Ten organizations filed formal comments on the U.S. Fish and Wildlife Service 5-Year Status Review of Grizzly Bears. They were submitted by Mike Bader, independent consultant on behalf of the Flathead-Lolo-Bitterroot Citizen Task Force, Friends of the Clearwater, Wilderness Watch, Friends of the Bitterroot, Alliance for the Wild Rockies, Western Watersheds Project, WildWest Institute, Wild Earth Guardians, Kootenai Environmental Alliance and Brian Peck, Independent Wildlife Consultant.

They wrote: “Many aspects of the status of the grizzly bear remain unknown as the Service cannot manage what it has not measured,” noting that analysis of vegetation, prey and potential climate change effects remains undone and rapidly expanding human population and large increases in visitors and backcountry recreational use haven’t been taken into account.

The organizations state that record high mortality, inadequate regulatory mechanisms on Forest Service lands, new recreation threats, food security and attractants storage on both public and private lands, chickens in grizzly habitat and black bear baiting in Idaho and Wyoming are new threats that must be addressed in the Five Year Review.

The organizations cite five scientists with more than 150 years of expertise in grizzly bears who conclude the current recovery areas will not support enough grizzly bears to constitute a viable population.

“These scientists all agree the only way to recover grizzly bears in the Northern Rockies is to link the five isolated recovery areas with linkages of protected habitat with sufficient security to allow occupation by both male and female grizzly bears. Recovery of grizzly bears requires reestablishment of a third major breeding population in the Selway-Bitterroot region in Idaho to provide core habitat and regional linkage between the other Recovery Areas.“

Flathead-Lolo-Bitterroot Citizen Task Force et al Five Year Status Comments (PDF)

Agency rules that grizzlies are protected, Bears in Selway-Bitterroot are under ESA protection, Missoulian - January 26, 2020 (PDF)