IWMC  World Conservation Trust

Florida, 7 January 2006

Grizzly Bear Recovery Coordinator
U.S. Fish and Wildlife Service
University Hall 309
University of Montana
Missoula, Montana 59812

Sir/ Madam,

We appreciate the opportunity to comment on your proposal to delist the Yellowstone population of grizzly bears under the Endangered Species Act. IWMC World Conservation Trust is an organization that promotes the sustainable use of wildlife.

We commend FWS for its extensive work over the last thirty years and the much greater understanding that now exists concerning grizzly bears. It is difficult to bring to mind any wildlife conservation program anywhere in the world that has been so diligently and painstakingly followed over so many years. The recovery of the Yellowstone grizzly has been well documented and, in our view, your proposal, taken together with the safeguards contained in the Conservation Strategy, is entirely appropriate.

We also commend FWS for taking a decision that it will have recognized would be controversial. Contrary to the opinions of some, conservation does not mean, or require, the total protection of all animals from human activities; instead it requires that proper care and management be exercised in these interactions. What you are proposing will ensure that grizzly bears continue to thrive in the Yellowstone area. In our view, opposition to the proposal from a few environmentalist groups reflects a desire on their part to maintain a permanent listing and is not justified by the extensive knowledge gathered by FWS in recent years.

The success of the Grizzly Bear Recovery Plan leads us to make two comments from the perspective of global wildlife conservation challenges. First, we believe that it would be useful for an objective evaluation to be undertaken of the reasons why the grizzly recovery program has been effective. FWS has gone to great lengths to explain the numerous steps that have been followed, and to cite cooperation between stakeholders, but which of the initiatives have been the most critical, and therefore might usefully be emulated by others?

Second, we are unable to find details of the overall cost of the grizzly conservation program. When evaluating the success of a program such as this, it is useful to be able to make cost comparisons with other conservation practices in the U.S. and overseas. In particular, this can help poor countries to evaluate which practices they may, or may not, be able to adopt to meet their challenges. In particular, we believe it would be useful to understand the following:

• The overall cost of the grizzly recovery program to date and by year
• A breakdown of the major costs (manpower, research, etc.)
• Expected future costs
• Expected income from the issuing of hunting licenses and from other activities

The Conservation Strategy produced by FWS provides strong safeguards for the grizzly population. Based on our work overseas, we agree with your assessment that limited and carefully regulated hunting will not lead to a decline in the Yellowstone grizzly population. We believe income from the issuing of hunting licenses should be used to compensate ranchers for loss of livestock from bear attacks, and thus be used to sustain the Conservation Strategy. This will reinforce the value of the conservation program to different stakeholders in the Yellowstone area.

Sincerely,
Eugene Lapointe
IWMC President
Former Secretary General of CITES (1982-1990)

Promoting the Sustainable Use of Wild Resources
- Whether Terrestrial or Aquatic
- as a Conservation Mechanism