Amendment 19

Because several planning and project proposals on the Flathead Forest are currently in the initial stages, the information in this report is needed immediately by concerned stakeholders. Our investigations into the appropriateness of Amendment 19 continues and this report will be updated when new information is discovered.

In March 1995, the Flathead National Forest adopted Amendment 19 to its forest plan. The amendment was initially required by a judicial decree that contrary to USFWS and USFS Biological Opinions, the FNF Allowable Sale Quantity (ASQ) threatened grizzly bear survival. The court ordered the FNF to re-consult with the USFWS to re-examine its ASQ for timber because the judge agreed with the plaintiffs that the amount of timber that could be sold was threatening grizzly bear survival. When the amendment was completed, it included restrictive standards for road densities and bear security core areas. The amendment was based on a progress report from the South Fork Grizzly Bear Study which hypothesized on the effects of roads on grizzly bear. The USFWS and USFS interpretation of that report allows for only 1mi./sq. mi. of open road and 2mi./sq. mi. of total road density. Roads must be closed or obliterated to meet the standards. Implementation was to be phased over ten years.

The Final Report of that study issued in 1997 had no conclusions or recommendations for the destruction of roads. Instead the report concluded that "strict road access programs on national forest lands will not be sufficient to significantly improve the population trajectory if mortality and habituation of bears on private lands is not reduced" and recommended seasonal road closures( p. 121). The USFWS has never updated their opinion based on the "best science available" (the final report), nor has the FNF attempted to revise or amend the Plan in that respect. The FNF has never even come close to the lowered ASQ because road closures and other perceived environmental factors have prevented the implementation of a reasonable timber sale program. Therefore the lowered ASQ itself has not had much impact on the local economy or the custom and culture of the local area. However, the closure and obliteration of roads has proven very detrimental to local social and economic functions and continues to be the most controversial of FNF activities.

INNAPPROPRIATE LEVEL OF NEPA COMPLIANCE

Amendment 19 was processed through NEPA as an EA with a Finding Of No Significant Impact (FONSI). However this amendment has had major impacts on recreation, fire management, the local economy, timber management, public access, and forest health. Therefore the FONSI was inappropriate and Amendment 19 proscriptions should be enjoined. The EA documented that there would likely be a loss of timber jobs, revenue to counties and motorized recreation. The EA also conceded that there would be other adverse economic impacts deriving from these losses. In fact, this has proven to be the case.

HUMAN IMPACTS OF A19 UNDERVALUED

Not only were, the adverse social and economic impacts not accorded sufficient importance in the EA, but they were also undervalued. This is because the overriding cause of those impacts, road closures and obliterations, was undervalued. The EA claimed that a total of 650 miles of road would be obliterated due to A19 requirements. According to the Daily Interlake, forest officials say that FNF "…still has an estimated 600 miles of forest roads that must be closed and reclaimed in order to comply with Forest Plan road density standards — a staggering number considering that just 320 miles have been obliterated since the standards were established in 1995." Yearlong road closures were likewise underestimated.

As predicted in the EA, sawmill capacity has declined as timber sales plummeted on the FNF. One medium sized mill, 140 employees, has closed and two others are operating on the verge of economic viability due in large part to the decrease in timber from FNF.

Although A19 is not completely responsible for the decline in timber sales many think it is the largest single contributor to that decline.

Motorized OHV use has declined or been crowded onto fewer trails. For example, the West Side Reservoir Post-Fire Project proposes to close almost 50 miles of trail to motorized use soley because of A19 standards. Presumably it will be left open to foot travel.

The Custom and Culture of the Flathead Valley has been adversely impacted by A19. No one knows how many local people have lost access to their favorite hunting, fishing, huckleberry picking or camping spot because of A19 road closures.

In 2000, Flathead County included a question on the primary ballot about road closures on the FNF. Voters were asked if they approved of road closures and FNF road management in general. 78% of the voters in Flathead County voted NO. Clearly, these voters believe that they have been adversely impacted. The frustration and anger that many Flathead residents experience because of the road policy mandated by A19 is evident at every public meeting in the county where forest issues are discussed.

COST OF RECLAMATION WAS UNDERVALUED

The Interlake article cited a cost of $5000/ mile for reclamation but a FNF roads expert told members of a Wedge/Roberts Collaboration group that the average cost was $7000 per mile for culvert removal and about the same amount to put them back in if that became necessary. This cost does not include recontouring the roadbed. This same official cited an average cost of $45,000/ mile for new road construction. The true economic cost of reclamation must include an amount for lost opportunity cost. Lost opportunity cost should include the cost of restoring the road if it becomes necessary or desirable at a later date. Assuming that recontouring was not done, the opportunity cost for restoration of the road, mainly replacing the culverts, would average at least $7000/mile if it is done in the near future, more as time goes by. If we assign a average cost of $6000/mile for minimum reclamation of all 920 miles of road that A19 requires (past, present and future) and add to that $7000/mile for opportunity cost, the cost of obliteration would be $11,960,000 for full implementation. Another way to assess the lost opportunity cost is to recognize that the value of a forest road is at least as much as the construction cost, therefore the lost opportunity cost of destroying these roads should be at least $45,000/mile. Therefore the cost of complete adherence to A19 is at least 45,000 + 6000 x 920 miles = $46,920,000

Lost opportunity cost should also include the additional costs of fire fighting and lost timber values, which runs into the millions, due to inability to address fires at an early stage because of closed and obliterated roads. It should also include the cost of loss of timber values due to disease and insect damage that could not be addressed because of inaccessibility exacerbated or caused by obliterated roads.

The Daily Interlake suggests that Forest Supervisor, Cathy Barbouletos, finally recognizes the high cost of road reclamation.

"Considering the cost per mile for reclaiming roads, Barbouletos suggests that money could be far better spent on bear conservation education programs or on bear managers who work to discourage conflicts between bears and humans.

"What Amendment 19 does is make us go straight to road reclamation every time," she said. "What we need to do is consider whether those dollars could be spent better elsewhere.""

INCREASED RISK OF CATASTROPHIC FIRE

When A19 was adopted, forest managers were generally not fully aware of the impending crisis in fuel buildups and the decline in overall forest health that has led to the catastrophic fires of the last few summers. However they were aware that A19 would negatively impact the ability of fire fighters to control these fires in the early stages thus preventing them from raging out of control. The Amended EA for A19 says on page 40:

"Management actions that change roaded access, may affect …initial attack fire suppression success and have significant effects on large-fire suppression capability. Delayed response time for initial attack and reinforcement for emerging fires is the critical limiting factor for fire starts. Extended response time due to reduced surface access (Note: caused by closed and obliterated roads ) increases escaped fire possibility. The cost of suppression increases due to needs for aviation support and fire fighter support in more remote areas."

and

"Vegetation to treat insect and disease mortality, blow down and undesirable tree species compositions are restricted to varying degrees in each alternative. Fire history suggests that those alternatives with the least vegetative management would have the most potential for large fires…. When a wildfire begins under the right weather and fuel conditions in these types, wildlife security habitat could be adversely impacted."

and

"In general, decreases in access can result in larger fires due to delays in getting firefighters to the site."

The EA concludes on page 41 that for the selected alternative, "The fire risk may increase...." The reason is closed and obliterated roads that are mandated by the amendment.

Testimony from firefighters reveals that serious losses and catastrophic near misses have indeed resulted from road obliteration.

"The one road that would have allowed almost direct access to the fire had been decommissioned with the road completely obliterated and recontoured."

And a loss of human life that was very narrowly avoided:

"Because of the limited access on this fire with road closures and obliteration due to Amendment #19 to the Flathead National Forest plan, the lives of more than twenty people -- everyone who was on Wedge Mountain at that time -- were put in extremely grave danger because there was only one escape route, and that route put them in the direct path of the fire."

 

BASED ON AN INCOMPLETE SCIENTIFIC STUDY

The EA acknowledges on page 8 that "The long term grizzly bear objectives for motorized access… are based on ….the South Fork Grizzly Bear Study."

The study cited is the "South Fork Flathead River Grizzly Bear Project: Progress Report for 1992" by Richard Mace and Timothy Manley. The report itself makes it clear that it is a progress report on four years of work of a ten-year study. It says on the cover page that "the results are not necessarily final and may be subject to change." On page 26 under the subtitle of "Recommendations", Mace and Manley state, "Subsequently, all data, analyses, and discussions are preliminary in nature. We recommend that managers and other interests recognize this, and that continued field observations and data analyses will occur during the remainder of this investigation." The authors go on to recommend that guidelines developed from their preliminary investigations "should remain flexible as we learn more about grizzly bears in this environment." Amendment 19 did not adopt the study recommendations as guidelines but as inflexible "standards" that must be complied with.

BASED ON FAULTY OR INADEQUATE SCIENCE

Biased towards morning hours

The Final Report reveals that the bear location data was only collected once a week for two study years and twice a week for the remaining four. This may not be enough of a sample especially since most of the data came from only 19 individual bears, three of which were yearlings when captured.

The most serious deficiency in the South Fork Study, other than the inappropriate conclusions reached and the fact that it was incomplete at the time A19 used it as the "best science available", is that the telemetric bear location data was only taken in the morning during "Optimal flying conditions, and thus the relocation flights, usually occurred between 0700 and 1100 hours." Yet the Final Report discloses that the grizzlies are active between the hours of 0500 and 2200. This deficiency is present in both the progress report and the Final Report. Therefore, the study assumes that grizzly bears choose the same type of habitat all throughout the day. Good science should not make such sweeping assumptions, especially when so much is riding on the outcome.

Inadequate traffic monitoring

On page 72, the Final Report presents a table, which shows some avoidance of roads based on traffic. However there is a problem with this analysis because the study only took traffic data on the West Side Reservoir road. They estimated traffic on the feeder roads and did not disclose how they arrived at the traffic classifications for the lesser traveled roads. Those estimates may be flawed and that would skew the data. Although the table does indicate a trend or tendency of bears to avoid the more traveled roads, it should not be used to set standards for road closures. More study needs to be done. However, the table clearly shows that closed roads, which have no traffic, are not avoided by grizzly bears.

The progress report on which A19 was based assumed that roads themselves rather than the human traffic on those roads caused bears to avoid habitat important for their survival. The Final Report makes it clear that traffic density not road density causes some avoidance behavior, although it is just as clear that bears display different levels of avoidance of traveled roads from none to near complete.

Not all of the class 1 telemetry locations were used. Why not?

The progress report based its conclusions on 1697 telemetric class 1 locations. However, they gathered 2641 class 1 locations. No explanation was given of why 1/3 of these locations were not used. If they had used all of the data, would different conclusions have been necessary?

Telemetric Error

The aerial locations were accurate to within 150 meters. However the study core area was divided into 30 meter cells and the road densities were studied with that 30 meter mapping. Thus, the actual location could have been 5 cells away from where it was mapped. The cell size should have coincided with the telemetric error.

A comparison with wilderness bears would have been useful.

None of the bears in the study had home ranges in the adjoining wilderness. It would have been useful to compare the behavior of wilderness bears with bears in roaded areas. This comparison may have helped to answer the question of whether grizzlies use high elevation habitat to avoid road traffic or because they prefer the cover and vegetation types found there.

There is a question whether grizzlies avoids roads or prefer unroaded habitat for other reasons ie food and cover.

On page 73, the Final Report says that " Neutral use of, or positive selection of habitat near roads implies that important habitats occur near roads." Why isn’t the opposite implication just as valid? Couldn’t you just as easily conclude that negative selection of habitat near roads implies that important habitats do not occur near roads or at lower elevations where road densities are higher? Science based on implications and assumptions can lead to erroneous conclusions. For instance the Final Study tells us that grizzlies are fond of avalanche chutes. These chutes occur only at high elevations. This "implies" that the demonstrated preference of grizzlies, females in particular, for high elevations is due to positive selection of avalanche chute habitat rather than negative selection for roads.

COMPLETED STUDY DOES NOT AGREE WITH ALL CONCLUSIONS OF THE PROGRESS REPORT

The completed study is titled: "Final Report: Grizzly Bear Ecology in the Swan Mountains, Montana" by Mace and Waller published in 1997, two years after Amendment 19 was adopted by FNF. The "Progress Report" indicated that grizzlies display a reluctance to use habitat near yearlong closed roads. While agreeing to some extent that grizzlies display some avoidance of open roads, the "Final Report" states on page 33 that "…no strong relationships were observed for closed road density and bear density." According to the table on page 72, bear avoidance of roads increases as traffic increases. The data shows that grizzlies did not avoid closed roads (Class 1).

Furthermore, the Final Report said that there was no intent to evaluate the relationship between grizzly bear density and road density.

Consequently, there is no justification for obliterating roads.

The Final Report claims that most grizzly bears do avoid human presence. Thus they generally avoid residential areas although some bears become habituated to humans. Both reports show some tendency to avoid roads with high traffic. Nevertheless, the Final Report indicates that bears primarily choose habitat for its value as cover and food and denning and will approach even busy roads if they are hungry enough. Neither study conclusively resolves the question of to what extent the bear’s choice of habitat is determined by positive habitat selection or avoidance of humans.

Mace and Waller believe that "road density standards and road closure programs should incorporate seasonal habitat requirements of grizzly bears.", thus minimizing open roads in high quality habitat at certain times of the year. "Road density standards could then be relaxed somewhat in less suitable habitats."

However A19 enforces strict standards on the entire NCDE grizzly recovery area with no consideration of real habitat values.

In a recent interview, Rick Mace, one of the biologists involved with the South Fork Study, said that

"…critics of the South Fork Study often believe that it "says go forth and close everything. But it does not."

Mace contends an effective road management program must have a "balance" that ensures considerable public support. Amendment 19 clearly does not have strong public support.

"I am unhappy that it has become such a controversial issue, and that the sides have become so polarized," said Mace, who believes that alternatives to Amendment 19 should be explored.

"I am philosophically right in the middle," he said. "I realize that as bear populations increase, there may be an opportunity to relax [road density] standards ... There's a point where this should tip, in my view. None of these standards should be forever, they should be adaptive.""

REMOVING CULVERTS DRASTICALLY INCREASES SEDIMENT IN STREAMS.

Although forest managers claim that sediment delivery after culvert removal will be decreased, the claim is only theoretical because road obliteration programs have not been studied long enough for corroboration. However, Table 3-15 from the Spotted Beetle EA on the Flathead NF reveals that sediment delivery to streams from the removal itself is very significant.

Depth is measured from the top of the outside shoulder of the road, vertically to the bottom of the culvert.

chart source: FNF Spotted Beetle EA pp 3-86

Assuming that the chart is correct as to the initial erosion effects of culvert removal, the removal of 44 culverts, which were required for A19 compliance in the Spotted Beetle project, will result in 127.6 tons of sediments, if they were all in the moderate range AND they were all "Best Case". This is 11 times the amount of sediment delivered by one culvert failure of the same type. Culvert failures are very rare. It is extremely unlikely that 11 culvert failures would occur in a drainage in the course of 50 years or more. Most importantly, 11 failures in one watershed over the course of five years, which is the typical time span for a culvert removal project, is out of the question.

4.4 x 44 = 193.6 tons for culvert removal > 11 x 17.2 = 189.2 tons or 11 culvert failures

The above analysis does not take into account the additional sediment delivery that occurs during the next 2 or 3 spring runoff events or until the new stream channel stabilizes. In some cases this would be more, maybe several times more, sediment delivered to the stream than culvert removal itself. Since these obliteration projects have always been associated with other management projects, they only affect one or two watersheds per project. This causes a massive spike in sediment for the downstream watershed that lasts for the duration of the project and beyond.

A study on one culvert removal on Quartz Creek on the Kootenai NF showed a lower sediment delivery than is indicated in the FNF study. The Quartz Cr. study used direct measurement of TSS above and below the culvert removal while the work was being done. This project pumped the water around the area while the culvert was being removed. This technique could only be used on a small creek like this one with a flow of only 0.86 cfs. The data would have been more useful if there was more data from before and after to confirm the baselines and if a larger number of culvert removals of different types had been studied. Still this culvert removal released 2.5 tons of sediments into a small creek over a very short (5 day) time span. How many tons would have reached this creek from the road if it had not been decommissioned?

More study on culvert removal must be done to answer the following questions:

1. How much sediment is released when larger streams are worked in and pumping is not possible?

2. How does the sediment released during obliteration compare with the sediment released from a well constructed road?

3. Wouldn’t water bars prevent ditch water sediments from reaching stream courses?

4. Wouldn’t upgrading the road such as installing water bars and replacing undersized culverts accomplish the same desired effect of road closure at less cost, especially when lost opportunity cost is considered?

Amendment 19 requires that total road densities above 2mi/mi² in a GB subunit be reduced by obliterating roads. Furthermore, A19 requires that the culverts be removed from obliterated roads. Not only is the obliteration unjustified according to the "Final Report" and other testimony by Mace, it damages the local fisheries many of which contain Endangered Bull Trout.

BASED ON OUTDATED GRIZZLY POPULATION ESTIMATES

Table 4 on page 43 of the EA declares that the minimum population estimate for grizzlies in the Northern Continental Divide Ecosystem (NCDE) was 306 bears in 1993. The amendment was signed in March of 1995. The "Final Report" (1997) declares, "Population estimates for the NCDE are believed to equal or exceed 500 bears." (pp2) Grizzly bear experts currently estimate the population at 600 in the NCDE. A new population study using hair traps and DNA analysis is expected to increase the population estimates for the NCDE even more. The first stage of the study covered only Glacier National Park and the North Fork Flathead NF has identified 315 individual bears, with about one third of the hair samples yet to be analyzed. A rough extrapolation of these results to the entire NCDE would yield between 1400-1500 bears, more than double the current estimates. Assuming that the road management actions required by A19 actually contribute to grizzly bear survival, they are no longer needed to the same extent as they were in 1995. Therefore the road proscriptions in A19 should be eliminated or modified.

PROBLEMS WITH MEASUREMENT OF ROAD DENSITIES

FLATHEAD FOREST ROAD DENSITIES FOR SELECTED GRIZZLY BEAR SUBUNITS

Amendment 19 Standards for open road density, total road density, and security core area are 19%, 19% and 68%.

The 2001 figures are taken from the 2000 Annual Monitoring Report for Amendment 19

*The first number is from the working draft for Wedge/Roberts presented at the public collaboration meeting first week of 01/04. The second is from the Proposed Action for Wedge/Roberts issued at the end of January 04.

1) Includes road prescriptions implemented and under decision. Existing =23%

2) Includes road prescriptions implemented and under decision. Existing = 43%

3) Includes road prescriptions implemented and under decision. Existing = 32%

@ West Side Reservoir Post-Fire Project Proposed Action

The most important thing to notice from this chart is that in most cases the parameters for Amendment 19 were further from compliance in 2004 than they were in 2001. This is contrary to the trend between 1995 and 2001 when almost all the numbers moved towards compliance or stayed the same. Since we know that no new roads were built and no closed roads were opened in these areas, we must assume that a methodological or technical change occurred in how the road densities were computed. If this is in fact what occurred, then the standard has effectually been changed without due process or public disclosure.

According to Jimmy De Herrera, Ranger for Glacier View, the discrepancies noted above are due to inclusion of motorized trails as an open road and inclusion of high use trails when calculating core security. These inclusions occurred after the 2000 monitoring report. However, this still does not account for all the discrepancies. For instance, there are no motorized trails or high use trails in the Lower Whale subunit but its security core value has still gone down considerably from the 2000 computation. Furthermore, neither trails closed to motorized use nor high use trails contribute to total road density yet those figures are up for Lower Whale and other subunits. Katharine Ake is the person who programs moving windows and apparently does most of the calculations. She says that in 2000 she included secure areas that were smaller than the 2500 contiguous acres required to qualify as security core. Now she removes all acreages that are otherwise secure but don’t meet the 2500 acres size test for security core. The effect of this change would be to decrease calculated security core in some subunits.

The Progress Report assigned one of four road density classes to each of 770,133 cells (30 sq. meters) in the study core area. Other than the fact that they were assigned a closed and an open density value, the report did not reveal how the class was determined. This determination was crucial because it affected the eventual standards that were adopted. We do know that there was some confusion because the standards were changed for the final Amended Environmental Assessment. Apparently the South Fork researchers used an early version of moving windows. Since that time different software using a different method of calculating the value for the center pixel in the moving window has been devised. The "Moving Windows Protocol" authored by Katharine Ake of FNF spells out how the standards are applied and how the densities are now calculated. Since the standards were based upon the methodology of the South Fork Progress Report, all calculations must use the same methodology. Ms. Ake states that she has been very careful to verify that the present technology supplies the same density figures as the original. Yet questions abound.

One of the most curious things about the road density standards is that the standards were based on the actual conditions in the study area, yet they have been closing and obliterating roads in that area ever since adoption of A19 and FNF claims that the area is still not in compliance.

"Conditions in the composite annual home range of adult female grizzly bears in the South Fork Grizzly Bear Project study area were used as a basis to formulate management objectives Alternatives 3 and 4."

The composite annual home range included all of the Kah Soldier, Ball Branch, Jewel Basin, Jungle Addition, Bunker Creek and Wheeler Quintonkin and parts of Noisy Red Owl, Swan Lake, Wounded Buck and So. Fork Lost Soup grizzly bear subunits.

Not only is the moving windows technique for determining road density for particular cells not explained in the study but the application of that technique to determine road densities in grizzly bear subunits is poorly understood today even by forest professionals. We do know that roads in a "buffer zone" outside of the subunit are counted against the standard within the zone. Thus, roads on the east side of Hungry Horse Reservoir may affect the allowed density calculations of subunits that are wholly contained on the west side of the reservoir. Furthermore, the impact of roads that are outside the subunit but within the buffer zone are accounted for in each subunit. In other words the impact of some roads is counted twice even though the affect, if there really is one, on a bear wandering through the area could only be that of one road not two. The result could be that road restrictions or obliterations will be mandated in both subunits because of the "impact" of a single road that is near the border of each. A more flexible methodology is needed that looks at bear management on a larger scale, taking into account road densities and security core in adjoining subunits.

There is no indication in the Progress Report that trails, motorized or non-motorized, were taken into consideration. The Final Report does document avoidance by grizzlies on high use non-motorized trails. However, the calculations for the density standards were based on the data in the Progress Report. Hence, the impact of trails was not considered in A19 and has never been addressed in a NEPA process. Nevertheless beginning sometime after 2000, FNF added motorized trails to the inventory of roads when calculating open and closed motorized access. From that point on density calculations for some of the subunits increased thus requiring more closures. Furthermore, high use non-motorized trails were added to the calculations as affecting security core areas, requiring even more closures. Yet, all of the additional closures required by adding trails to the moving windows calculations were motorized trails or roads. No hiking trails have been closed.

DIFFERENT LANDSCAPE SCALES USED.

The scientific recommendations and the management practices required by A19 do not coincide because they were applied over different landscape scales. The South Fork Study used a study that encompassed all or part of 10 grizzly subunits. A19 is implemented on a subunit-by-subunit basis. This has the effect of ignoring road densities and security core in adjoining subunits. Since the delineation of the subunits are more or less arbitrary and bears are not constrained by them, one affect of managing by subunit is that the surfeit or lack of quality grizzly habitat in one subunit is not taken into account in management decisions for adjoining subunits. Since FNF managers never act to reduce grizzly habitat security in subunits that exceed the A19 standards but only act to increase security in subunits that fall short of the standards, the end result is more unroaded and secure habitat for grizzlies than even the most strident bear advocates claim they need and even less access to forest resources for the public.

If you remove the boundary between two subunits and recalculate moving windows for the combined subunit, the A19 calculations will actually be an average of the calculations for the individual subunits. In some cases it will meet the standards if the impact of the adjoining subunit is considered. Clearly, the impact on the bear is mitigated by the presence of more secure, unroaded habitat in a nearby subunit. The opposite is also true. A new protocol needs to be developed that takes these facts into consideration.

TRAILS ALSO IMPACT GRIZZLIES

The Final Report makes it clear that the bears avoid foot traffic as well as motorized traffic.

"During each season, bears were significantly further from areas (in the Jewel Basin hiking area) frequented by humans."

This report makes it clear that bears avoided the trails and campsites in the popular hiking area that is closed to all motorized use. Nevertheless, A19 did not address the very real issue of non-motorized use in bear habitat. Why not, if the purpose of the amendment was really grizzly bear protection from human influences?

MAN CAUSED MORTALITY IS NOT LINKED TO OPEN FOREST ROADS

Many commentators have attempted to link human caused bear mortality to open forest roads. but neither the Progress Report nor the Final Report makes that claim. Indeed, the Final Report states that all but two of the 19 man-caused bear deaths during the study period occurred inside wilderness or in the rural areas inhabited by humans on the periphery of the study area.

However, the Final Report, the EA and the ROD do express concern that negative human attitudes brought about by the loss of motorized access mandated by A19 will cause some adverse impact on grizzly bears. This may in fact partially explain some of the poaching incidents recorded during this study period and since.

CONCLUSION

While some road closures may be advisable for grizzly bear well being, the large number of closures required by A19 is not needed – in fact it may be counter-productive by producing a backlash of anti-bear sentiment among the local populace. Road obliteration is clearly not required because the cost vastly exceeds the speculative benefits to bears, and should be eliminated immediately except in cases where it can be done economically and there is another road close by that can be used for public and management access to the same area. The Final Report recommends a system of rotating road closures in areas that are seasonally important to grizzlies such as early spring closures on lower elevation roads.

In the light of new science, a larger population of grizzlies, the inadequacies and errors in the old science and the high impact that road closure has on the local human population, the road standards of A19 should be discarded and a new system for mitigating road impacts on grizzlies that fully accounts for human impacts should be adopted. The new system will recognize the value of roads for present or future management and public access and will retain all roads even those that are closed. Rotating closures will be preferred over permanent closures. Unlike the A19, this system will balance all competing needs including the requirements for species viability, water quality, forest and local economic health, recreational and cultural uses.

This report was researched and written by Gary Hall, Vice-President of Montanans For Multiple Use with advice and suggestions from other members of MFMU

"The Daily Interlake", Kalispell, Mt. by Jim Mann, 2/08/04

www.mtmultipleuse.org/public_lands_articles.htm

"Multiple Use News", Montanans For Multiple Use, Box 2509, Kalispell, MT 59901. January, 2004

Mace, R. D. and Timothy Manley. 1993. "South Fork Flathead River Grizzly Bear Project: Progress Report for 1992". Montana Fish, Wildlife and Parks, Helena, MT

Mace, R.D. and J.S. Waller. 1997. "Final Report: Grizzly bear ecology in the Swan Mountains". Montana Fish., Wildlife, and Parks, Helena, MT.

"The Daily Interlake", 2/09/04

"Flathead National Forest Plan Amendment 19, Amended Environmental Assessment" February, 1995

"Flathead National Forest Robert-Wedge Post Fire Project Proposed Action", Janurary, 2004

"Flathead National Forest West Side Reservoir Post-Fire Project Scoping Document" February, 2004

"Spotted Beetle Resource Management Project Environmental Assessment". Flathead National Forest. September, 2001

Steve Wegner, "Monitoring Results of Watershed Restoration Activities – Quartz Creek – Middle Kootenai Bull Trout Recovery Area", Kootenai National Forest