In a perfect world, we would have at our disposal a Grizzly Bear Recovery Plan that would set forth appropriate standards to protect habitat in the face of timber sales and other developments. Instead, we are faced with a plan that is seriously deficient. Revised in 1993, the plan now contains a decent discussion of roads and how they adversely affect bears (Appendix B), but fails to conclude this discussion with adequate standards to limit the amount of roads in grizzly bear habitat. The plan is virtually silent regarding how to manage timber sales and other developments in grizzly bear habitat, aside from the vague and ineffectual statements: "Make [Timber Harvesting and Road Building, Mining and Oil and Gas Exploration and Development, etc.] Compatible with Grizzly Bear Habitat Requirements." It also refers to the "Interagency Grizzly Bear Guidelines," which are vastly outdated and discretionary (see IGBC 1986).

The recovery zones described in the recovery plan are deficient in some fundamental respects: (1) they do not reflect current bear use; and (2) no analysis has ever been done to determine if they are large enough to support a viable population (since FWS has done no population viability analysis). Therefore, the issues raised here should not be confined to areas within currently designated grizzly bear recovery zones. They may also be appropriate in areas outside the recovery zone where grizzly bears are known to occur, areas that receive no current use but could provide important habitat to an expanded population, and connecting corridors between these areas.

The population goals set forth in the recovery plan are not grounded in any "population viability analysis." That is, the plan does not answer the question: how many bears are needed before a population can be deemed truly recovered? The best available information from the field of conservation biology reveals that small, isolated, "island" populations of grizzly bears cannot be considered recovered. Instead, a large, contiguous population of as many as a few thousand bears minimum is needed. No single remaining grizzly bear ecosystem is large enough to support this many bears today. Therefore, these issues should also be raised within ecosystem "linkage zones," or potential corridors between existing grizzly bear ecosystems, to ensure that their capacity to function as a linkage zone does not deteriorate over time (see Shaffer 1992).

Despite nearly two decades of grizzly bear research from the time the species was listed as Threatened in 1975, and over a decade from the original recovery plan in 1982, very little science has been incorporated into the recovery plan. Absent from the recovery plan, this information is either utilized at the discretion of individual land managers, or it is not used at all. PCA's "Clearinghouse" is an attempt to assemble the best available information, for use by citizens concerned with the survival and recovery of grizzly bears.

Roads

As mentioned above, the recovery plan devotes significant attention to the harmful effects of roads on grizzly bears, and contains the following statements (pp. 21, 145, 149):

"Roads probably pose the most imminent threat to grizzly habitat today..."

"The management of roads is the most powerful tool available to balance the needs of bears and all other wildlife with the activities of humans..."

"Any unroaded land represents important and unique opportunities..."

"Management should seek to maintain these areas as unroaded wherever possible."

Appendix B: Guidlines on the Management of Roads

The appendix opens: "The management of roads is the most powerful tool available to balance the needs of bears and all other wildlife with the activities of humans... In general, increased human access on open roads and continued human use of closed roads have overall deterimental effects on grizzly populations. Roads and road activity allow continued bear mortality risk, increase habituation of bears, and effectively decrease usable habitat" (p. 163).

The appendix states: "Mortality is the most serious consequence of roads in grizzly habitat (p. 164). It cites Aune and Kasworm's study (1989) where 63% of all known human caused mortalities occurred within 1.0 km of a road, including 10 to 11 known female mortalities. It also cites studies which document the loss of habitat resulting from roads.

The appendix states: "It is recommended that open road density in all MS1 (Management Situation 1) and MS2 areas within grizzly bear recovery zones be less than 1.0 mile of open road pe square mile. Where existing open roads are currently below 1.0 mile per square mile, there should be no net gain in open road density" (p. 170). The appendix then describes the importance of unroaded areas to provide security for grizzly bears and other wildlife, and states: "Management should seek to maintain these areas as unroaded wherever possible" (p.171). Finally, the appendix recommends using the "moving window" technique to calculate road densities.

Recovery Plan Revisions

The recovery plan was successfully challenged in court by PCA and many other grizzly supporters. The following excerpt explains the import of the ruling that the FWS recovery criteria were legally and biologically inadequate (from a memo from Sierra Club Legal Defense Fund attorney Jim Angell, 12/15/95):

"The most important of the court's rulings was that the recovery criteria are legally required to address each of the ESA's five delisting factors and that the recovery plan's criteria failed to do so. In addition, the court ruled that FWS must design its recovery criteria so that they address the threats that led to the grizzly bear's original listing. Specifically, the court held that the recovery criteria are legally inadequate because they fail to adequately address: (1) habitat loss; (2) threats posed by disease; (3) threats resulting from grizzly/livestock conflict; (4) the adequacy of existing regulatory mechanisms; and (5) threats posed by the genetic isolation of the grizzly's remaining habitat islands In addition the court held that FWS's females with cubs-of-the-year recovery measure was so unreliable as to make its adoption arbitrary and capricious."

Since this ruling, FWS has begun efforts to address these deficiencies. It released a "habitat-based recovery criteria" document in Fall 1999 that is still under review. It has contracted peer review of its recovery plan targets, based on the females-with-cubs observation data. Efforts to address the threats due to livestock, disease and due to genetic isolation are still forthcoming. A final deficiency noted by the Court was an unjustified reliance on bear populations in Canada, and connections with these populations to augment U.S. populations. Unfortunately, efforts to "delist" the grizzly in Yellowstone and Glacier continue, despite these fundamental flaws in defining and measuring progress toward recovery.