Predator Conservation Alliance's comments on the
Northern Rockies Lynx Amendment Proposal

written by David Gaillard, Program Associate

October 25, 2001


Northern Rockies Lynx Amendment
Jon Haber
Northern Region Headquarters
P.O. Box 7669
Missoula, MT 59807

Dear Mr. Haber:

Please accept these comments on behalf of Predator Conservation Alliance and Defenders of Wildlife. Predator Conservation Alliance is a non-profit conservation group based in Bozeman, Montana, working to conserve and restore ecological integrity by protecting predators and their habitats in the U.S. northern Rockies and High Plains. Predator Conservation Alliance's membership includes 1600 people, approximately half of whom reside in the northern Rockies region, and all of whom highly value the recovery of lynx within all areas of suitable habitat in this and other regions of the lower-48 states. Defenders of Wildlife is a non-profit environmental group founded in 1947, dedicated to the protection and restoration of native wild animals and plants in their natural communities. On behalf of over 430,000 members and supporters, Defenders of Wildlife advocates new approaches to wildlife conservation that will prevent species from becoming endangered. Defenders' programs encourage conservation of entire ecosystems and interconnected habitats while protecting predators that serve as "umbrella" species for ecosystem health.

Predator Conservation Alliance and Defenders of Wildlife very much appreciate and support the amendment as an important first step toward recovering the lynx in the northern Rockies, but we believe it should be stronger to ensure that lynx recovery will succeed.

General Comments

1. The short timeframe for public review is a problem.

We were surprised at the suddenness of this proposal, and only learned of it after the comment period was already underway, despite our proven interest in this issue (co-plaintiffs in the ESA listing litigation, active member of Western Forest Carnivore Committee, etc.). We would appreciate more advance notice in future of important developments like this one and others affecting forest carnivores in the northern Rockies.

2. Little information is provided for the public to evaluate the adequacy of the mapping of the Lynx Analysis Units, which has a large bearing on the adequacy of the proposed standards.

We have a hard time commenting on the specifics of this proposal without a better idea about where it will be implemented and where it will not be implemented. From the maps we have been able to find, we understand that there is discrepancy among the forests about whether or not all lands are included, and that some lands may be excluded based upon arbitrary criteria. We urge the Forest Service to implement the proposed amendment in all areas that could provide suitable lynx habitat. Failure to do so is in violation of the Endangered Species Act, since it may allow activities that harm lynx using these areas.

3. The geographic scope of the proposed amendment is unclear and inconsistent: do we have assurance that identical standards will be implemented in the Forest Service and Bureau of Land Management (BLM) plans left out of this process? Outside of the northern Rockies, how will lynx protections be coordinated and consistent, and how much longer do we have to wait for lynx protections? This is especially important in the Northwest, since the fate of these two populations appears to be connected.

Lynx protections should be implemented consistently across all areas of suitable habitat on federal lands across the northern Rockies. Excluding BLM lands in Montana, Wyoming, excluding Forest Service lands that are under plan revisions, and excluding Forest Service lands in Oregon and Washington does not give us assurance that this will happen.

4. We appreciate much of the language in the proposed amendment, but are concerned that: (1) the proposed amendment departs from the Lynx Conservation Assessment and Strategy (LCAS) in significant cases, and (2) the standards within the LCAS may not be adequate to recover the lynx.

We describe the first problem in Part I that follows, and we believe that failure to resolve this discrepancy represents a clear violation of the Endangered Species Act, because it fails to implement standards that the U.S. Fish and Wildlife Service agreed are necessary to recover the lynx, according to its biological opinion on this matter dated, October 25, 2000.

We describe the second problem in Part II of our comments, which we also believe represents a violation of the Endangered Species Act, because the Forest Service and BLM have failed to fulfill their obligation under the Act to use the best available information to promote lynx conservation and recovery on the lands they manage.

Part I. Discrepancies between the proposed amendment and the Lynx Conservation Assessment and Strategy (Ruediger et al. 2000).

A. LCAS standards that are missing in the proposed amendment

1. The LCAS directs that the Forest Service (FS) and BLM: "Develop and implement a plan to protect key linkage areas on federal lands that would create barriers to movement" (p. 89).* The proposed amendment directs these agencies to identify key linkage areas, but only proposes protection from new developments or special use permits, land exchanges, etc. This is not adequate to fulfill what was described in the LCAS, and this is a very important, because lack of coordinated forest planning to address the fragmentation of lynx habitat is among the primary reasons why the lynx was listed for Endangered Species Act protections. A Forest Service spokesman claimed that this LCAS standard is outside the scope of this amendment, and may be addressed in a separate process, but we have no assurance that this will occur any time soon. It is only appropriate that this amendment directs that each national forest and BLM unit actively participate in the timely implementation of a regional strategy to maintain landscape connectivity among lynx populations in the northern Rockies.

2. The LCAS directs FS and BLM: "Within the range of lynx, complete a biological assessment for all proposed highway projects on federal lands" (p. 90). There is no mention of this in the proposed amendment, and again this is an important omission because of the fragmentation effects on lynx populations from highways across the region.

3. The LCAS directs that predator control be conducted in accordance with a U.S. Fish and Wildlife (FWS) consultation process (p.87). There is no mention of this in the proposed amendment. A Forest Service spokesman claimed that this is the responsibility of USDA Wildlife Services, but the Forest Service and BLM also have authority and responsibility regarding predator control operations on their lands, and a responsibility to ensure that lynx and other protected species are not at risk from these operations.

4. The proposed amendment changes an LCAS grazing "standard" to an "objective," thereby making it harder to implement and enforce. The standard has to do with maintaining vegetation in mid- to high seral condition in riparian areas within lynx range (LCAS, p. 85, Project Planning Standard #4). By comparison, a similar standard regarding grazing in shrub-steppe habitats has survived intact as a standard in the proposed amendment (LCAS, p.89, Project Planning Standard #3). All grazing standards in the LCAS should remain standards in the proposed amendment.

B. LCAS standards that appear to be unjustifiably weakened in the proposed amendment

1. LCAS direction to maintain and restore connectivity between lynx analysis units (LAU's) is qualified in the amendment with the words, "where necessary and feasible." This qualification goes without saying, and invites unnecessary subjectivity into the process, so it should be omitted from the proposed amendment.

2. The LCAS standard to prohibit any further reduction of suitable habitat in LAU beyond 30% appears to have been qualified to allow for further reduction in areas where historical conditions were different. The wording in the proposed amendment should exactly follow the wording in the LCAS, to ensure that no unnecessary "loopholes" are created by the new wording. For example, since lynx habitat in the northern Rockies is dynamic, almost all of it has been "unsuitable" for lynx at one time or another, such as immediately following a large fire. This should not be grounds for further degradation of lynx habitat beyond the 30% threshold, which already appears to be plenty achievable, especially if LAU boundaries already exclude areas considered unsuitable for lynx.

3. The LCAS standard to maintain at least 10% of each LAU in lynx denning habitat is qualified in the amendment such that it only applies to stands that will provide denning habitat in the near future (0-20 years). This qualification is arbitrary and unnecessary and should be omitted from the amendment. Since it is impossible to determine at exactly what age a stand may become suitable denning habitat for lynx, all intermediate-to-mature forests that have potential to provide denning habitat should be protected from logging, wherever denning habitat appears to be a limiting factor for lynx recovery.

4. The LCAS standard to pro-actively burn areas to improve foraging habitat for lynx (LCAS, p. 82, Project Planning Standard #2) has been changed to a reactive policy in the proposed amendment: all prescribed burning plans will incorporate lynx needs. This is far less than what was agreed to in the LCAS, and the amendment language should be changed to follow the clear purpose of the initial standard.

5. The LCAS standard that directs no net increase in designated snowmobile routes and play areas is narrowed so that the "play areas" must also be designated to be restricted. This is a critically important change, because so few national forests have designated "play areas" and new areas are constantly created regardless of any Forest Service designation. To be consistent with the LCAS, the amendment should be re-worded to prohibit any net increase in snowmobile play areas, designated or not. In addition, we are concerned about an apparent "loophole" in the amendment that does allow an increase in designated routes or play areas in the questionable cases where it improves lynx habitat by consolidating use. We believe that this exception is unjustified and unnecessary, since we cannot understand a situation where "consolidating use" would mean something other than reducing the number of snowmobile routes.

C. LCAS guidelines that are lacking in the proposed amendment

Our review of the "guidelines" in the proposed amendment revealed an omission that concerns us. There is a guideline in the LCAS that the Forest Service and BLM: "Minimize construction of temporary roads and machine fire lines to the extent possible during fire suppression activities" (p.82). There is no mention of this in the proposed amendment, and we strongly believe this should be added because of its importance to restoring and maintaining habitat security for lynx. To ensure the safety of fire fighters, we would support appending language to this guideline such as the following, "to the extent that it does not jeopardize human safety."


Part II. Cases where the LCAS fails to incorporate the best available science about how to promote lynx recovery.

A. Forest Practices

1. The LCAS fails to limit the sizes of large clearcuts that are known to be harmful to lynx. At a minimum, the amendment should ensure that clearcuts in lynx habitat do not exceed 40 acres in size.

In its proposed rule to list the lynx for Endangered Species Act protections (USDI 1998), the U.S. Fish and Wildlife Service (FWS) explains the major reasons for limiting opening sizes in lynx habitat:

Intensive tree harvesting (e.g., large-scale clearcutting) can eliminate the mosaic of habitats necessary for Canada lynx survival, including late successional denning and early successional prey habitat. Specifically, these activities can result in reduced cover, unusable forest openings, and monotypic stands with a sparse understory that are unfavorable for Canada lynx and/or their prey." (USDI 1998, p. 37001)

"Canada lynx avoid openings such as clearcuts, unforested areas, and grasslands (Koehler et al. 1979; Koehler and Brittell 1990, Murray et al. 1994) and snowshoe hares are also unlikely to use such areas because of the lack of cover (Koehler et al. 1979; H. Golden, Alaska Department of Fish and Game, pers. comm. 1994; Koehler and Aubry 1994)." (USDI 1998, pp. 37001-37002)

Additional literature concurs that lynx avoid open areas (Halfpenny and Biesiot 1986, cited in WDNR 1996a) for thermoregulatory reasons, to avoid predation, and to increase contact with prey (Poole 1994, Murray et al. 1984, Parker et al. 1983, Koehler et al. 1979; as cited in WDNR 1996a). The "40 acres" limit appears in the literature cited above (Koehler and Brittell 1990, Brittell et al. 1989). Incidentally, maximum opening sizes of 40 acres is also recommended for protecting grizzly bear habitat (IGBC 1986).

2. The LCAS and amendment fail to limit the size of openings due to logging, which should be limited and irregularly shaped such that they do not exceed 100 meters (330 feet) across

Research has shown that lynx typically do not cross openings greater than 100 meters across (Koehler and Brittell 1990), and therefore clearcuts larger than this may detriment lynx not only by the loss of that area to lynx, but also by serving as an obstacle to lynx movements. Washington Department of Natural Resources recommends against creating openings in lynx travel corridors greater than 100 meters (330 feet) across (WDNR 1996a).

3. The LCAS and amendment fail to ensure that cutting units are designed to preserve travel corridors for lynx across the landscape, especially along ridges, saddles and riparian areas; travel corridors must be greater than 100 meters (330 feet) wide

FWS explains the importance of spatial considerations when managing habitat for lynx:

"Lynx require adequate travel cover (frequently intermediate successional forest stages) to provide connectivity within a forest landscape for security, movement within home ranges, and access between den sites and foraging areas." (USDI 1998, p. 36995)

Brittel et al. (1989) and the USFS (1997, 1994) provide evidence to justify the 100-meter standard and some more specific recommendations for mitigating the effects of cutting units described above:

o cutting units must be contiguous with travel cover (Brittell et al. 1989);

o to function as travel cover, requires coniferous or deciduous vegetation greater than 6 feet in height (Brittell et al. 1989, USFS 1997);

o 40-60% of suitable habitat should function as travel cover (USFS 1997, USFS 1994);

o To function as travel cover, canopy cover should exceed 30% (USFS 1994);

o To function as travel cover, stem density should be at least 200 stems per acre (USFS 1994).

4. The LCAS and amendment fail to protect lynx from the harmful effects of forest roads year-round.

Logging roads should be minimized and kept as primitive as possible and should be closed and obliterated immediately after use (WDW 1993, Koehler and Brittel 1990).

B. Fire

We appreciate language within the LCAS that calls for increased use of fire to restore and maintain lynx habitat. We urge the Forest Service to use fire instead of logging or thinning wherever possible, because of its proven effectiveness over these other methods.

Wildfire was the disturbance mechanism that created and maintained lynx foraging areas historically, so it is likely to be our best tool to restore these areas today. Only where fire is not an option due to other management constraints may logging be appropriate as the next-best alternative to create similar conditions, provided it is carefully designed to do so (Brittel et al. 1989). Research has shown that there are significant differences between fires and clearcuts that imitate logging, mostly concerning the time required before the areas are productive foraging habitat:
o hares reoccupy severely burned areas within 15 months (Keith and Surrendi 1971, cited in Brittel et al. 1989), yet
o small mammal populations are "drastically reduced immediately following clear cut operations" (Brittel et al. 1989), such that
o hares may not recolonize clearcuts until 6-7 years after cutting, and may not reach high densities for 20-25 years (Koehler and Brittell 1990, summarized by Butts 1992)

These differences may be driven by discrepancies in vegetative production between areas cleared by logging and those cleared by burning:
o harvested areas provide less forage than naturally burned areas: regrowth of fewer than 250 lbs/acre versus fewer than 500 lbs/acre (Freedman and Habeck 1984, cited in WDW 1993)

Thus, fire appears to be significantly preferable to logging in creating foraging habitat for lynx. More recent lynx literature affirms this as well:

For the boreal forest, there are several general principles that must be addressed in landscape management plans if harvesting or fire disturbance is to be incorporated:
1. The habitat will be a product of the cumulative effect of all disturbances. The substitution of logging for fire, for example, is only meaningful if fire can be successfully removed from the environment, and even then, logging will not totally mimic fire as a disturbance process because of roading and coarse woody debris differences.
2. Typical models used for fire history studies suggest that fire selected a range of stand ages to burn. Harvesting only the oldest ages will decrease the average stand age of the landscape and will remove the complex boreal stand structure that may be critical for lynx denning. Young and old stands need to be part of any landscape disturbance plan.
3. Size and juxtaposition of stands is critical. Most fires are small. Most of the landscape, however, is affected by larger fire patches, with unburned areas inside the fire perimeter (stringers, islands, fire skips). (Ruggiero et al. 2000, III, 34)*

"Fire has played an important role in forest ecology in western mountain ranges of the United States. Forest fires naturally maintained mosaics of early successional forest stands, unburnt bogs and swamps, and late-successional conifer forest forming ideal snowshoe hare and Canada lynx habitat (Todd 1985; Fischer and Bradley 1987; Quinn and Parker 1987). During the early twentieth century, Federal and State agencies in the contiguous United States enacted a policy of suppressing forest fires. The lack of adequate hare habitat in southern latitudes may be partially a result of fire suppression during the past 50 years (Koehler 1990). Suppression of forest fires in the West has allowed forests to mature, thereby reducing habitat suitability for snowshoe hares and Canada lynx (Brittell et al. 1989; Fox 1978; Koehler 1990; Washington Department of Wildlife 1993; T. Bailey, U.S. Fish and Wildlife Service, in litt. 1994; H. Golden, pers. comm. 1994). Fire suppression is most likely affecting lynx habitat in areas where historical frequency of fires is shorter than the length of time fires have been suppressed in the Region (P. Stickney, U.S. Forest Service, pers. comm. 1994)." (USDI 1998, p. 37003)

C. Roads and Motorized Access

1. The LCAS and amendment fail to include road density standards that are needed to protect lynx habitat security. Road densities in all areas important to lynx should not exceed one mile of open road per square mile of habitat, and unroaded areas should remain that way.

A current study underway in south-central British Columbia is finding that roads affect lynx movements and suggests a mechanism for why the effects of roads on lynx may be more significant than movement data may suggest:

The likelihood of highway crossings by resident lynx can be expected to vary among home ranges according to proximal habitat conditions, width of road allowance and traffic volume, and perhaps by the animal’s sex and reproductive status. Although my analysis did not account for these factors, all lynx crossed highways less than random expectation within their 95% UD home ranges, suggesting that highways influenced lynx movements. Although my analysis only considered the influence of highways within home ranges, they may also influence home range selection just as dominant natural features can (Koehler and Aubry 1994), and this would decrease the substantive influence apparent within home ranges. (Ruggiero et al. 2000, XII, 9)

The same researcher cites a relevant study in Wisconsin where bobcats avoided roads:

... bobcats in Wisconsin selected home ranges with lower densities of secondary roads and crossed paved highways less than expected, a function of vehicle traffic levels and juxtaposition of preferred habitat to roads (Lovallo and Anderson 1996). (Ruggiero et al. 2000, XII, 9)

The Lynx Science Report mentions less-direct effects of roads, including the fact that increased access into lynx habitat for both people and competitors would likely result in increased lynx mortalities.

As in the taiga, we found little evidence that roads represented a significant disturbance or mortality factor for lynx. Roads into lynx habitat may, however, provide access to generalist competitors, such as coyotes and bobcats. (Ruggiero et al. 2000, XIII, 2)

Roads into areas occupied by lynx may pose a threat to lynx from incidental harvest or poaching (Koehler and Brittell 1990), increased access during winter for competing carnivores, especially coyotes (Chapter 4), disturbance or mortality from vehicles, and loss of habitat. (Ruggiero et al. 2000, XIII, 19)

In its proposed rule to list the lynx, FWS describes the problems of increased human access into lynx habitat, primarily due to roads:

"The likelihood of lynx encountering people has dramatically increased over the last few decades as a result of elevated levels of human access into lynx habitat. Roads and trails, snowmobiles, offroad vehicles, and ski area developments enable human access into historically remote forests, thereby increasing the likelihood of lynx being displaced from otherwise suitable habitats and increasing the vulnerability of lynx to human-induced mortality." (USDI 1998, p. 37008)

Elevated levels of human access into forests are a significant threat to Canada lynx because they increase the likelihood of lynx encountering people, which may result in displacement of lynx from their habitats and/or possible injuries or deaths by intentional or unintentional shooting, trapping, and vehicle accidents (Hatler 1988; Thiel 1987; Brittell et al. 1989; Koehler and Brittell 1990; Brocke et al. 1991; Andrew 1992; Washington Department of Wildlife 1993; Brocke et al. 1993; M. Hunter, University of Maine, pers. comm. 1994). Human access into Canada lynx habitat in many areas has increased over the last several decades because of increasing human populations and increased construction of roads and trails and the growing popularity of snowmobiles and offroad vehicles. In the interior Columbia River basin of Washington, Oregon, Idaho, and Montana, increased human access has decreased the availability of areas with low human activities, which are important to large forest carnivores, including lynx (U.S. Forest Service and Bureau of Land Management 1997)." (USDI 1998, p. 37005)

Although roads in and of themselves may not harm lynx — in fact, lynx may use them as for easy travel routes, and even benefit from foraging habitat along the roadsides — the associated human access typically overrides any positive or neutral aspects of roads into lynx habitat. FWS explains:

"Lynx will use some types of roads for hunting and travel (Koehler and Aubry 1994). Koehler and Aubry (1994) concluded road construction and maintenance are important components of lynx habitat management because they both destroy and create prey habitat, but also make lynx more vulnerable to human-caused mortalities...

Even roads that are considered "closed'' will continue to be accessible to snowmobiles, thereby allowing access to higher elevation lynx habitat by humans and lynx competitors." (USDI 1998, p. 37005)

FWS also relates the significant negative effects of roads that receive higher traffic, primarily due to direct mortalities and fragmenting lynx habitat:

"Blocks of suitable habitat, both public and private, are often dissected by extensive networks of paved roads. Traffic on highways has been shown to pose a considerable mortality risk to Canada lynx (Brocke et al. 1991; B. Ruediger, U.S. Forest Service, pers. comm. 1997). Highway densities are a contributing factor in the decline of carnivores, including the lynx, in the contiguous United States (Ruediger 1996). Dispersing or transient lynx are more vulnerable to traffic deaths than resident lynx because their movements over large areas increase their exposure to roads. In the Great Lakes States, recent records of lynx are from mortalities due to vehicle collisions, which could limit the potential for reestablishment of populations in Wisconsin or Michigan." (USDI 1998, p. 37005-37006)

Finally, FWS demonstrates the negative indirect effects of roads on legal and illegal hunting and trapping of lynx in both the U.S. and Canada:

"Increasing human access into Canada lynx habitat has increased the vulnerability of Canada lynx to both legal and illegal harvest in areas that, historically, were relatively isolated from humans (Todd 1985; McKay 1991; Washington Department of Wildlife 1993; M. Hunter, pers. comm. 1994). In the Uinta Mountains of Utah, most of the documented Canada lynx specimens were shot during deer hunting season in an area easily accessed by hunters (McKay 1991). In Washington, there is concern that human access may reduce the number of Canada lynx emigrating from British Columbia, further increasing the vulnerability of the remaining small population (Washington Department of Wildlife 1993). The high degree of access into Alberta's forests created by petroleum development and logging was suggested as an explanation for why Alberta produced a large proportion of the total Canadian lynx harvest in the 1970's and 1980's (Todd 1985)." (USDI 1998, p. 37006)

A review of other literature further supports these findings and argues for implementing standards to reduce roaded access into lynx habitat.

The impacts of roads include:
o roads increase access for hunters and trappers, destroy habitat for prey, and disrupt lynx travel and hunting patterns (Koehler and Brittell, 1990)
o direct loss of habitat
o indirect loss of habitat by avoidance of human activity areas
o greater accessibility to the legal trapper or hunter
o greater vulnerability to poaching... opportunities for illegal take will increase
o impacts from traffic include snowmobile use in the winter (Brittel et al. 1989)

Washington Department of Natural Resources is already implementing the following directions regarding road management (WDNR 1996a):
o minimize road width
o encourage vegetation on both sides
o reduce sight distance
o avoid loop roads
o close roads as soon as possible

Additional recommended standards include the following:
o [logging] roads should be kept to a minimum
o less than 50 ft. rights-of-way
o roads should be closed once timber harvest is complete, physical barriers
(Koehler and Brittell 1990, summarized by Butts 1993; Brittel et al. 1989)

Though lynx research has not yet defined a specific "threshold" road density for lynx habitat, it is clear that the fewer roads into lynx habitat the better. Where lynx habitat overlaps with grizzly bear habitat or important habitat for elk, FWS should urge hasty progress toward ensuring that road density standards to protect those species is made.

Road density analysis is an important component of determining habitat security with Lynx Management Units on the Kootenai National Forest (see below). The Kootenai Forest uses a Risk Index whereby open road densities of less than 1 mile per square mile rate a "low" risk, 1-2 miles per square mile rate "medium," and greater than 2 miles per square mile rate "high" risk of mortality (USDA 1997 at 6-3). These proposed thresholds are preliminary, but represent an important first step toward quantifying the adverse effects of roads on lynx habitat, toward highlighting problem areas. Again, such analysis is very much consistent and should be coordinated with efforts to maintain and enhance habitat security for grizzly bears, elk, and other species.

Another preliminary attempt toward establishing road density standards recommends a standard of 1 mile per square mile in "primary" lynx conservation areas, and not to exceed 2 miles per square mile in "secondary" lynx conservation areas (USDA 1994). Though it is not clear if these standards are adequate to promote the survival and recovery of lynx, they should be instituted on an experimental basis and lynx effects should be monitored to see if they are adequate or need to be strengthened.

2. Snowmobiles should be restricted in all areas where they pose a threat to lynx due to disturbance and/or allowing competitors access into lynx habitat. It is not enough just to cap existing use of designated routes and play areas.

While we appreciate direction in the LCAS and amendment that prohibits any increased snowmobile use, we are concerned that this may not be enough to recover the lynx in many areas. Perhaps most important, the proposed standard does not address dispersed use, which affects a far larger area of lynx habitat than designated routes. Further, the proposed standard does not address snowmobile use in areas where existing levels are already harmful to lynx. To resolve these problems, the amendment should be revised so that it restricts snowmobile use in all areas where it is harmful to the lynx. Since dispersed use can be difficult to restrict, we urge the Forest Service and BLM to confine all snowmobile use in lynx habitat to designated routes and play areas, as is now the case for off-highway wheeled vehicles. Each of these routes and play areas should then be analyzed to ensure that they do not adversely affect lynx, either by degrading habitat security from people and activity or by allowing lynx competitors access into lynx habitat otherwise inaccessible to them (via snow compaction). Expanding regulations that address motorized access to include snowmobiles will benefit many other species besides lynx, by restoring and maintaining secure winter and early spring habitat for grizzly bears, wolverines, fishers, moose, elk, deer, and many other species.

There is ample scientific evidence to justify a reduction of snowmobile use in lynx habitat, including both designated routes and dispersed use. The following excerpt from the Lynx Science Report provides a nice summary (Buskirk et al. 2000, pp. 94-5):

"Numerous reports describe coyotes accessing high-elevation, deep snow areas by moving along paths, roads, and snowshoe hare trails (Bider 1962; Ozoga and Harger 1966; Murray et al. 1995). Unpublished data from Oregon (USDA Forest Service, unpublished report) and Colorado (Byrne 1998, unpublished) also suggest that coyotes use high elevation areas, although their means of access is not known. Byrne (1998,unpublished) conducted track surveys for snowshoe hares and recorded other species' tracks on 1,160 km of snow transects within presumed snowshoe hare habitat (7,500-11,800 feet elevation) in winter. Coyotes were the second most common carnivore taxon (after weasels) encountered, with 628 tracks recorded. The elevation zone with the highest frequency of coyote tracks was 8,000-9,000 feet but coyote tracks were fairly common (about 0.45/km of transect) in the 9,000-10,000 and 10,000-11,000 foot elevation zones. These results indicate that coyotes are much more common in high elevation, deep snow areas of western mountains than generally has been believed to be the case.
Nevertheless, some basis exists to believe that coyotes and lynx are spatially segregated in winter by deep snow. In central Alberta, Todd et al. (1981) found that coyote use of open habitats increased from November to March, which they attributed to snow accumulation in forest and the greater compactness and load-bearing strength of snow in openings. This intolerance of deep snow resulted in a diet shift from snowshoe hares to ungulate carrion in winter. Also in Alberta, Murray et al. (1994) found that coyotes were more selective of hard or shallow snow conditions than were lynx. In the western (Murray and Boutin 1991) and northeastern United States (Litvaitis 1992), this morphological difference causes coyotes and lynx to be spatially segregated by snow conditions. In the West, this occurs along an elevational gradient. Such separation should minimize competition between the two species. However, this separation may break down where human modifications to the environment increase access by coyotes to deep snow areas. Such modifications include expanded forest openings throughout the range of the lynx in which snow may be drifted, and increased snowmobile use in deep snow areas of western mountains. Recreational snowmobile use has expanded dramatically in the contiguous United States in the past 25 years, with hundreds of thousands of km of trails (>19,000 km of groomed trails in Maine alone) within the pre-settlement range of the lynx (Maine Snowmobile Association, World Wide Web site, Zesiger 1997). Various unpublished accounts describe snowmobile and snowshoe trails facilitating access by coyotes to areas used by hares and lynx. In the Yukon, coyotes use both snowshoe and snowmobile trails (O ’Donoghue, personal communication). This facilitation of travel, in general, could help explain possible lynx reductions in the West via human-facilitated competition from coyotes and other generalist predators. Better understanding of this postulated relationship is critical."

D. Connectivity vs. Fragmentation

As mentioned in Part I above, we are concerned that the LCAS and amendment fail to ensure that adequate and timely measures will be taken to reverse the fragmentation of lynx populations within the U.S. populations, and between lynx populations in both the U.S. and Canada.

1. US/Canada connectivity

Because of the interdependence between lynx populations in the U.S. lower-48 states and southern Canada, U.S. land and wildlife officials should: (1) approach Canadian officials toward maintaining contiguous lynx populations, and (2) direct even more precautionary management of U.S. habitat given the threat to this connectivity.

The importance of this to recovery in the U.S. is appropriately highlighted in publications by the Forest Service and Fish and Wildlife Service:

We cannot assume that lynx populations in the contiguous United States will be maintained by dispersal of lynx from Canada, nor that connectivity with larger habitat areas in Canada will be maintained in perpetuity. Although cooperative conservation efforts with Canadian land management agencies should be explored in all areas of adjacent lynx habitat, we believe that lynx conservation efforts in the contiguous United States should be addressed at geographic scales that will provide for the persistence of resident populations of lynx, regardless of periodic augmentations that may occur from other areas. Clearly, ecoprovince-wide planning is necessary to provide the broad-scale information necessary for effective conservation of lynx. (Ruggiero et al. 2000, XV, 9)

"... dispersal of Canada lynx into the contiguous United States may now be necessary to replenish lynx numbers because of the current status of lynx in the contiguous United States." (USDI 1998, p. 36996)

FWS notes that lynx populations in Washington are particularly vulnerable:

"Recolonization of suitable lynx habitat within the State of Washington eventually may be precluded by the fragmentation of habitat and potential isolation from the lynx population in Canada (Washington Department of Wildlife 1993)." (USDI 1998, p. 37003)

Efforts to persuade Canada to conserve lynx habitat should include trapping restrictions as well as forest practices. FWS notes some problems with current management in Canada:

"In Canada, management of forest lands and conservation of wildlife habitat varies depending on Provincial regulations. In Alberta, there is no law regulating forest practices and the status of Canada lynx in Alberta is of concern because of habitat-related threats as a result of logging (B. Triechel, Alberta Environmental Protection, pers. comm. 1997). There is no overarching forest practices legislation in Canada, such as the United States' National Forest Management Act, governing management of national lands and/or providing for consideration of wildlife habitat requirements. Additionally, in Canada, lynx harvest regulations vary, being regulated by individual Province or, in some cases, individual trapping district." (USDI 1998, p. 37007)

2. Connectivity within the U.S.

Actions are needed to reduce the threat to lynx due to fragmentation at the regional and local levels within the U.S.

a. Connectivity between populations

Again, as mentioned in Part I of our comments above, we do not believe that the proposed amendment goes far enough to address the threat of past and ongoing fragmentation of lynx populations in the U.S. northern Rockies. FWS summarizes the threats to lynx due to its fragmented status in the lower-48 states:

"Loss of suitable habitat for Canada lynx reduces the potential for population growth or recolonization of the lynx and further confines lynx to smaller, more isolated habitat units (Weaver 1993). Isolation increases the susceptibility of the lynx to human-caused threats, natural stochastic events, and effects of genetic bottlenecks (Andrews 1992; Weaver 1993). In the Rocky Mountain/Cascades Region much of lynx habitat is naturally disjunct and habitat connectivity is required across large geographic areas to facilitate dispersal and genetic exchange (Roloff 1995). The increased fragmentation of forest lands and loss of connectivity within and among blocks of habitat in the interior Columbia River basin of Washington, Oregon, Idaho, and Montana has reduced the ability of some wildlife populations to move across the landscape, resulting in long-term loss of genetic interchange (U.S. Forest Service and Bureau of Land Management 1997)." (USDI 1998, p. 37005)

FWS' own research demonstrates the especially vulnerable status of lynx populations in the Northeast, Lake states, and the southern Rockies due to their isolation from other lynx populations. Thus, these populations merit the highest level of protection:

"Within the contiguous United States, the lynx population is divided regionally by ecological barriers consisting of unsuitable lynx habitat. These regions are the Northeast, the Great Lakes, and the Rocky Mountains/Cascades." (USDI 1998, p. 36996)

b. Connectivity within populations

Within populations as well, barriers to lynx movement must be considered because they may represent a major obstacle to lynx survival and recovery. FWS offers Maine as an example:

"Although localized habitat conditions have improved [in Maine], reoccupation of these areas may be impeded by barriers to lynx immigration, such as paved roads with high-volume traffic, non-forested agricultural habitats, or other intervening areas of suitable habitat." (USDI 1998, p. 36996)

The USFS has already responded to this problem on the Kootenai National Forest, where lynx locations were mapped, and then identified ten "areas of concern for lynx movement across the forest." Management activities within these areas are reviewed for their effects on maintaining connectivity for lynx across the Kootenai Forest (USDA 1997, p.6).

E. Cumulative Effects Analysis

We appreciate the designation of Lynx Analysis Units across federal lands within the northern Rockies as a first step toward ensuring that conditions improve for the lynx, but we are concerned that the LCAS and amendment do not go far enough to ensure that lynx will be adequately protected from the cumulative effects of all human developments and activities within a given LAU. We are also concerned that the LCAS fails to ensure adequate monitoring of lynx within the LAU's, to determine if the strategy is working to recover lynx or if more protections are needed.

Because of the diversity of threats facing lynx survival and recovery across the landscape, a process of cumulative effects analysis is needed to assess the combined magnitude of these threats and implications for future management. Cumulative effects analysis can also provide a means to monitor the habitat quality of an area: that is, its ability to provide the security and various other components for denning, foraging, travel, and other lynx needs.

We also commend the Kootenai National Forest for its precedent-setting work on this, and urge that the Forest Service, BLM, and FWS work to ensure that it is applied throughout all areas of lynx habitat. The Kootenai Forest's Lynx Management Unit (LMU) areas correspond to the estimated home range sizes of female lynx in the area. Other considerations in delineating their LMU's are described in a USFS memo on the subject (1997):
o Areas need to be small enough to show effects of projects
o Areas need to contain all habitat components necessary to support female lynx (existing or potential)
o Areas need to be aggregated up to a larger scale for cumulative effects
o Planning sub-units make efficient analysis areas, as do compartments on some districts

"Blocks" of suitable habitat within each LMU were evaluated based on their area and proximity to other blocks of habitat, such that small blocks that were at the limits of daily movements of lynx (2-5 miles away) were not considered suitable. The LMU process is still in its preliminary stages on the Kootenai, but forest officials claim that the system will ensure that they fulfill their viability objectives for lynx as directed in the National Forest Management Act: "With this strategy, it is the Kootenai National Forest biologists consensus opinion that lynx persistence on the Kootenai National Forest is assured" (USDA 1997, p. 6-1).

In Closing

Thank you for the opportunity to provide detailed comments on this proposed amendment, which we support and applaud as a fundamentally important first step toward restoring the lynx in the northern Rocky Mountains, but we believe the amendment should be considerably stronger to reverse the declining range and numbers of lynx throughout the region. Please contact us for any additional information pertaining to these comments, and please provide us with timely updates of future developments on this issue.

Sincerely,



David Gaillard
Program Associate
Predator Conservation Alliance

Mike Leahy
Natural Resources Counsel
Defenders of Wildlife

cc: U.S. Forest Service Chief Dale Bosworth
U.S. Forest Service Rocky Mountain Research Station, Missoula, Montana
U.S. Fish and Wildlife Service Director, Denver Office, Helena Office
Mr. Eric Glitzenstein, Attorney at Law, Meyer and Glitzenstein, Washington, DC
Mr. William Snape, Attorney at Law, Defenders of Wildlife, Washington, DC

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