These comments reflect my abbreviated thoughts on the proposal for the IBA to endorse the delisting of the grizzly bear in the Yellowstone Ecosystem. I feel that this is not an appropriate issue for the IBA, but is more appropriate for individual members to address, primarily because of its highly political nature. The question of process seems clear to me: recovery goals have been met. The larger question is whether those goals are adequate. I feel they meet goals for short-term population stability, but there are no habitat standards to ensure that current conditions are sustainable. Goals fall far short of long-term viability: the genetic effective size of the current population is about 1/4 of that needed to maintain genetic variability. Adding a new animal every ten years is unlikely to provide the necessary gene flow considering the low success of transplants into occupied habitat, much less filled to carrying capacity.

The overarching question is the political climate in which this proposal is being made. In my opinion, this puts it beyond the mandate of the IBA. Delisting the grizzly under the Bush Administration is the worst possible decision. Nationwide recovery goals include "viable" populations in all recovery areas, yet this administration blocked reintroduction of grizzlies into the Selway-Bitterroot area, effectively preventing long-term recovery. There is no reason to believe that delisting bears in the GYE will improve chances to recover them in the Selway-Bitterroot. Instead, I believe the most likely scenario is that extractive industry activities will surge in all habitat that was previously off-limits due to the ESA, effectively shrinking the size of the habitat island in which the bears now survive.

Current management has worked well and the population in the GYE has increased. To ensure that favorable conditions continue, we should wait for a less hostile political climate. Management plans developed by Montana, Idaho, and Wyoming may be sufficient to maintain grizzly bear numbers, but the population can decline markedly before such changes are detected and habitat requirements are not sufficiently addressed. Moreover, I understand that state management plans are not legally binding. Although many state biologists and mangers will do their best to maintain grizzly populations, they will not ultimately make the decisions regarding grizzly bear habitat.

Lance Craighead