Commissioners submit comments to federal government on grizzly bear restoration plan

The Board of Chelan County Commissioners submitted its comments to the federal government on an Environmental Impact Statement (EIS) that evaluates options for restoring grizzly bears to the North Cascades. The commissioners have repeatedly expressed their opposition to the plan.

The National Park Service and U.S. Fish & Wildlife Service were seeking public input on the EIS. The U.S. Fish & Wildlife Service was also inviting public comment on a proposed rule under section 10(j) of the Endangered Species Act that would provide local communities more flexibility to manage the grizzly bear population with additional wildlife management tools. Those comment periods ended on Nov. 14.

Released in late September, the draft EIS offers several paths the agencies could take to restore this piece of the ecosystem. Among them, a “no action” alternative that would continue existing management practices, and two action alternatives that would both allow for the active restoration of grizzly bears, but differ in how a population of bears might be managed.

One of the action alternatives outlined in the draft EIS would designate grizzlies in the area as an experimental population under section 10(j) of the Endangered Species Act. That designation would give communities and land managers additional options for managing bears, including deterrence, relocation, or removal of animals involved in conflict. These additional tools could offer more safety and certainty for the region, while providing for the conservation of the species.

In addition, the BOCC submitted separate comments, asking that the National Park Service and U.S. Fish & Wildlife extend the comment period an additional 45 days.

"While we appreciate the additional public meetings you have held, we have heard from constituents that additional time is needed to read and comment on the draft EIS and proposed 10(j) rule due to the volume and complexity of materials," the request states. "Given that over 84 percent of Chelan County is located within the proposed North Cascades Ecosystem, it is imperative that you allow for more public engagement, hear from our constituents and consider the impacts of the proposal on the local community and economy."

The comments, addressed to the Don Striker, superintendent of the North Cascades National Park Service Complex, and Hugh Morrison, director of the U.S. Fish and Wildlife's Pacific Region, are below:


Dear Mr. Striker and Mr. Morrison:

Chelan County has reviewed the draft Environmental Impact Statement and proposed 10(j) rule associated with the joint National Park Service and U.S. Fish and Wildlife Service Grizzly Bear Restoration Plan.  We have previously provided extensive comments opposing grizzly bear reintroduction into our local communities.  We continue to oppose grizzly bear reintroduction given the likely negative impacts to our rural communities.  The federal agencies leading this effort continue to fail to adequately analyze and address these concerns in the current draft EIS and proposed 10(j) rule.

1.  The draft EIS fails to analyze and consider impacts to local communities

Chelan County and other local governments within the North Cascades Ecosystem (NCE) requested Cooperating Agency status to participate in the development of the draft EIS and proposed 10(j) rule.  Unfortunately, the National Park Service and U.S. Fish and Wildlife Service chose not to engage local governments and their expertise in the development of the draft EIS and proposed 10(j) rule.  Notably, the draft EIS does not adequately analyze or consider impacts to local communities within the NCE, including public safety, economic development, recreation opportunities and overall livelihood of rural communities.  Counties, in particular, have special expertise and jurisdiction in land use planning, economic development, parks and recreation and road development and management that should be incorporated into the draft EIS and proposed 10(j) rule.  We, again, request Cooperating Agency status and that completion of the draft EIS be delayed until the potential impacts to local communities are better analyzed and understood.

2.  New and emerging information must be considered and incorporated into the draft EIS and proposed 10(j) rule

We learned from the October 2023 Interagency Grizzly Bear Task Force that extensive modeling is being completed by the U.S. Geological Survey to predict NCE grizzly bear habitat use, and the current modeling, described by USGS scientists as “highly predictive,” shows high-value grizzly bear habitat well outside the proposed release areas identified in the draft EIS.  We do not purport to be experts in wildlife biology, but the preliminary results of the modelling appear to point to obvious areas of potential conflicts between grizzly bears and local communities.  Significant blocks of these high-value grizzly bear habitat areas are located outside the North Cascades National Park and designated wilderness areas and squarely within non-wilderness lands managed by the US Forest Service and private property.  The current draft EIS and proposed 10(j) rule must be delayed to allow for the USGS modelling effort to be completed, incorporated into a new draft EIS and shared with the public.


**The red circles indicate large blocks of Predicted Grizzly Bear Habitat. Adapted from Sells and Costello (draft).  Polygons created by Chelan County.)

**The black squares indicate Potential Grizzly Bear Release Areas (approximate).  Adapted from draft EIS.  Polygons created by Chelan County.


3.  The role of the Okanogan Wenatchee National Forest in grizzly bear reintroduction must be fully analyzed and incorporated into the draft EIS. 

Grizzly bear reintroduction appears to rely heavily on actions that will take place on the Okanogan Wenatchee National Forest (OWNF), yet OWNF is not participating in the development of the draft EIS or proposed 10(j) rule.  The draft EIS can not be based on assumptions about future OWNF policies and actions and must identify, analyze and incorporate those issues now.  We are particularly concerned that the draft EIS does not consider impacts to much-needed forest health treatments, road building and recreation, especially “high-use” roads and trails.  It is unclear to us if there is sufficient “core area” within the NCE to support grizzly bear reintroduction given the recreational uses on the OWNF. Given the increase in size and scale of wildfires, the need for forest health treatments and road building to support those treatments is paramount for ecological and community needs and would likely be significantly constrained by grizzly bear protections.

4.  Grizzly bear reintroduction and management must be re-considered in light of draft EIS deficiencies

The current proposed 10(j) and 4(d) rules need to be re-considered after the draft EIS deficiencies are addressed.  It appears that the NCE does not provide sufficient habitat to support grizzly bear reintroduction population goals and that substantial preferred habitat is located on the OWNF and rural communities.  Given the high level of activity in these non-wilderness areas, 10(j) and 4(d) provisions must be re-considered and expanded to anticipate and address significant conflicts between grizzly bears, local communities, forest practices and recreational activities.  Conversely, the feasibility of grizzly bear reintroduction must be reconsidered given these likely conflicts.

We reiterate our opposition to grizzly bear reintroduction given the likely adverse impacts to our local communities and lack of local government engagement by the federal agenices.  At minimum, we hope that you will consider our comments and develop a draft EIS and proposed 10(j) rule that more accurately reflect the current science, management needs and local community impacts of grizzly bear reintroduction.



Kevin Overbay, Commissioner

Shon Smith, Commissioner

Tiffany Gering, Commissioner

Last Updated: 12/13/2023 02:08 PM

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