Talking Points for USFWS Comments, #2

Comments are due by 11:59 p.m. on October 7, 2016. You do not have to be a resident of the United States to comment. 

Pursuant to Serena Baker of the USFWS, you are welcome to comment as many times as you want and all comments are read and considered.  The substance of your comment is the key factor not the number of times you comment, so you are welcome to include all your comments and documents in one comment.  If you have not commented previously, you can view our talking points for the first round of comments. These may be used now if this is your first comment.

Please REWORD the talking points below when writing your comments. In addition, please cite the peer review source for your comments where applicable. Please note that not all of the talking points include citations. Use as many of the following talking points as you like. Please prepare your comments in a separate document and then copy and paste them into the USFWS comments page AND email them to Secretary Jewell at exsec@ios.doi.gov.

If you have more time and have not already done so, please use some of these talking points as well. 

Submit your comment here. 

Federal agencies must engage in meaningful consultation with the tribes. Pursuant to Executive Order 13175, implemented by President Clinton and affirmed by President Obama, federal agencies MUST engage in a meaningful consultation process with the tribes when decisions are being made that affect the tribes. USFWS should have consulted with the tribes from the beginning but has failed to do. As a result, the delisting process should be immediately paused to enable proper consultation to occur between the federal government and each of the impacted tribes. 

Further Public Comment Needed. Even in the peer review, there were significant concerns expressed regarding the draft Conservation Strategy. The Conservation Strategy must incorporate updated information and the revisions should be released for public comment and review. (Peer Review 21). Prior to publishing the final rule, the public should have the chance to comment on a complete proposed delisting package with a final Conservation Strategy, all final revised and enforceable state management plans and regulatory frameworks as well as the peer review.

Mortality Limits. USFWS’s calculation of mortality limits is far too high given how slowly grizzly bears reproduce. Further, the limits do not account for the possibility to overshoot these bounds. (Peer Review 15, 41). Even more concerning, in 2015, while Endangered Species Act protections were still in place, the independent female mortality exceeded the limit. This violation was omitted from the IGBST report but has been acknowledged by Mr. Wayne Kasworm of the USFWS. Despite that acknowledgment, nothing has been done to address the violation of female mortality limits in 2015. If this issue is unaddressed now, why should the public believe that things will be better when grizzlies are delisted?

No binding commitments on the states. There are no enforceable limits on mortality once delisting has occurred. The Conservation Strategy, itself, does not compel any agency to do anything. In fact, even if deaths exceed prescribed levels, no agency is required to do anything. USFWS has a duty to the American people for continued conservation of the grizzly bear species. Unfortunately, Montana, Idaho and Wyoming have not offered the necessary  assurances that grizzly bears will continue to be conserved into the future. Rather, the states have rushed to put trophy hunting frameworks in place, revealing their true motivations.

In addition to submitting your own comment, please also sign on to the following comment letters from WildEarth Guardians, Humane Society of the United States and Center for Biological Diversity.

- WildEarth Guardians letter

- Humane Society letter

- Center for Biological Diversity letter 

- Sierra Club Letter

- NRDC Letter