Endangered and Threatened Wildlife and Plants; Proposed Establishment of a Nonessential Experimental Population of Grizzly Bear in the North Cascades Ecosystem, Washington State

Dear Supervisor Thompson, Thank you for the opportunity to comment on this Proposed Rule regarding Establishment of a Nonessential Experimental Population of Grizzly Bear in the North Cascades Ecosystem, Washington State. Defenders of Wildlife is a national non-profit organization founded in 1947 dedicated to conserving and restoring native species and the habitat upon which they depend. Defenders has over 2 million members and supporters nationally, 70,000 of whom reside in Washington State. Our full comments on this Proposed Rule are hereby attached as Attachment 1. Overall, Defenders supports the use of a 10(j) rule as part of the restoration effort to the extent it promotes the recovery of the population, ensures management is humane and prioritizes non-lethal alternatives, and enables humans and grizzly bears to coexist. While we support the overall goals and approach outlined in the Proposed Rule, we recommend several revisions to clarify and strengthen it to ensure it provides adequate safeguards to promote grizzly bear recovery consistent with the best available science. Our primary concern is to limit population loss in the nonessential experimental population (NEP) by (1) securing sufficient grizzly bear habitat, including through an updated roads and trails inventory and strengthening the definition and implementation of the "no-net-loss-of-core" approach; (2) providing additional measures to avoid human-bear conflict through securing attractants; (3) prioritizing non-lethal deterrence in any conditional take authorization and allowing only authorized agencies (not private individuals) to conduct lethal take; (4) setting specific population goals, including mortality thresholds, for the NEP; and (5) establishing a robust, specific, and long term monitoring and evaluation plan. If you have any questions, please do not hesitate to contact me at 206.577.2007 or via email at kcallaghy@defenders.org. Sincerely, Kathleen Callaghy Northwest Representative Defenders of Wildlife