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GRIZZLY TIMES
COMMENTS ON & OBJECTIONS TO GOVERNMENT DECISIONS
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Comments on the 2016 USFWS Draft Rule to Delist Yellowstone Grizzly Bears
These comments address numerous problems in the Draft Rule related to interpretations of science, the deployed logic, and the invoked science itself. All of these problems amount to fatal flaws (Dr. David Mattson)
Supplemental comments on the draft 2016 rule to remove ESA protections for Yellowstone grizzly bears
These comments augment those submitted during May of 2016 in response to the US Fish & Wildlife Service's attempts to circumvent legal comment protocols. (Dr. David Mattson)
Comments in response to the USFWS's solicitation of comments on its DPS designation
These comments address the USFWS's extra-legal efforts to circumvent concerns about its efforts to designate the Yellowstone population as a Distinct Population Segiment (DPS). (Dr. David Mattson)
Comments on the Kootenai NF's Black Ram Project draft EIS
These comments address the many short-comings of a draft EIS, since withdrawn, covering impacts of a major proposed timber sale on endangered grizzly bears in the Kootenai National Forest of northwestern Montana. (Dr. David Mattson)
Comments on the AM3 Expansion of the Bull Mountains Coal Mine
These comments address the impacts on grizzly bears likely to be caused by trains hauling coal from the Bull Mountains Mine in eastern Montana. (Dr. David Mattson)
Objections to the Custer Gallatin NF Revised Forest Plan
These objections address the numerous short-coming related to standards the Custer Gallatin NF Plans for protecting grizzly bears. There is no acknowledgment of impacts caused by non-motorized recreation; major deficiencies in standards that address roads; and lack of habitat protection in areas outside the PCA (Dr. David Mattson)
Comments on the Custer Gallatin NF South Plateau Project
These comments cover failings by the Forest Service to adequately address impacts on grizzly bears of a massive proposed timber sale in an area near West Yellowstone that has long been a population sink for bears. Rather than planning to close enough roads to provide the security that bears need to survive, the project instead proposes further harmful impacts. (Dr. David Mattson)
Objections to the Kootenai NF Black Ram Project
After the Forest Service predictably ignored or dismissed out of hand virtually all public comments, the agency went ahead to issue a Record of Decision that adopted an alternative harmful to grizzlies in this region. These objections were in response. (Dr. David Mattson)
Comments on the Custer Gallatin NF East Paradise Grazing Plan
These comments cover failings by the Forest Service to adequately analyze and address a host of issues arising from plans to restore and liberalize grazing in allotments along the east side of Paradise Valley in areas comprising critical habitat for numerous wildlife species, including grizzly bears. (Dr. David Mattson)
Comments on the proposed Montenore Mine, Cabinet Mountains, Montana
These comments critique the US Fish & Wildlife Service's assessment of population status for grizzly bears in the Cabinet Mountains, as well as mitigations proposed for the Montenore Mine, all of which were used to justify approval of mine operations. (Dr. David Mattson)
