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Mattson 5-10-2016 Comments Excerpts
Mattson 5-10-2016 Comments Excerpts
The Rule and the accompanying Memorandum of Agreement (MOA) developed by the states for managing
Yellowstones grizzly bears post-delisting are inadequate in provisions for calculating and managing total
allowable mortality. Moreover, both the MOA and the Rule are deficient in terminology and provisions for
managing grizzly bear distribution.
20.1. The methods described in the Rule to account for background mortality are not only discrepant with
methods described in the MOA, but also fail to account for unknown-unreported grizzly bear deaths, thus
constituting a major methodological threat to the Yellowstone grizzly bear population.
On page 13203 of the Rule the Service walks the reader
through an example of how discretionary mortality will
be calculatedof which presumably all could be
provisionally allocated by the states at the beginning of a
given year for sport hunting. The example calculations
purport to account for background mortality, which is
defined in the previous paragraph as including various
causes, including unknown/unreported calculations.
Yet the example given by the Service, fails, in fact to
account for unknown/unreported mortalities, leading
to an inflated estimate of the number of bears candidate
for discretionary mortality. This is a major error given
that discretionary mortality for independent females and
males ends up being over-estimated by approximately
75% and 200%, respectively. In other words, this is a nontrivial even fatal mistake on the part of the Service.
The Service needs to account for unknown-unreported
mortalities in its calculations. Given the current IGBST
method used to estimate unknown-unreported deaths,
this foreseeable cause needs to be subtracted before
other foreseeable non-discretionary deaths are
deducted. Given that the unknown-unreported fraction
during 2010-2014 has averaged 39% of the total knownprobable deaths for independent females and 37% of the
same for independent males, these fractions need to be
the first to be subtracted from the initial calculation of
allowable mortality. After that, other non-discretionary
causes can be deducted.
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The rationale for this recommendation is pretty straightforward. Managers should set a goal, expressed in terms
of total mortality rates, that will likely produce growth in
the Yellowstone grizzly bear population should it drop
below the basement number of 600. Even taken at face
value, the mortality guidelines currently set for any
population less than or equal to 674 are, by the Services
own admission, rates associated with a stable population
at best.
The agencies may argue that they already have a
provision for eliminating virtually all Discretionary
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21. Occupancy provisions for adult females need to apply to all portions of the DMA, not just the PCA, stratified
on the basis of what are currently called Flight areas.
less than 33% of the adult females in the population (say,
25%), all concentrated on the ecosystem periphery, will
be subject to most of the planned killing each year. And,
importantly, the current approach essentially uses
females inside National Parks to subsidize calculations of
allowable sport harvest outside.
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Figure 21.1. Map A, above, shows the PCA (delineated by red, as shown in map B) relative to the full extent and partitioning of the
DMA (in yellow). The Rule and current MOA only provide for insurance of occupancy by adult females within the units contained by the
PCA and leaves occupancy of all the other units (Flight Areas) in the DMA up in the air when it comes to presence of reproductive
females.
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