontains significantly outdated science, false interpretations of the law, and land management actionsthat render it an inappropriate choice. The Forest Service’s abandonment of Amendment 19 iswholy unaccpetable.Alternative B’s minimal recommended wilderness, nearly 160,000 acres of motorized “fakebackcountry” summer and winter use, its 693,262 acres of General Forest Management Areas(“MAs”), and 465,200 acres suitable for timer harvest the will fracture necessary connectivityopportunities for grizzly bears across geographic areas, making it a significantly poor choice.Flathead ROD at 12, 14.We again recommend adoption of Alternative C, with modifications, because it most closely abidesby the conservation mandates of the Forest Service’s mission. For example, Alternative Cdesignates 506,919 acres as Recommended Wilderness. DEIS Vol. 1 at 36–37. Notably, thealternative includes 98% of inventoried Wilderness within Recommended Wilderness designation aswell. Id. Additionally, at 73,426 acres, Alternative C’s proposal will designate the least amount ofbackcountry acreage for motorized over-snow (i.e., snowmobile) use, providing a huge benefit toimperiled species like Candana lynx, wolverine, and grizzly bears, as well as the large number offorest users seeking quiet landscapes. Id. Alternative C further provides for 79% of General ForestMA to be in the low and moderate categories, enhancing vital habitat protections. Id. Importantly,this alternative also generally provides a higher amount of habitat connectivity than any other actionalternative. However, with 317,300 acres proposed as suitable for timber production, and another392,000 acres proposed as suitable for timber harvest, there remains substantial reason for concern.DEIS Vol. 2 at 108–09.WildEarth Guardians, Western Watersheds Project, Sierra Club Objection to the Flathead and NCDE Draft RODs8

Aside from our general concurrence with the Forest Plan provsions as proposed under AlternativeC, we suggest the forest would benefit from additional modifications to increase the vitality of theFlathead’s outstanding wildlife, vegetation, habitat and water resources. We suggest the ForestService consider implementing the following improvements to its alternatives analysis to create aForest Plan that is not only biologically and economically sound, but also is appropriatelyscientifically and legally defensible.Proposed Solution: Adopt the revised Forest Plan as outlined in Alternative C with the belowadditional considerations fully incorporated. Alternative C, in combination with the aforementionedsuggested modifications, provides an opportunity for the Forest Service to prove its good intentionsunderlying grizzly bear recovery in the NCDE.1. Retain Amendment 19 Road Density StandardsWe suggested in our DEIS Comments that the Forest Service retain Amendment 19 road densitystandards as reflected in the current Flathead Forest Plan. Amendment 19 is based upon the bestavailable science from Mace and Waller (1997) and cannot be cursorily dismissed. We furtherrecommended the agency include the following Amendment 19 provisions in a revised AlternativeC: Open Motorized Route Density (“OMRD”): 19% or less of each Bear Management Unit(“BMU”) Subunit contains one-mile per square-mile or less of open motorized routes.Total Motorized Route Density (“TMRD”): 19% or less of each BMU Subunit containsless than or equal to two-miles per square-mile of total motorized routes.Security Core: 68% or more of each BMU Subunit is defined as security core, meaning anarea at least 2,500 acres in size that is at least 500 meters away from any open/gatedroute, motorized route, or high-use trail.We noted that implementation of these standards would not mean that a BMU subunit with OMRDor TMRD of 16% would exceed Amendment 19 standards, thus leaving another 3% available forroad development. Rather, it would mean that 16% meets Amendment 19 and therefore must bemaintained at that level, or better. Likewise, the security core standard suggested above does notmean that a BMU subunit with 75% core would exceed Amendment 19, therby allowing the forestto develop via logging or roads an additional 7% of the subunit’s footprint. Rather, it means that75% core meets Amendment 19 and therefore must be maintained at that level, or better.Proposed Solution: Retain Amendment 19 standards, and move promptly to close and fullydecommission 518 miles of national forest system roads and 57 miles of trails within the next 10years. DEIS Vol. 2 at 38. The Flathead can use the 2.2 million in annual savings, as identified bythe DEIS under Alternative C (Id. at 115), to fund this necessary program of decommissioning.2. Decommission RoadsDecommissioning requires all bridges and culverts to be removed, as required by Amendment 19.Only fully decommissioned routes can be removed from the TMRD mileage list. Intermittentstored-service routes should never be substituted for decommissioned routes, and cannot beremoved from TMRD miles. USDA 1995. Wildlife dependent on large unroaded landscapes – likegrizzly be

26 Fort Missoula Road Missoula, MT 59804 Submitted electronically via: appeals-northern-regional-office@fs.fed.us Dear Objection Reviewing Officer, WildEarth Guardians, Western Watersheds Project, and the Sierra Club hereby object to the: Draft Record of Decision for the Final Environmental Impact Statement and Forest Plan,