Peer Review Report Reviewer 4 Species Status Assessment for the Grizzly Bear (Ursus arctos horribilis) In the Lower 48 States: A Biological Report U.S. Fish and Wildlife Service Grizzly Bear Recovery Office Missoula, Montana Version 1.0 – July 7, 2020 1 Reviewer 4 Peer Review of the Draft Species Status Assessment for the Grizzly Bear (Ursus arctos horribilis) in the Lower-48 States: A Biological Report. GENERAL COMMENTS 1. Is the Biological Report’s description and analysis of the species’ needs, biology, habitat, population trends, and historic and current distribution accurate and, if not, what information is missing and how is it relevant? Basically, these sections are basically complete as written except for the lack of information on adjacent populations in Canada. Four of the 6 grizzly bear ecosystems are transboundary and share bears and bear habitat with adjacent areas of Canada. It is not possible to fully address issues about the current status and biology of these bear ecosystems without including discussions about what is happening in adjacent areas of Canada. There is very little information throughout the document about these shared transboundary population issues. I have noted this problem in comments throughout the document. 2. Does the Biological Report provide adequate review and analysis of the factors relating to the overall viability of grizzly bears in the lower-48 States (e.g., demographics, habitat, disease and predation, and genetics) and, if not, what information is missing and how is it relevant? The sections on overall viability are adequate as written except for the lack of information about what is happening in adjacent areas of Canada for the 4 transboundary ecosystems. 3. Does the Biological Report provide accurate and adequate review and analysis of the current and projected future condition of the species? If not, what information is missing and how is it relevant? The projected future condition of the species sections have significant issues with flawed conclusions and unsupported expectations – particularly for scenario 1. I have detailed my comments on these problems in the text. I believe this section needs significant revision and clarification. 4. Does the Biological Report provide adequate review and analysis of stressors and other influences on grizzly bears in the lower-48 States? If not, what information is missing and how is it relevant? 2 The stressors section is basically complete except for the lack of information about certain cattle allotments where there are ongoing significant conflicts and concerning the complications of grizzly recovery while there is black bear baiting ongoing in the Bitterroot ecosystem. These issues need to be included in discussions of stressors and expected effects. These issues are noted in the text. 5. Are there any significant oversights, omissions, or inconsistencies in the Biological Report? The biggest oversight is the lack of inclusion of information about adjacent Canadian bear populations. These populations are shared by both countries and management authorities, and bears go back and forth across the border. The US and Canada have been cooperating on grizzly bears research, monitoring, and management for over 30 years, yet there is almost nothing about Canada and Canadian bears in this review. This is a significant oversight in this report and needs to be rectified. Comments about this deficiency are noted multiple times throughout the text. 6. Are the statements about current and future condition logical and supported by the evidence provided? I have significant disagreement with the conclusions reached in the future condition section, scenario 1 on all grizzly bear ecosystems and these concerns are detailed in the text. I do not believe that the scenario 1 conclusions reached in this analysis are logical or based on facts or evidence. The basic issue is that the conclusions reached in these scenario analyses are subjective and not repeatable. The conclusions on scenarios 2-5 are more logical and defensible, but they are still subjective. 7. Does the Biological Report include all the necessary and pertinent literature to support our assumptions/arguments/conclusions? I have suggested additional literature throughout the document, and these are noted in the text. 8. Are there demonstrable errors of fact or interpretation? Please provide the specifics regarding those particular concerns. The major issue of interpretation is the conclusions reached in future condition scenario 1. The rest of the conclusions are reasonable and acceptable. This is noted in the text. 9. Additional general comments. N/A SPECIFIC COMMENTS 3 Multiple specific comments and suggested literature are noted throughout the text in track changes [NOTE FROM EMPSi – the specific comments and revisions/text edits from the tracked changes version are copied below with page and line numbers as well as text from the review for location reference. The report with the reviewer’s tracked changes was also submitted as supplemental material.] P4 L16: “272 kilograms (600 pounds)” Comment: Bears over 800 pounds have been captured along the eastern edge of the NCDE in Montana. P5 L3: “There are no known populations in the North Cascades and Bitterroot (BE) ecosystems and no known populations outside these defined ecosystems” Comment: Should define the word “population the first time you use it since without a definition this statement is very unclear. P5 L6: “Outside the lower-48 States, approximately 55,000 grizzly bears exist in the largely unsettled areas of Alaska and northwestern Canada (Alaska Department of Fish and Game 2020, entire; COSEWIC 2012, p. vi).” Comment: I suggest saying western Canada since there are grizzly bears along the Canada-US border as well. P5-6: Comment: whole paragraph under Summary of Needs, suggest changes in red: Text edit: “In general, a grizzly bear’s individual habitat needs and daily movements are largely driven by the search for food, mates, cover, security, or den sites. All life stages need large intact blocks of land to breed, feed, shelter and disperse; cover to shelter; high-caloric foods to feed and reproduce; and dens as winter shelter. In order to be resilient, grizzly bears need sufficient abundance for genetic and demographic health, stable to positive population trends, high adult female survival, survival of subadults and adults to maintain stable to increasing populations, fecundity, and genetic diversity. Grizzly bears in the lower-48 States need multiple, resilient ecosystems distributed across a broad geographic range in order to be redundant and withstand catastrophic events. Additionally, grizzly bears in the lower-48 States need genetic and ecological diversity in order to preserve variation and the ability to adapt to changing conditions (Error! Reference source not found.).” P7 L6-10: Text edit: “These conservation efforts or mechanisms include: Habitat management and mortality management including land management status (i.e. the Wilderness Act and Inventoried Roadless Areas (IRAs)); attractant removal on private lands, food storage orders on public lands; conservation easements; information and education (I&E) programs; and augmentation or translocation programs. “ P14 L44: “the SE declines from moderate to very low, and the CYE declines from low to very low” Comment: It seems to me that if “conservation actions decrease significantly, largely through the termination or non-renewal of plans or regulations” the result would be elimination of grizzly bears 4 in the C/Y and the Selkirks. No plans or regulations or funding would result in significant declines in numbers and range of bears in the YEL and NCDE. That is my subjective assessment. See main section for more on this. P14 L44-46: “Although resiliency decreases, redundancy and representation remain the same under Scenario 1, with four ecosystems distributed similarly to current condition within their ecological types (Figure 6).” Comment: There is no basis for this conclusion other than someone’s subjective estimates. Making this statement in a 5-year review basically says FWS and others can significantly reduce conservation effort (i.e. eliminate FWS recovery positions, eliminate habitat management like road closures, stop augmentation, stop funding bear management specialists, do not enforce mortality management, and stop population monitoring) and the populations in the C/Y and the SEL will continue to exist. This is not a credible conclusion at all. P15 L13: “As a result, the NCDE and GYE remain in high resiliency, the SE stays moderate resiliency, but the CYE improves in overall resiliency from low to moderate (Table 3). ” Comment: This sounds reasonable. P15 L18-31: “Under Scenario 4, redundancy and representation improve, as both the BE and North Cascades shift from extirpated condition with no resiliency to low resiliency. The NCDE and GYE remain in high resiliency, the SE remains moderate, and the CYE improves from low to moderate resiliency (Table 3). Risk from potential catastrophic events is now spread across six instead of four ecosystems (redundancy) with additional ecological diversity gained at the northwestern and central extents of the overall range (representation) (Figure 6). Future Scenario 5 is an optimistic scenario under which conservation increases significantly. As a result, resiliency, redundancy, and representation for the grizzly bear improve. Under this scenario, the NCDE and GYE stay in high resiliency, but the CYE and SE improve to