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Saturday, March 25, 2017

Help Restore the North Cascades' Grizzly Bears

The National Park Service and Fish and Wildlife Service are taking comments on a plan to restore
Grizzly bears to Washington State's North Cascades Ecosystem. The plan's four alternatives (A,B,C,D) take between 25 to 100 years to reach the goal of 200 bears. The plan can be found here.

The federal government is taking comments on its plan.

The plan's Alternative D best complies with federal law, produces the most public benefits, while minimizing environmental and social costs. Click here to add your name to the growing list who ask the National Park Service to adopt Alternative D.


Grizzly Bears once roamed from the Arctic circle to Central America, from the Pacific ocean to America's great plains. At their peak, the United States' had approximately 50,000 bears.

At parks like Glacier and Yellowstone, Grizzly bears were nearly wiped out. However in 1975, the federal government placed the Grizzly bear on the Endangered Species List and due to strong action, bear populations in these two parks have rebounded from a few dozen individuals to roughly a thousand today.

We now have a chance to repeat this success at the North Cascades National Park. Please add your voice to those who support Grizzly Bear restoration. Click here to sign the petition.

My comments on this plan follow.


March 25, 2017

Karen Taylor-Goodrich


National Park Service

North Cascades National Park Complex

RE: Draft Grizzly Bear Restoration Plan/Environmental Impact Statement/ North Cascades Ecosystem

Dear Ms. Taylor-Goodrich

I write in support of the U.S. Fish and Wildlife Service (FWS) and National Park Services’ (NPS) efforts to restore and maintain a health Grizzly Bear population in the North Cascades Ecosystem (NCE).  In particular, I fully support Alternative D with an accelerated recovery time frame and ask the FWS and NPS to implement this alternative as soon as possible.

As a former park ranger who has worked at the North Cascades, Yellowstone, and Glacier National Parks I’ve had significant experience working, living, and playing in Grizzly country.  I’ve encountered dozens of bears during my time in these parks, and every encounter left me exhilarated and grateful that my country is big enough to set aside some truly wild places for Grizzlies to live. 

During my time at these parks I also came in contact with tens of thousands of visitors from all over the world. Nearly every one of these visitors came to these parks with the hopes of seeing a bear in general and a Grizzly bear in particular.  It was my experience, that for those who did see a Grizzly they realized it was likely a once in a lifetime experience, something they would cherish.

The FWS and NPS have a unique opportunity to increase the chance the present and future generations have the opportunity to also have this “once in a lifetime experience” by augmenting the NCE Grizzly population.


As the Draft Grizzly Bear Restoration Plan (EIS) rightly points out, the FWS and NPS are required by both federal statute and case law to restore endangered species, leave that National Park System unimpaired for future generations, protect wilderness, and conduct a thorough analysis.  The EIS’s stated purpose is to “restore the grizzly bear to the NCE” which I wholeheartedly agree with. Alternative D would achieve this stated purpose at the quickest time possible while producing maximum benefits, and minimizing long-term costs.  Alternative D also, and likely most important, best complies with federal statutes, policy, and case law.

On page i of the EIS the FWS and NPS state that historical records indicate that Grizzly bears once “occurred throughout the NCE.”  Later on page ii of the EIS the lead agencies write that Grizzly bears in the NCE are at risk of local extinction.  Extinction as defined by the encyclopedia Britannica is “the dying out or termination of a species. Extinction occurs when species are diminished because of environmental forces (habitat fragmentation, global change, overexploitation of species for human use) or because of evolutionary changes in their members (genetic inbreeding, poor reproduction, decline in population numbers).” Extinction can take place at many levels including the loss of local populations and scientific studies on the removal of apex predators are finding this extinction represents a lasting injury or impairment to that ecosystem. Further, the extirpation of Grizzly bears from the NCE represents a violation of the Endangered Species Act’s prohibition of the extinction of listed species, the NPS Organic Act’s requirements that park resources and wildlife be left unimpaired and for the enjoyment of both present and future generations, the Wilderness Act’s requirement that wilderness areas be managed to preserve natural conditions and appears to have been affected primarily by the forces of nature, with the imprint of man's work substantially unnoticeable, as well as the National Environmental Policy Act’s requirement that federal agencies prepare detailed statements assessing the environmental impact of and alternatives to major federal actions significantly affecting the environment.

Alternatives D is the only viable alternative and best complies with federal law

A healthy Grizzly Bear population would produce many benefits for the park, surrounding national forests, gateway communities, tribes, and industries.  By contrast Alternative A, B, and C produce fewer benefits, greater costs, at longer time frames and appear to violate federal law and policy.

ESA Mandates

As stated above, federal law such as the Endangered Species Act requires federal agencies such as the FWS, NPS, and the United States Forest Service (USFS) to prevent the extinction of federally listed species. Since 1975 the Grizzly Bear has been listed as threatened in the continental United States. The draft EIS states on page 1 that it is currently highly unlikely the NCE contains a viable Grizzly bear population. In fact, the EIS states that all four documented grizzly bear sightings in the NCE are the result of 2 bears. Two bears by is not a viable population, which by definition is one that faces near-term extinction.

NPS management policies also require proactive action on preventing local extinction. Specifically, the 2006 policies states it is NPS policy to “pass on to future generations natural, cultural and physical resources that meet desired conditions better than they do today, along with improved opportunities for enjoyment.” Emphasis added.

It’s clear that Alternative A does not comply with federal law and policies which require the FWS and NPS to take immediate action to prevent extinction.  Alternatives B and C also appear questionable in their compliance with federal mandates, while Alternative D, by contrast, best complies with these requirements.

Organic Act Mandates

Next, the recovery time frames as stated in the no action and alternatives B and C are far too long and likely make them illegal. 

The Organic Act requires the NPS to leave park resources unimpaired for the enjoyment of both present and future generations.  NPS’ knows the enjoyment mandate that is contemplated is this statute:

“is broad; it is the enjoyment of all the people of the United States and includes enjoyment both by people who visit parks and by those who appreciate them from afar. It also includes deriving benefit (including scientific knowledge) and inspiration from parks, as well as other forms of enjoyment and inspiration. Congress, recognizing that the enjoyment by future generations of the national parks can be ensured only if the superb quality of park resources and values is left unimpaired, has provided that when there is a conflict between conserving resources and values and providing for enjoyment of them, conservation is to be predominant. This is how courts have consistently interpreted the Organic Act.”

At a minimum, the FWS and NPS estimate it will take between 60 to 100 years, if not longer, for Alternatives B and C to reach the target population of 200 bears. Alternative A will take even longer. These timeframes prevent present generations from enjoying a recovered Grizzly bear population whether through direct visits, from afar, through scientific research and inspiration. They also prevent a significant portion of future generations from enjoying these bears. This is a violation of the Organic Act’s mandate that parks be provided for present day and future enjoyment.  Alternative D by contrast comes closest to complying with the Organic Act, however even its 25 year recovery time is likely too long.

Wilderness Act Mandates

The 1964 Wilderness Act requires federal agencies to manage designated wilderness “an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain.” This mandate includes the restoration of a wilderness area’s “wilderness character.”  The Forest Service in an interagency report defines wilderness character to include an area that is untrammeled, undeveloped, natural, and provides an opportunity for solitude or primitive and unconfined recreation. The Forest Service notes that wilderness character is degraded by many things including the “Extirpation or extinction of native animals and plants.” The Forest Service also understands that Congress has made clear that preserving wilderness character is the act’s primary legal mandate.

According to the Natural Resource Conservation Service, Grizzly bears once ranged from the Arctic Slope to Central Mexico and from the Pacific Coast to Minnesota.  Today, “the grizzly mainly occupies high mountain wilderness areas.” 

It’s clear that federal law and policy requires agencies like the FWS, NPS, and the USFS to protect not just wilderness but its wilderness character.  Grizzly bears according to the federal government are mainly associated today with high mountain wilderness areas like the North Cascades.  By its own admission, the federal government recognizes the extirpation of a native wilderness species is a degradation of wilderness barred by federal law.  As stated above, the EIS’s no action alternative is unlikely to save the bear from local extinction and therefore does not comply with the Wilderness Act.  Alternative D on the other hand,  best complies with this act, by returning Grizzly Bears to a stable population at the shortest time possible, and thus better restoring the wilderness character of the NCE also at the shortest time possible.

NEPA Mandates

The National Environmental Policy Act requires federal agencies to assess the environmental effects of their proposed actions prior to making decisions. Agencies are required to assess and consider all reasonable impacts to the affected environment.  It appears the draft EIS may violate NEPA for its analysis fails to adequately address the following issues.

1.      The EIS doesn’t appear to investigate Grizzly bear extirpation and its impact upon the NCE.  The removal of large predators such as the Gray Wolf and its impact upon the environment have been studied at national parks like Olympic and Yellowstone.  A similar analysis of the impacts of Grizzly bear extinction in the NCE should be conducted in this EIS before making a decision.

2.      The EIS also appears to overplay the negative impact of Grizzly bear augmentation may have upon park visitation. Rather, visitor studies out of Alaska show that park visitors often come to parks like Denali with a hope and expectation of seeing a bear. The vast majority of park visitors to Denali see Grizzly bears and many come away from the experience with a higher commitment to conservation.

Meanwhile, at parks like Yellowstone and Glacier Grizzly bear recovery has had no negative impacts upon park visitation. When grizzlies were listed as threatened in 1975, Yellowstone’s annual visitation was 2.2 million, while Glacier’s was 1.5 million.  Today those parks’ visitation numbers are 4.2 million for Yellowstone and 2.9 million for Glacier. Meanwhile during this same time, Grizzly bear populations at Yellowstone went from approximately 130 bears in 1975 to more than 700 today. Meanwhile at Glacier went from a low of a few dozen bears to more than 300 today.  Obviously, Grizzly bears have not had a negative impact upon park visitation.  


Grizzly bear recovery in the NCE enjoys broad public support and similar to Yellowstone, Denali, and Glacier, is unlikely to negatively impact visitation.  If fact, a case could be made that a viable Grizzly bear population may actual improve NCE visitation.

3.      There appears to be a similar overplay in the EIS of the threat Grizzlies pose to public safety.  As stated above grizzly bear populations have dramatically increased over the past half century at Yellowstone and Glacier from a few isolated bears to healthy populations of hundreds today.  Over these parks’ more than 100 year histories less than a dozen visitors respectively have been killed by Grizzly bears.  One is just about as likely to be killed by lightning as a Grizzly bear in these parks. Visitors are far more likely to die from drowning, heart attacks, or falls.  These trends would likely be similar at NCE.

4.      Some are also raising concern about new bears and their impact upon salmon runs.  These concerns are overblown.  The NCE contains some of the best Grizzly bear habitat in the continental United States. Alternative Grizzly bear foods sources are plentiful in the recovery area.  The FWS and NPS both find that Grizzly bear recovery will have little impact upon NCE fish stocks.  On page 105, the FWS and NPS state “Fish are not expected to be a primary food source, and the number of Grizzly bears in the ecosystem would not be sufficient to generate adverse impact on fish populations as a result of predation.”

5.      Livestock predation is the final area where more analysis needs to be conducted.  On page 145 of the EIS it states that “concerns have been raised about potential for depredation of livestock.” Concerns have been raised about the potential for [Grizzly bear] depredation of livestock.  While this is a possibility, it is very remote. Grizzly bears have been known to kill livestock such as cattle and sheep, but through good livestock management such as the elimination of bone yards and active herd monitoring livestock deaths can be reduced.  Researchers have found bears tend to prey on livestock because it tends to represent an easy foraging opportunity.  However, these impacts will be less in NCE because the area already contains excellent Grizzly bear habitat with outstanding non-livestock foraging opportunities.  Moreover, the scope of the threat will be smaller in NCE.  On page 74 of the EIS it states there are more than 220,000 heads of cattle in the region of influence.  By comparison the Greater Yellowstone Ecosystem (MT, ID, WY) has at least double this many heads of cattle.  Moreover, there are few firm numbers on the number of cattle killed by grizzlies but it’s likely around 30 to 40 per year.  With both fewer cattle and bears than the GYE, the NCE is likely to see far fewer Grizzly cattle predations.

6.      Finally, the NCE has set 200 bears as the target population.  However, counting Grizzly bears is not straight forward.  Researchers out of Yellowstone report that coming to a Grizzly bear population estimate is not simple.  The draft EIS seems to underplay the time, energy, and resources needed to accurately count NCE bears.  Without a better explanation of how the FWS and NPS plan to count NCE bears, public confidence in any Grizzly bear population numbers will be questionable at best.

I appreciate both the Fish and Wildlife Service and the National Park Service’s efforts to recover the NCE’s Grizzly bear populations.  I encourage the FWS and NPS to choose Alternative D with an accelerate recovery time frame.  This alternative best complies with federal law, maximizes public benefits, while minimizing costs.


Sean Smith

Covington, WA 98042

Former North Cascades National Park Ranger

Former Yellowstone National Park Ranger

Former Glacier National Park Naturalist