Friends of the Clearwater's Policy Director, Jeff Juel, and board member, Dr. Harry Jageman, recently submitted comments regarding the proposed change to limit public input from the U.S. Forest Service.

Friends of the Clearwater advocates for democratic management of the public's land. For nearly 40 years we have advocated for greater transparency and openness from government agencies.

Read more below to see both comments that were submitted in opposition to this change.

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Jeff Juel's Comment:

March 6, 2025

Re: Project-Level Predecisional Administrative Review Process (Federal Register Vol. 91, No. 25 / February 6, 2026; 5387-5398)

Submitted to comment portal at:
https://www.regulations.gov/commenton/FS-2026-0001-0001

On behalf of Friends of the Clearwater (FOC), these are comments on the U.S. Department of Agriculture Forest Service proposal to amend its Project-Level Predecisional Administrative Review Process regulations (proposed rule). FOC is an organization whose purpose is to protect, conserve, restore and advocate on behalf of the wild nature of the Clearwater River Basin and adjacent watersheds of north-central Idaho which feature Wilderness, roadless areas, and habitat integrity and connectivity for large predators and other at-risk species on public lands and surrounding areas.

With this proposed rule the Forest Service attempts to make public influence on national forest land management extremely difficult. We see nothing about serving the public interest in “amending these regulations to consolidate and streamline processes, increase efficiency, and better align with the Agency’s statutory obligations and recent rescissions and revisions to National Environmental Policy Act regulations.”¹ It is said to be about agency “efficiency” which is code for making it much more difficult for citizens to participate in a meaningful dialogue with the agency. Arbitrary decisions made in the dark do not serve the public interest, rather they are made to serve those with political connections who plunder the public commons to make huge profits. Surely it matters that public lands not be sold off. But taking measures to obstruct the public from influencing management, as does this set of proposals, is essentially the same thing.

¹ Quotes, quoted sections and citations in these comments are from the proposed rule unless otherwise specified.

Taken individually and in combination, the various changes outlined in the proposed rule are an attack on public lands, wildlife, a clean and healthy environment and therefore on the values of the American people—as well as an attack on democracy itself.

Shortening public comment periods

In the proposed rule Summary the Forest Service deceptively states, “These regulations establish the process by which the public may file objections seeking administrative review for projects and activities implementing land management plans on national forests.” However a major aspect of the proposed rule would affect the public process governed by the National Environmental Policy Act (NEPA) well before the administrative review process: “The time to file comments for a proposed action to be documented in an EA has been reduced from 30 days to 10 days, and from 45 days to 20 days for a proposed action to be documented in an EIS.”

The Forest Service can cite no example of how allowing more traditional 30-day, 45-day, or even 60-day comment periods on NEPA documents has resulted in harm to forests or any public value. On the other hand, robust comment period opportunities better inform citizens who care about the natural world and the ecological condition of our national forests. This naturally leads to better decisions and management.

And whereas for filing objections, “when the time period begins or expires on a Saturday, Sunday, or Federal holiday, the start or end date is extended to the next Federal working day” the comment period for filing comments on an EA or EIS is allowed to start any day—even on the Saturday before a Monday holiday—effectively reducing comment periods even further. The Forest Service is already notorious for having timed important comment periods to overlap with the Christmas/New Years holiday season.

Refusal to notify interested parties

When developing projects and for updates on projects, the Forest Service proposes to speak only to its own websites—not to the interested public: “The Forest Service would no longer publish comment and objection notices in a newspaper of record, but would publish notices on the USDA website where other project documents are also published. … The requirement to post notice on a USDA website is a more modern, cost-effective, efficient, and consistent way to inform individuals and entities about the opportunity to comment.” The Forest Service isn’t saying how much it would cost to actively notify the public as it has in the past, so this “cost-effective” claim is specious.

We are aware of no regulation explaining the meaning of “a USDA website.” Even specifying “the USDA website where other project documents are also published” is insufficient. The Forest Service could conform to the proposed requirement even if it posted a notice to an illogical, flat-out wrong, or previously unknown website/link. We are aware of no accountability mechanism if a responsible official chooses to obstruct or hide notifications in such a manner.

Similarly, “Objection responses would no longer be mailed to objectors, as is the current process.... Instead, responses would be published on the USDA website where other associated project documents are also published.” That is absurd. The proposal would require that Lead Objectors be identified in objections—for what purpose? Why would it be so hard for the Responsible Official to timely send via email or U.S. mail the objection response to the Lead Objector, and to even all the objecting parties?

No comment period on NEPA documents

“The designated opportunity for public comment for an EIS may be combined with the request for comment included in the notice of intent to prepare an EIS, as required by NEPA.” This is similar to what’s being proposed for Environmental Assessments (EAs). Section § 218.3(d) only vaguely describes requirements for what may likely be the only document subject to comment prior to the objection process. However, it does not specify that detailed analyses of impacts and environmental consequences is required. Furthermore, this is at a time when other Forest Service documents potentially posted on the project website—such as specialists’ reports, those documenting consultation with other agencies, required mitigations, project design specifications, and monitoring—may not be finalized or made publicly available. In other words, there is no requirement for allowing public comments on full NEPA analyses including detailed descriptions of alternatives, summaries of environmental consequences as written up by Forest Service specialists, and mitigation measures and project specifications so the public may provide feedback to prevent the agency from wasting public resources going far down a path towards creating a potentially illegal or destructive project. So much for “efficiency.” This also obliterates the public’s potential role in proposing better, more cost effective and truly efficient ways—alternatives—for full analysis and consideration. The proposed rule’s failure to genuinely involve the public is inconsistent with provisions of NEPA including:

And when a project proposed under this new rule is litigated and a court declares the rule in violation of NEPA, potentially dozens of other Forest Service decisions could soon be enjoined based on the new precedent. So much for “timely and efficient!”

Proposed rule would illegally censor the public by imposing unreasonable limitations on public expression.

A very clear message embedded throughout the proposed rule is that the Forest Service really does not want to read, consider, or respond to detailed, thoughtful, science-based and thorough input from the public at any stage of the project development or review.

This is evident from the proposed limit on the number of pages in objections. Under the proposed rule, we foresee a preponderance of instances where an EIS is only finally published when accompanied by a draft Record of Decision (ROD), or correspondingly when an EA is only made public when accompanied by a draft Finding of No Significant Impact (FONSI). So for example the public would have a 150 to 300 page EIS to review but is only allowed to submit 30 pages in response, no matter how badly the EIS might analyze and disclose project impacts to, e.g., water quality and quantity, soil productivity, fish and wildlife habitat, endangered plants, fish and animals, roads, greenhouse gas emissions and climate, fire regimes, recreation opportunities, economic costs and benefits; plus cumulative effects, monitoring, and consistency with laws and land management plans. And although a picture is worth a thousand words as the saying goes, photographs of conditions in a project area to which the Forest Service might otherwise be oblivious are discouraged because they would count towards the page limitations so further limit objection text. The Forest Service would only finally disclose the wide array of project details and analyses of potential environmental harms at the initiation of the objection period, during which the new rule will gag the public using unreasonable page limits for criticisms, suggestions, alternatives, questions, and notifications of potential illegalities.

It’s of little help that, “Science or literature may be considered if the commenter clearly identifies the cause-and-effect issues relating literature to the environmental analysis.” At the comment stage, as we indicate above, the Forest Service may have provided little information to the public because Section §218.3(d) requirements are so vague. So how can anyone “relat(e) literature to the environmental analysis” if the latter is hardly articulated at that stage? Granting the Forest Service authority to reject submitted science and literature for its consideration would only approach acceptability if, it turn, the agency grants that these public submissions be officially recognized as part of the Project Record for judicial determination of its relevance. Courts should be allowed to judge whether the Forest Service is arbitrary and capricious in what it chooses to consider as best available science or otherwise relevant to its project analysis. The Forest Service might not like the judiciary reviewing its actions, but a) the frequency of Forest Service decisions being enjoined clearly demonstrates a need for such oversight, and b) that’s how a democracy

works.

“Objections submitted on or via electronic external media (such as CD-ROMs or external hard drives) shall not be accepted due to computer security policies.” This creates a problem for cases where much new scientific information or other documents supporting objections might arise after the close of the comment period. And even if the proposed rule did not expressly limit the amount of new literature submitted as attachments to an objection as long as it is supported by the required cause-and-effect explanation, the question remains as to how it can be feasibly provided. For example, the Forest Service website to which these comments are submitted states, “You can attach up to 20 files, but each file cannot exceed 10MB.” Both the limitation on number of files and the size of individual files (megabytes) is arbitrary and unreasonable. Such limitations have, without proper authorization, plagued public comment and objection submissions for quite some time already. And the clause, “Comments submitted on or via electronic external media (such as CD-ROMs or external hard drives) shall not be accepted due to computer security policies” presents similar barriers for submissions of comments on Forest Service proposals. The Forest Service cannot point to any instances where submissions on external media/hard drives have breached security. It is inconceivable that the Forest Service is unable to analyze external media for security threats as other government agencies undoubtedly do. Clearly the Forest Service is only interested in arbitrarily limiting the number of attachments supporting opposing views, including independent science—not keeping its internet portals or computers secure.

“For objections …Electronic documents must be in .doc, .docx, .pdf, or .txt document formats. …Objections (sic) submitted electronically must be in .doc, .docx, .pdf, or .txt document formats...” These limitations are also arbitrary, unreasonable and unwarranted. The Forest Service website to which these comments are submitted says, “Valid file types include: bmp, docx, gif, jpg, jpeg, pdf, png, pptx, rtf, sgml, tif, tiff, txt, wpd, xlsx, xml” so why not with comments and objections?

“References and attachments. The following documents may be incorporated by reference in the comments submitted. Other documents, attachments, or website links are not allowed except as specified. …(2) Forest Service directives and land management plans.” We fail to see why the agency’s own regulatory documents must be expressly incorporated. The NEPA documents being commented on already incorporate them. This signals that the agency is attempting to distance itself from the planning record upon which the validation of the land management plan—in its position of being tiered to—is based. That record, including the full documentation of public participation during the entire planning process, must also be available for incorporation. It is disturbing that the agency wants to avoid accountability to those members of the public who went to great pains in participating in the planning process. So for example, where FOC disagrees with the lack of protections for wildlife in the applicable land management plan, and expressed this throughout the planning NEPA and objection phases, then where projects are being proposed to implement actions that exemplify those very threats to wildlife, this proposed rule would force us reiterate our entire planning participation in regards to wildlife—even though the agency already has our concerns on record. This is beyond absurd.

Elimination of higher agency review

“As the Agency continues to navigate organizational change and streamline processes, it is more efficient and effective to allow the objection process to remain with the responsible official and interdisciplinary team most familiar with the project or activities that are subject to the objection process.” Since the responsible official will have shown they were incapable of designing a project in alignment with laws and public values over the months-long duration of development and analysis, etc. there should be no expectation that they would we willing and capable of making corrections and improvements over the course of 10 or 15 days, and adequately explaining it in five pages or less.

Declaring “emergency” outside of statutory authority

Section § 218.14: “Circumstances requiring immediate implementation. A situation may arise where immediate implementation of a proposed project or activity is needed, such as to provide relief from hazards threatening human health and safety, mitigate threats to natural resources on National Forest System or adjacent lands, or avoid a loss of commodity value sufficient to jeopardize the Agency’s ability to accomplish project objectives directly related to resource protection or restoration.” In its context, it is not clear if this is referring to projects “developed under statutory emergency authorities not subject to objections” as stated earlier in the proposed rule (emphasis added). Therefore, Section § 218.14 appears to authorize bypassing the objection process in instances where procedures and public participation steps were initiated under the assumption that there is no “emergency.” If this latter scenario is what is being contemplated, the Forest Service should explain the basis of such authority plus the limitations on authority to avoid arbitrary invocation of this section.

“This section is amended to specify how the procedures set forth in these regulations would apply to emergency situations requiring immediate actions, as determined by the Chief or Associate Chief.” The Forest Service must explain why the Forest Service Chief or Associate Chief would not be the Responsible Official in that instance. We would assume they would know the consequences (via reviewing project analysis) of such a determination. If not, the Chief or Associate Chief would have no business exercising such authority in what would then be essentially a rubber stamp exercise.

Switching processes midstream

“Projects subject to 36 CFR 218 that initiate the designated opportunity for public comment after the publication of this proposed rule may include a statement in the notice for opportunity to comment that the FONSI or ROD may be subject to the revised objection process if the final 36 CFR 218 rule is published before the project’s objection period.” Clearly the Forest Service is so chomping at the bit to exist within its proposed new regulatory framework that it expects citizens to act as if they are there also. It is quite perverse to burden the public with two different sets of rules and procedures at the same time they are already navigating an unpalatable Forest Service project proposal.

Other displays of contempt for public participation

We note:

“…an objection must include …a statement that demonstrates the connection between the issue included in the objection and the issue as it was included in prior specific written comments…”

“…an objection must include …Clearly articulated recommendations for the responsible official to consider taking and/or clearly stated specific mitigations for the responsible official to consider …when finalizing the FONSI or ROD.”

By including the above bold emphasized (ours) vague and subjective conditions, the Forest Service is signaling it will exercise more arbitrary justifications for ignoring and dismissing public concerns.

We also note:

“…an objection must include … clearly stated specific mitigations for the responsible official to consider (with statutory or regulatory authority for the mitigation specified) when finalizing the FONSI or ROD.”

By including the above bold emphasized (ours) clause, the agency unreasonably demands the public hold the Forest Service’s hand to remind them of the authorities they pretend to be unaware of. Well done!

In closing, the proposed rule is a thinly disguised ploy to prevent the public from exerting influence on national forest management. We strongly urge the USDA to withdraw it for the reasons we’ve expressed in this letter.

Sincerely,

Jeff Juel, Forest Policy Director
Friends of the Clearwater, P.O. Box 9241, Moscow, ID 83843

(208) 882-9755

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Dr. Harry Jageman's comment:

February 26, 2026

To: Director Ecosystem Management Coordination
201 14^th Street SW, Mailstop 1108, Washington, DC 20250-1124

Dear Sir:

I am appalled at the Forest Service’s veiled attempt to limit public input on proposed projects as outlined in the agency’s Proposed Project-Level Predecisional Administrative Review Process. Allowing only ten days to respond to an Environmental Assessment or twenty days to respond to a complex Environmental Impact Statement is totally insufficient. For the average person working a full-time job, that only gives one weekend and a few evenings to read, understand and formulate a response to a 75-page Environmental Assessment.   A little more time is given for a 150-page Environmental Impact Statement, but those documents are likely to be more complex and formulating a response is likely to be more time consuming.

You have said nothing about the fact that multiple projects could be released during the same timeframe, making it even harder for the public to respond appropriately.  You have not considered that members of the public are often traveling or are on work assignments that do not allow immediate review of your proposals.  Even with the existing 30 and 45-day comment periods, I have personally had instances where my schedule did not allow me to respond appropriately.  I can remember one instance when my local Forest released at least five projects during the Christmas holidays. Your proposal thus limits the ability of the general public to respond to your proposals and favors paid fulltime professionals in environmental groups, industry organizations or advocacy groups to respond to your proposals. That being said, ten days for and EA and twenty days for an EIS is not an adequate timeframe for anybody, professionals included.

Your idea of letting the responsible official become the reviewing officer for the project objection is also suspect.  It is highly unlikely that the people who designed the project are going to respond objectively to criticism of their proposal.  The idea of the old appeal and existing objection system was to put a fresh set of objective eyes on the proposal. Lack of oversight is likely to lead to more egregious proposals and losses in the court system.

I don’t see how putting page limits on comments, objections or even the environmental documents themselves are appropriate.  Some concerns may require longer explanations, especially when the Forest Service is limiting the size of the environmental documents to 90-pages for an EA and 150-pages for an EIS.  With shorter project descriptions and limited discussion of environmental impacts by the Forest Service, it is likely that even more detail may be needed to respond to complex issues like impacts to water quality, wildlife, and vegetative condition.  Please drop these arbitrary page requirements.

You have also proposed limiting attachments and alternative scientific publications to comments and objectives.   This provision will allow Forest Service officials to “cherry pick” scientific publications favorable to their position and exclude potentially important and credible information into the project record.  For controversial issues like fuels management and the impact of logging on wildfire ignition and behavior, the other side of the issue is unlikely to be brought forward without public oversight.  Please drop provisions that exclude what the public can attach to their comments and/or objections.

You have said you are going to eliminate project notifications in newspapers and the Federal Register.  If this is done you must maintain opportunities for individuals and organizations to be notified regarding all potential projects either by text or email.  Notifications should include all potential projects including categorical exclusions and emergency proposals that are not part of the objection process.  The public must be given the opportunity to fully understand what is going on their public lands without having to search multiple websites on a recurring basis.  Individuals and organizations must be able to sign up for appropriate automatic notification of all projects on a particular Forest prior to the final decision being made (no exceptions).

In summary, you have not made a sufficient case for significantly reducing public input on proposed projects.  You estimate that the current system adds 120-165 days to a proposed project that is dealing with forest conditions that will have consequences for decades.  In comparison to the impacts you are creating, this is a relatively short timeframe! If done correctly, project staff work can often take several months or even years and there is no reason why staff work can not be done concurrently with collecting and responding to public comment.  Please work to include public input into your decisions and not exclude it.  This has always been the goal of NEPA.

/s/ Harry R. Jageman
Dr. Harry R. Jageman
U.S. Forest Service Retired

A wonderful Friends of the Clearwater member, Christine Gertschen, sent us this letter to the editor they submitted.

"In 2023, the Idaho Wolf Control Board approved proposals to allocate $140,000 to hire private contractors to use aerial gunning to kill wolves on federal lands, grazing allotments and private property, the Center for Biological Diversity, Western Watersheds Project, and International Wildlife Coexistence Network, petitioned the U.S. Forest Service to use its authority to prohibit aerial gunning by private contractors on Idaho’s national forests, asking that USFS use its authority to “to protect wildlife, public safety, recreational interests, and wilderness values by issuing an order for … regulations that ban aerial gunning and predator control by private contractors on Idaho’s national forests”.

The same ranchers and legislators are back with House Bill 630 which authorizes the Dept. of Agriculture to issue free permits for AERIAL GUNNING of native wolves, coyotes and foxes.  This bill replaces Section 22-102A that prohibits aerial gunning by private contractors.  APHIS/Wildlife Services has been using aerial gunning to kill entire packs of wolves each year in the Lolo.  HB 630 expands upon this to allow aerial hunting by nearly anyone on any grazing allotment in Idaho.

IDFG authorizes and supports hunters and trappers in killing of hundreds of wolves, foxes, and thousands of coyotes each year by nearly any means.  Indiscriminate traps and snares kill thousands of other native species each year.  HB 630 would increase the killing what remains of our biodiversity.      

During hunting season our public lands are full of humans on motorized vehicles armed with a variety of high-powered weapons patrolling the backcountry to kill the wildlife that belongs to all Idahoans.  HB 630 would remove all protections on native wildlife and poses a threat to all of us and our native wildlife that we love so much.  House representatives must vote NO on HB 630.*"

Christine Gertschen

Hailey, Idaho

*Unfortunately, HB 630 passed through Idaho's House of Representatives shortly after the writing of this letter to the editor. Please contact your Idaho Senators TODAY and tell them to VOTE NO on this incredibly harmful and inhumane practice.

Find your district's senator here to contact them!

Good news is hard to find. But for imperiled wolverines, two new efforts are giving hope for the future.

With only about 300 wolverines in the entire Lower 48, FOC achieved a huge win when the US Fish and Wildlife Service (USFWS) finally listed wolverines in December 2023.

However, we are not resting on our laurels, and have been proactive in fighting for this icon of the alpine West. We are involved in two actions to save wolverines nationally and in Idaho:

1. Suing the USFWS to designate critical habitat for wolverines
2. Protecting wolverines in the Idaho Panhandle from snowmobiles

Let's look at both actions in more detail.

1. Establishing Critical Habitat for Wolverines Nationally

The Endangered Species Act (ESA) requires the Fish and Wildlife Service to designate critical habitat (areas where a species have additional protections for their recovery) within one year of listing. They are now more than a year overdue in designating critical habitat for wolverines.

Friends of the Clearwater, along with several allies, are suing the USFWS to force action. We are represented by Western Environmental Law Center (WELC).

You can read the full press release here.

From our Forest Policy Director Jeff Juel:

"In an age when wild, undisturbed areas have already become too rare, we believe it is vital that the USFWS identify and protect the critical habitat the wolverine, a species which perhaps best symbolizes the spirit of wildness, needs to survive.

And this means improving core habitat security and also landscape connectivity so this wide-ranging species can increase its precariously low population of only about 300 in the Lower 48 states to fully recover across its historic home range in the Northern U.S. Rocky Mountains and beyond."

2. Defending wolverine habitat in the Panhandle

Keeping snowmobiles off of wolverine dens

In a win for local wolverine populations, the Idaho Panhandle National Forests (IPNF) has agreed to reconsult the USFWS to make sure the Kaniksu Over-Snow Vehicle (OSV) Project won't harm habitat for the imperiled wolverine.

The Kaniksu OSV Project, designed to increase snowmobiling opportunities, originally faced scrutiny for its potential impacts to federally threatened grizzly bears. We, along with Western Environmental Law Center (WELC), WildEarth Guardians, Selkirk Conservation Alliance, and Inland Empire Task Force, believed that authorizing the plan without consulting on newly-listed wolverines would constitute a violation of the ESA.

Fortunately, the IPNF conceded to our request, and is now seeking reconsultation with the Fish and Wildlife Service. That means over 1 million acres of key habitat are temporarily safe from the impacts of snowmobiling.

Special thanks to activist Paul Sieracki, who put in many hours creating maps of wolverine habitat that helped make the case for reconsultation.

If you support our work protecting wolverines, please consider becoming a monthly donor on our website. Monthly donations (even small ones) make a huge difference for keeping our organization at full capacity year round.

Thank you!

Public Lands should serve the Public Good

The following list is just some of the work that we do everyday to ensure that our public lands are used for their highest and greatest good—as refuge for Wild Nature.

1. We are advocating for Roadless Wildlands

The Trump administration set it's sights on rescinding the 2001 Roadless Rule in September. We, and thousands of others, sounded the alarm on this affront to wild areas.

More than 625,000 comments were submitted in the absurdly short time frame (21 days, as opposed to several months for the creation of the rule). More than 99.2% of the comments supported keeping the rule, according to one source.

There are some roadless areas under direct threat, including portions of the Grizzly and Old-growth 8 (see below). Friends of the Clearwater advocates for preserving all remaining roadless areas as wilderness—and winning as strong a rule as possible until then!

2. We are fighting for grizzly bear habitat and old-growth forests in Idaho.

We filed a lawsuit to protect grizzly bear habitat and old growth areas on the Nez Perce-Clearwater National Forests. Eight timber sales, primarily on the Nez Perce portion of the forest, pose significant risks for wildlife and habitat.

Grizzly Bears

These 8 timber sales would significantly harm recovering populations of grizzly bears in central Idaho, creating or opening 134 miles of roads and degrading habitat. Roads are the primary driver of grizzly bear mortality, largely because they increase opportunities for bear-human conflict.

The Bitterroot Ecosystem is called the "grizzly bear promised land" for its high-quality habitat. It needs to stay that way until the Great Bear is truly recovered.

Old-Growth

Likewise, old growth areas are not adequately protected from logging by these projects. That is what initially brought us to litigate the Hungry Ridge and End of the World timber sales (which are included in this litigation) in the first place, which we first won in court in 2022.

3. We are pressuring agencies to give full protections for wolverines.

With only about 300 remaining in the lower 48, wolverines are exceedingly rare. In December 2023, they won protections under the Endangered Species Act because of a lawsuit brought by FOC and allies.

Locally, we are supporting our allies in the Panhandle by filing a notice of intent against a proposal to significantly expand winter over snow use in important wolverine habitat in the Selkirks of North Idaho.

Nationally, the next step is ensuring that critical habitat is adequately protected. We continue to monitor the actions of the US Fish and Wildlife Service, and are prepared to take necessary action to ensure that wolverines see timely protections.

4. We are standing up for wolves, the most persecuted carnivore in America.

Due to the huge liberalization and unethical wolf harvest in the northern Rockies, we asked and received a Federal District Court ruling in our favor and ordering the U.S. Fish and Wildlife Service to reconsider its decision to not protect wolves under the Endangered Species Act. View article

Additionally, our efforts to reign in trapping of wolves in grizzly bear habitat was successful in 2024, leading to new regulations that have offered safety for the imperiled carnivore. We have continued that litigation in 2025.

5. We are challenging bad road policy over the divide.

FOC and allies filed a lawsuit in December 2024 challenging federal agencies’ plans to allow increased road building in the Bitterroot National Forest that would cause harm to grizzly bears and bull trout, both of which are listed as Threatened under the Endangered Species Act.

The lawsuit challenges the removal of Bitterroot Forest Plan Amendments that ensure road density standards. This litigation is a real team effort from Friends of the Bitterroot, Native Ecosystems Council, WildEarth Guardians, and Friends of the Clearwater.

6. We are keeping track of real conditions in the forest.

In 2025, we monitored 28 sites in the Nez Perce-Clearwater National Forest to ensure no violations of Wilderness, road closures, road building, timber harvest rules or water protections.

We found numerous violations we will send to US Forest Service to address, and work with our allies to discuss other steps to solve these violations. With Trump's huge cuts to public land agencies in 2025, there will be even less on the ground monitoring form the Forest Service.

7. We are expanding our team.

We recently hired an Executive Director, Kyran Kunkel, and Office Manager, Krystal Starkey, to significantly ramp up FOC capacity.

8. We are creating awareness.

This year, we reached more people, including over 3,000 people online via our email list. We have had over 50 new donors this year and are close to the milestone of 500 current dues-paying members.

We are also getting back into events and community actions, including potlucks, letter-writing events, concerts, and more.

9. We are building forward.

We are building on nearly 40 years of results for the region, meeting the huge challenges of our era, and charting a new proactive course forward.

The FOC board unanimously approved our Big New Plan to protect the Wild Clearwater—more coming on that soon!

If you love native wildlife, consider a donation to Friends of the Clearwater to continue our work.

Roadless Areas Under Threat

The Trump administration has opened a comment period starting this Friday, August 29^th, in order to rescind the 2001 National Roadless Rule. That regulation largely limits road construction and logging on national forest wildlands in most of the United States. The US Department of Agriculture opened up a comment period today. Comments are accepted until September 19^th.

This is essentially another version of a public lands selloff. This administration wants to sell out the public’s forests by opening remote, protected areas to logging, roadbuilding and other development that will forever change the character of these forest that belong to all of us.

What about Idaho?

With more than 9 million acres of roadless national forests, Idaho is the wildest state in the Lower 48. Our mission area boasts roughly 1.5 million acres of roadless forest, including iconic wild landscapes like the Great Burn, Meadow Creek, Mallard-Larkins, and Weitas Creek roadless areas.

As of today, the 2008 Idaho Roadless Rule, a (much weaker) regulation that governs those roadless areas in Idaho, has not been targeted by the Trump administration. However, we strongly encourage commenting on this important change in federal policy. The roadless rule is our best (and perhaps only) chance to protect wild national forests during this administration.

What to Comment

We need you to stand up for these irreplaceable wild places. Here are three basic talking points to inform your comment:

1. Do not rescind the 2001 Roadless Rule.

The 2001 Roadless Rule has limited development of wild public lands in most of the wild forests of the US. These are invaluable places for wildlife and backcountry recreation.

2. Increase Protections for Wildlands

Roadless areas should have greater protections under federal regulations, not less. Existing loopholes in the Idaho, Colorado, and National rules can and should be closed.

3. Protect Idaho and Colorado wildlands.

The roadless rule should be re-written to include Idaho and Colorado, which are currently governed by much weaker regulations.

Telling Your Story

As always, Friends of the Clearwater recommends writing an individualized comment, not copying and pasting from organizations (including us!). Telling your personal story helps make your case. Have you hiked the Great Burn in Montana? Have you fished Weitas Creek in Idaho? Have you hunted in Nevada’s Ruby mountains?

Whatever is most important to you, whether it’s abundant wildlife, carbon-sequestering forests, or revitalizing solitude, is what is most important to say.

Where to comment: https://www.federalregister.gov/d/2025-16581

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Roadless FAQs

What are roadless areas?

Roadless areas are undeveloped national forest lands. They are essentially wilderness areas without congressional protection. Roadless and unroaded wild places have been in massive decline for the last century, caused by insatiable expansion of human infrastructure and exploitation. Today, roadless areas make up roughly 60 million acres of the national forests of the United States, or 2.5% of the entire country. The majority of those areas are located in Alaska and the Western half of the lower 48. Idaho has 9 million acres of roadless public lands, the most of any in the lower 48.

Wild, undeveloped areas on other public lands (managed by the BLM, USFWS, or NPS) are administered differently.

How do roadless areas protect wildlife?

Roadless areas are crucial for many kinds of wildlife. Elk herds benefit from the habitat security of places far from easy access by automobile or OHV. Several wild carnivores are essentially roadless-dependent, like grizzly bears and wolverines. Roadless watersheds are some of the most productive for cold-water fish in the region, like the salmon-bearing Meadow Creek, which is nearly entirely roadless.

How do roadless areas affect climate change?

Roadless areas are critical to reduce climate change impacts. American forests absorb roughly 1/3rd of the annual fossil emissions of the country. Many old-growth forests, which keep millions of tons of carbon out of the atmosphere for centuries or millennia, are found in roadless areas. Unlogged forests consistently store more carbon than logged forests.

Why are Idaho and Colorado not included in the 2001 Rule?

Roadless areas in Idaho and Colorado are currently governed by two state-specific federal rules. These rules are much more lenient for road-building and timber production than the national rule. Both states should be included on a stronger version of the national (2001) roadless rule.

Why is the Trump administration targeting wild public lands?

The Trump administration’s view of public lands is that they are only a source of raw materials for corporations. In order to hit the ludicrously high timber targets on the national forests, roadless areas would have to be opened up to much greater logging, roadbuilding, and development.

Are roadless areas wilderness?

Roadless areas are "wild" but not congressionally-designated wilderness areas. They are essentially unprotected wildernesses. Most congressionally-protected wildernesses were once inventoried roadless areas (IRAs). A small number of roadless areas are recommended for protection as wilderness by the US Forest Service, most are not.

How would NREPA change roadless protections?

The Northern Rockies Ecosystem Protection Act (NREPA) would permanently protect 20 million acres of roadless country as wilderness in six states. It has been introduced as recently as this year: https://allianceforthewildrockies.org/nrepa/

Is the 2001 Roadless Rule a law?

No. The Roadless Rule is a federal regulation that was created at the end of the Clinton administration. It is not a law, but is subject to the same standards of public process that other federal actions are. The Trump administration, more than any other, has a general disdain for the public process and legal accountability for the government and corporations.

Why is logging in roadless areas an issue?

Roadless areas tend to be in very steep, high elevation areas, like the more remote parts of the Rocky Mountains. These areas are very expensive to log, and timber projects on public lands almost always come at a loss to the tax-payer. The costs of fixing roads is immense (the Forest Service is the largest road manager on the planet, managing some 380,000 miles of active roads, roughly five times more mileage than the US interstate system), and the damages to wildlife are diverse and chronic.

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Further Reading:

• Interactive roadless area map
• Open letter on increasing roadless protections by Western Watersheds, John Muir Project, and over 150 organizations
• Roadless Report detailing problems with 2001 and Idaho rule
• Roadless areas and wildfire by George Wuerthner
• Roadless rule defense kit
• FOC Roadless Page: https://www.friendsoftheclearwater.org/roadless/

“…trees and plants have agency. They perceive, relate, and communicate; they exercise various behaviors. They cooperate, make decisions, learn, and remember—qualities we normally ascribe to sentience, wisdom, intelligence.

"By noting how trees, animals, and even fungi—any and all nonhuman species—have this agency, we can acknowledge that they deserve as much regard as we accord ourselves.” —

Suzanne Simard, Finding the Mother Tree: Discovering the Wisdom of the Forest

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In our efforts towards conservation of wild forests, we often invoke the concept of “biological diversity.” To most people, the term brings to mind the multitude of native fish, wildlife, and plant species and how those species interact with one another in our favorite wild places.

And during our visits to these places, although we often notice things like mushrooms or millipedes on the forest floor, seldom do we contemplate the diversity they might signify for the vast assemblage of species living beneath the ground’s surface.

"The soil harbors huge reservoirs of biological diversity, with over 40% of terrestrial organisms associated with soils during their life cycle."

The soil harbors huge reservoirs of biological diversity, with over 40% of terrestrial organisms associated with soils during their life cycle. This reservoir includes animals such as nematodes, oribatid mites, enchytraeids, tardigrades, springtails, ants, ground beetles, centipedes, millipedes and earthworms, fungi, the single-celled bacteria and archaea, and protists, (a kingdom separate from animals, plants or fungi which includes algae, amoebae and slime molds). Together these organisms comprise the “soil food web” where one thing eats another—or is eaten—and so forth.

Despite longstanding scientific investigation, general public awareness of this underground ecology has been limited. In recent years this has changed, thanks in part to groundbreaking research by ecologist Suzanne Simard of the University of British Columbia, and reports of her discoveries in popular media. Her research centers on connection and communication between organisms in forest ecosystems as facilitated by mycorrhizal (fungal) networks, and the intricate symbiotic relationships thus formed between organisms of different species.

“Most life on land depends ultimately on one relationship: the mycorrhiza, the intimate and mutually dependent coexistence of fungi and the root systems of plants.” — E.O. Wilson

The profound role of fungi was noted by the renowned biologist E.O. Wilson, who once wrote, “Most life on land depends ultimately on one relationship: the mycorrhiza, the intimate and mutually dependent coexistence of fungi and the root systems of plants.” Mushrooms, the fruiting body of fungi, are just the tip of the iceberg. The main fungal body is the mycelium, the mass of tissue growing in soil and other substrates such as dead wood or other biomass. In turn, mycorrhizae are part plant, part fungus, consisting of the mycelia and the roots of plants. But it is the mycorrhiza’s functions that are most fascinating.

Consider a genus of fungi, Rhizopogon, commonly known as a false truffle. They form mycorrhyzae with several conifer tree species. Mycorrhizae might appear as a swollen, whitish mass of mycelium surrounding the tips of tree roots. It is the structure where water and nutrients exchange between the Rhizopogon and the tree, to the benefit of both. The Rhizopogon mycelium absorbs water and other essential nutrients such as nitrogen from the soil more efficiently than roots, due to the fact that the hyphae (filaments that make up the mycelium) are able to penetrate small spaces and efficiently extend much more widely than tree roots. And while trees thus receive enhanced access to building blocks essential for growth in this symbiotic relationship, in turn the Rhizopogon feed on carbon (energy) in the form of plant sugars produced by trees. There are potentially multitudes of different fungal species in a given ecosystem, effecting similar and often quite different roles as networking entities.

The complexity of mycorrhizae’s ecological roles are astounding. Following a hunch, Simard fed CO₂ concentrated with a radioactive carbon isotope to individual trees via plastic bags placed around their branches. Recall that plants need carbon dioxide from the atmosphere along with sunlight to photosynthesize and grow. To her delight, she soon found an increase in radioactive carbon in the composition of surrounding trees. It turns out that the mycorrhizal network facilitates sharing of nutrients between trees! And the trees don’t even have to be of the same species.

Trees can share water, nutrients, and even information between themselves

The plot thickens further. Scientists have found that large, old trees tend to be more connected to neighboring trees through this mycorrhizal network than the younger ones. These hub trees literally influence the health and fitness of all the trees in the forest, leading to the notion of “mother trees.” And they act selectively; feeding seedlings that might be shaded and therefore otherwise unable to survive. Or transferring resources from dying trees to healthy ones. Oddly enough, there are even accounts of the roots of stumps being kept alive through this network, years after the tree was cut and its photosynthesis halted. It even turns out hub trees can favor offspring from their own seed more than unrelated trees of the same species.

The complexity of chemical transmission between plants goes beyond nutrient transfer. Information itself is a currency. In the human body, glutamate and glycine are common neurotransmitters facilitating signals in brain and spinal tissue across synapses (the connections between neurons, or nerve cells). In plants, glutamine and glycine are involved in triggering the aforementioned exchange of nitrogen and carbon through mycorrhizal networks, and they also help to facilitate fundamental metabolic functions within plants. Experimentally, stress signals have been shown to transfer from injured plants to healthy ones across mycorrhizal networks even more rapidly than carbon, nutrients or water. Healthy plants can then produces defense enzymes, increasing their resistance to the pest afflicting their neighbors.

Since it’s commonly accepted that neural connections facilitating the functioning of the human brain and nervous system give rise to what we call “intelligence”, this begs the question—do trees, plants, or other non-animal life forms also possess intelligence? Our own nervous systems control internal biological functions, and also muscle activity effecting behaviors we see as signs of intelligence. So is this ecological entity we call a “forest“ exhibiting intelligence, given the complexity of the below-ground connectivity between organisms, given the behaviors it facilitates?

These communication networks not only appear underground. In response to attack by defoliating insects, trees transmit airborne volatile chemical signals. Scientists have found that, neighboring trees cued by those signals are able to marshal defenses against the defoliating insects.

Here’s an example of another, more complex network. Some fungi cause tree decay, leading to woodpeckers being able to excavate nest cavities, which are later used as nests and dens for other species, such as squirrels, who eat false truffles and thus spread spores, benefitting trees by the creation of mycorrhizal networks, which help to grow large trees, which eventually provide decaying wood structures for woodpeckers.

It turns out there are many such networks interacting with each other, nested within what is called a “meta-network.” These meta-networks provide for interactions and feedback among the various connected entities, leading to structure and function that define “complex adaptive systems.” In such systems, change and adaptation occur constantly as a result of these interactions. Is this intelligence?

Some would answer yes, because individuals they study perceive, process, and communicate with other organisms and the environment, and remember and use this information to learn, adapt, and heal themselves and others. Another scientific view is that, within this meta-network, a forest’s mycorrhizal networks are most crucial in organizing other networks, given their critical role in establishment and growth of trees. Fungi are “keystone” species because they are vital nodes in this network of connectivity. Russula brevipes, for example, is a fungal keystone species which has the most connections to other species in mature forest ecosystems.

This essay barely scratches the surface of what scientists have discovered about these complex adaptive systems. And of course, science itself is a process that leads to far more questions than answers. But clearly, as major actors on this stage of life on earth, humans play an outsized role. And far too often, our acts sever natural connections, resulting in vast unintended consequences, literally shaking the foundation of the life-giving biosphere, these complex adaptive systems that have given rise to our very existence.

"What does matter—to our very survival—is what humans believe about other living things"

This calls into question what exactly is “intelligence”, and who or what actually possesses it. Because the term is of our own creation, perhaps the question itself is not so relevant. What does matter—to our very survival—is what humans believe about other living things, forests, ecosystems, and even the entire biosphere, and our actions based on those beliefs, and ultimately, the consequences of our actions. For example, in North America what little is left of the vast, pre-settlement extent of old-growth forests is still being targeted for clearcutting—even in national forests. Also, in the U.S. Northern Rockies “treatments” are proposed allegedly to “enhance” old growth, reflecting the prevailing management paradigm of dominating and controlling nature rather than acting in harmony in the acknowledgement that we actually know so little about these wondrous forests. Does anyone really believe that ripping centuries old trees from the web of life is enhancing anything but greed?

In “The Social Life of Forests” writer Ferris Jabr wrote in the New York Times, “The razing of an old-growth forest is not just the destruction of magnificent individual trees—it’s the collapse of an ancient republic whose interspecies covenant of reciprocation and compromise is essential for the survival of Earth as we’ve known it.” This theme of reciprocation, between humans and the plants, animals, and spirits of the natural world, is common in the myths, lessons, and other stories handed down over countless generations of aboriginal peoples. This wisdom has been largely dismissed by the empires that have largely conquered and displaced native cultures, too often with tragic genocidal consequences. To the degree we yet fail to heed this ancient wisdom, western civilization—and humanity itself—approaches the brink of its own tragic demise.

Of her book “Finding the Mother Tree” Suzanne Simard states:

“This is a book—not so much about us saving trees, it’s more about how the trees will save us.”

The connections she describes are lessons to us, from the trees and from everything they touch. If we heed those lessons—if we allow ourselves to feel the connections—like the mother trees we will be able to grow, heal and truly enhance.

Old timers might call this Defender’s Species Spotlight the fisher cat. But the fisher (Pekania pennanti) is not a cat, nor does it eat fish. It might better be called the porcupine-eating weasel, and is one of the rarest carnivores in the Clearwater Basin.

Conservation status: Pacific populations are threatened; Northern Rockies populations are not listed.

Species Description

            Fishers are cat-sized carnivores closely related to pine martens and wolverines, adapted to the northern forests of North America. They are adept at climbing trees in search of prey or to escape larger predators. Fishers are solitary generalists, roaming the forest in search of any prey they can get their paws on, primarily squirrels, rabbits, hares, mice, and porcupines.

            Porcupines are the most infamous of fisher’s prey. Fishers seem to be the only common predator of the needle-armored rodents, so much so that timber companies have re-introduced fishers to reduce porcupine impacts on saplings. Fishers aggressively target the porcupine’s face—the only part of its body without quills—until it dies and can be dismembered. For large prey, fishers will store pieces of their prey in caches to finish eating later.

            Fishers live in closed-canopy forests. They tend to live in lower elevations than pine martens or wolverines. Like other wild carnivores, their presence is an indicator of ecological health. While fishers in the American Northeast seem to be expanding, populations in the Pacific ranges and Northern Rockies are in decline.

Life Cycle

            Fishers are solitary except during mating season in spring. Gestation, however, is delayed until the next February, nearly a whole year. After a 50-day gestation, females give birth to one to four kits. Like other weasels, fishers use two dens, giving birth in one and moving the kits to a different den to raise their young. Dens are usually in hollow trees, so older forests are key for denning habitat. Kits are altricial, born blind and wholly dependent on their mother. After about seven weeks, kits open their eyes. They feed only on milk for eight to ten weeks before weaning. At five months old, juveniles are forced out on their own.

Evolution

            Wolverines and the Latin American tayra are the fishers closest relatives, all of which are part of subfamily Gulonidnae, which includes martens and the sable. Fossil records seem to show that American mustelids evolved in Eurasia and dispersed several times over land bridges.[1]

            The earliest conclusive fisher fossil was found in the John Day Fossil Beds National Monument in Oregon.[2] That fossil, a portion of an upper jaw and several teeth, is around 7 million years old. According to researchers, the fossil had larger teeth than today’s fishers, more closely resembling the teeth of present-day wolverines. 

Conservation

            Trappers and farmers killed off most fishers in the 19^th and 20^th centuries, the former to sell fur and the latter to protect poultry. Prior to White American settlement, fishers occupied the boreal forests of Canada, the Pacific Coast forests, the Northern Rockies, and the Eastern hardwood forests as far south as Georgia. However, they were extirpated in the US south and had dramatic range reductions elsewhere. According to some researchers, fisher populations are now growing in New England and Eastern Canada, where some mature hardwood forests have recovered. In the early 2000s, fishers were reintroduced into Tennessee.[3]

            On the West Coast, the Pacific subspecies of fisher is at risk of extinction.[4] Old-growth logging continues to reduce their habitat and rodenticide (both legal, as used on tree farms, and illegal, as used in marijuana farms) has led to increased mortality. The Pacific fisher used to roam from western Washington south into California; today two isolated populations exist in the Klamath-Siskiyou region and the southern Sierras. Reintroductions have taken place at Olympic and Mount Rainier National Park in Washington State.[5]

            Fishers in the Northern Rockies do not have the protections of their West Coast counterparts. Fishers are one of the most elusive carnivores of the Clearwater and their exact population in the Northern Rockies is uncertain. For decades, it was believed all fishers in North Idaho and northwest Montana were descended from reintroduced animals; genetic research in 2006[6] showed that there was a small population of fishers in the Clearwater and Bitterroot mountains that was never extirpated. That genetic group, or haplotype, is unique to Clearwater country.

Research in Idaho in 2019 shows that those fishers in the Clearwater and Bitterroot are isolated from fishers in the Cabinet and Purcell ranges further north[7]. A larger hair-trap study between Idaho Fish and Game and Montana Fish Wildlife and Parks assessed fisher occupancy in Idaho and Montana in 2020[8].

            Habitat loss is the primary threat to Idaho’s fisher population, due to logging in mature and old-growth forests. The U.S. Forest Service overarching goal to clearcut North Idaho’s mesic pine-fir forests and replace them with ponderosa-larch plantations is not compatible with fisher survival, based on fisher’s preference for older, taller, structurally complex forests.[9] Rodenticide use, especially on private timberlands, may be a problem as well. Incidental trapping of fishers in Idaho as well as vehicle collisions[10] have been documented. Wildfire may harm fisher populations, though this is based on models and not first-hand data.[11]

            The Center for Biological Diversity petitioned the US Fish and Wildlife Service to list the Northern Rockies fisher as endangered in 2009 and 2013 (supported by Friends of the Clearwater and other groups).[12] The USFWS declined to list both times. As of 2025, fishers can still be legally trapped in Montana, and their habitat continues to be targeted for clearcutting across the region.

Other work referenced:

https://idfg.idaho.gov/sites/default/files/for_public_comment_draft_fisher_wolverine_and_canada_lynx_plan.pdf

https://www.science.smith.edu/departments/Biology/VHAYSSEN/msi/pdf/i0076-3519-156-01-0001.pdf

https://northcascades.org/pacific-fisher/

https://thefurbearers.com/blog/the-fisher-pekania-pennanti

https://idfg.idaho.gov/species/taxa/18029

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[1] https://bmcbiol.biomedcentral.com/articles/10.1186/1741-7007-6-10

[2] https://www.tandfonline.com/doi/full/10.1080/02724634.2013.722155#d1e541Species Fisher.doc

[3] https://www.chattanoogan.com/2001/11/7/14644/Elusive-Fishers-Make-Quiet-Return-to.aspxSpecies Fisher.doc

[4] https://www.fws.gov/species/fisher-pekania-pennanti

[5] https://www.nps.gov/olym/learn/nature/fisher-reintroduction.htm

[6] https://doi.org/10.1644/06-MAMM-A-217R1.1

[7] https://www.webpages.uidaho.edu/~jacks/Lucid.Fisher.2019.pdf

[8] https://fwp.mt.gov/binaries/content/assets/fwp/conservation/wildlife-reports/8-mfwp-fisher-study-annual-report-2020.pdfSpecies Fisher.doc

[9] https://research.fs.usda.gov/treesearch/download/52272.pdf

[10] https://www.inaturalist.org/observations/7380879

[11] https://research.fs.usda.gov/treesearch/64266

[12] https://www.biologicaldiversity.org/species/mammals/fisher/

Comment period EXTENDED to Friday, May 16th, 2025

Read the full documents and comment online here:

https://www.regulations.gov/docket/FWS-R6-ES-2024-0186/document

What is the rule?

The US Fish and Wildlife Service (USFWS) is changing direction on grizzly bear management in the Northern Rockies. This proposed rule would guide management and set rules on human activities throughout the region.

Why does it focus on the Northern Rockies?

Biologists and wildlife activists have long advocated for grizzly bears to be managed as one large population instead of isolated islands in the national parks. One connected population of a minimum of 3,000 to 5,000 grizzly bears is necessary to prevent extinction long term, especially with the onset of dramatic climate change.

We do need a large, connected population of bears in the Northern Rockies, which this rule claims to do.

Unfortunately, this rule aims to create a distinct population segment (DPS) for only the Northern Rockies, meaning that restoration of grizzly bears in the Wasatch Front, Southern Rockies, Sierra Nevada, and elsewhere is off the table. Any grizzlies outside the Northern Rockies would lose ESA protections. Even this DPS boundary is political and arbitrary—Oregon's Blue Mountains and Utah's Uinta Mountains are left off.

How does it connect isolated populations?

It doesn't. The proposed rule uses the same five "recovery areas" that are in place today, which do not connect. The proposed rule acknowledges the need for connective habitat, but such places should be explicitly included in recovery area boundaries. Additionally, because of the 4(d) change, grizzly bears outside of recovery zones would have less protection.

What are the recovery area boundaries in Idaho?

The recovery areas in Idaho in this proposed rule are the same as they currently are. This includes part of the Selkirk, a portion of the Cabinet-Yaak, a portion of the Greater Yellowstone, and the so-called Bitterroot Ecosystem, which is the combination of the Selway-Bitterroot and Frank Church-River of No Return Wildernesses.

Are those recovery areas based on science?

No! They are political boundaries that would allow grizzlies in some wilderness and little else. There are better alternatives to these that are based on habitat quality, while still remaining on public land.

The map below, created by Mike Bader and Paul Sieracki, shows what a larger Bitterroot Recovery Area would look like. This map includes important habitat outside of wilderness like in the Nez Perce-Clearwater, Payette, Boise, and Custer-Gallatin National Forests.

What is a 4(d) rule?

Section 4(d) of the Endangered Species Act details regulations on harming threatened and endangered species. It also, controversially, allows for limited "take" or harm of a species under certain conditions.

What does this 4(d) rule allow?

In this version of the rule, state agencies and livestock producers would be granted broad authority to kill grizzlies they deem a threat—even when non-lethal deterrents haven’t been exhausted.

The rule could lead to:

• Increased grizzly bear killings on public lands to appease livestock operators who already benefit from taxpayer-subsidized grazing fees.
  
• Preemptive killings of grizzlies found “lingering” near human-occupied areas, even if they have caused no harm.
  
• The potential for future grizzly bear hunting seasons, despite overwhelming public opposition to sport hunting of a federally protected species.

Won't killing grizzly bears increase their fear of humans?

No! Grizzly bears have no fear when food is near. The primary conflict between humans and bears is because of unsecured (human) food, trash, and livestock. This usually results in humans shooting the bear. Even as a protected species, 85% of grizzly bear mortality is human caused.

Creating serious standards for food and livestock in bear country is critical to reducing conflict, something that this proposed rule does not seriously address.

If this rule won't help, what will?

This version of the rule has problems. Public opinion swayed the USFWS before, and we can do it again. It's important to urge for strong protections for wildlife that are based in science and can make coexistence possible.

Friends of the Clearwater and our allies have created an outline for what better grizzly bear management in the Northern Rockies might look like.

You can read that PDF below!

New-vision-for-grizzly-bear-recovery-in-the-northern-rocky-mountains-FINAL

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EDITOR'S NOTE: Demographic information like population and inhabited range in this article refer to grizzly bears in the Lower 48 States unless otherwise stated.

Grizzly bears (Ursus arctos horribilis) are one of the great symbols of the American West, synonymous with wildness and might—and they are still threatened.

Since the US Fish and Wildlife Service (USFWS) first listed them in 1975, they have also been synonymous with Western politics, and their legal status continues to fuel debate.

In early 2025, thanks to many of your comments, the USFWS decided to keep grizzly bears listed as threatened in the Lower 48. They also announced a process to redefine how they manage the species in the Northern Rockies.

That announcement (and the accompanying rule-making process) has good and bad elements. Ultimately, their primary aim is to prevent grizzly extinction. So how do you do that?

What constitutes grizzly bear recovery?

When a species is listed as threatened or endangered, federal agencies often create rules and regulations to protect them. The Endangered Species Act is explicit about the scope of these protections and clear about the imperative to prevent extinction for every species.

However, removing protections, or "de-listing" has been less obvious. This ambiguity has plagued wildlife policy for decades, including for grizzly bears.

Some argue that grizzlies are already recovered, and so should be removed from protections. If you compare grizzly bear populations and occupied range between 1960 and present day, they argue, there are some reasons to be optimistic; populations in the Lower 48 have increased by 50% and grizzlies have expanded their range.

This is misleading. Presenting the information this way sets the baseline at 1960, when grizzly bears were nearly extinct. Prior to Euro-American settlement, there were an estimated 30,000 grizzly bears in the Lower 48.

Instead of comparing today to when grizzlies were almost extinct in 1960, let's compare today to when they were abundant in 1750. Using the same numbers, grizzly bears have increased from 2% of their 1750 population... to 3%.

Is a 1% increase "recovery"? Is that "restoration"? Is that reason enough to open up trophy hunting?

This context is vital to any discussion about grizzly bear recovery. For the last several decades, Western bureaucrats and their corporate constituents have argued that grizzly bears are fully recovered and must be removed from the Endangered Species List. Their reasoning relies on the baseline of 1960, when grizzlies were nearly limited to only Glacier and Yellowstone National Park.

It also ignores that humans are still responsible for 85% of grizzly bear fatalities while they are currently protected.

Idaho—the grizzly bear promised land

The best available research suggests that grizzly bears need a connected population of 3,000 to 5,000 in the Northern Rockies to ensure their survival for centuries to come.

Isolated populations of grizzly bears pose long-term risks. In Yellowstone National Park, whitebark pine trees, an important food source for grizzly bears, have all but died out. In Glacier National Park, berry production has become erratic with climate change. In the Selkirk and Cabinet-Yaak ecosystems, roads, recreation, and black bear hunting have kept those populations extremely small and genetically at risk of in-breeding.

Because of these pressures, as well as lethal "management" by wildlife agencies, it is very unlikely that the current population and distribution of bears is sustainable in the long run.

The vast wildlands of Central Idaho could provide a massive benefit to grizzly bears. One Montana grizzly bear researcher calls it the "grizzly bear promised land". This vast wild country could support hundreds of bears, and act as a genetic link between grizzlies in the Northern Continental Divide Ecosystem (near Glacier Nat'l Park) and the Greater Yellowstone Ecosystem.

Simply put, there is no "recovery" of grizzly bears in the Lower 48 until Idaho gets its bears back.

We need better "goalposts" for grizzlies

Claiming that a few hundred grizzly bears living outside national parks constitutes full recovery is bogus. Likewise, aiming for 30,000 grizzly bears in the American West is impossible (at least without a lot of zoos).

So what is a meaningful goal for grizzly recovery in the Northern Rockies?

A new vision for grizzlies in the Northern Rockies

Friends of the Clearwater, along with a diverse coalition of public lands and wildlife advocates, has outlined what that might look like. We've condensed a lot of science and policy into a vision for the sustainable management of grizzly bears.

This vision aims for meaningful policy in the Northern Rockies to ensure grizzly survival. Some of the more tangible points include:

• A minimum population of 3,000 grizzly bears in the Northern Rockies
• One connected population of bears instead of isolated "islands" within national parks
• Ending black bear baiting in grizzly habitat
• Implementing food storage orders in campgrounds
• Reducing highway and rail collisions
• Increasing agency funding for enforcement

And more. It's time to stop advocating for below the "bear minimum". We need to think big, act fast, and make sure that real protection can become law of the land.

You can read our vision in the embedded PDF below, open it in a new tab, or download it at the bottom of this page.

New-vision-for-grizzly-bear-recovery-in-the-northern-rocky-mountains-FINAL

This article was first published in the Spring 2024 edition of the Clearwater Defender. You can have the Defender delivered straight to your house when you become an FOC member.

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Natural History

Pacific lamprey (Entosphenus tridentatus) are eel-shaped jawless fish. Lamprey aren’t actually eels, but a kind of very primitive cartilaginous fish, like sharks and rays. They were some of the very first fish to evolve, at least 350 million years ago during the Cambrian explosion – before trees existed! Instead of a jaw, they have a circular mouth filled with teeth, which adult lamprey use to suck blood and fluids from larger fish and whales in the ocean (but they don’t kill their host).

Like salmon, they are anadromous, meaning they migrate between the Pacific ocean and freshwater streams to spawn. They spawn in gravelly, cold-water streams like the South Fork of the Clearwater, laying upwards of 100,000 eggs in summer.

Unlike salmon, though, newly-hatched, eyeless lamprey drift into the slow moving parts of streams, dig themselves into the sand, and filter-feed on algae for up to six years. In this stage they are most sensitive to pollution and high temperatures.

After their larval stage, they grow eyes and their circular-saw mouth, and start a long journey to the ocean. Little is known about their life at sea, but we do know that they attach themselves to a big host fish or whale for two years or more, just hanging on and sucking blood. After a buffet of liquid fish (and a big growth spurt), fattened adult lamprey start the journey back inland to spawn.

The way home is not easy! For one, adult lamprey don’t eat at all on the trip home, living solely off of fat reserves. For another, it’s very difficult for a mostly finless fish to get over falls and dams. They use their circular-saw mouths to latch on to and inch their way over boulders and waterfalls. Once they reach their spawning habitat, they mate and die, starting the cycle over again.

Conservation

Like other anadromous fish, their survival depends on managing the four H’s: habitat, harvest, hatcheries, and hydropower. In particular, hydropower has led to enormous population declines. Lamprey are weak swimmers, and do not swim up fish ladders as easily as salmon and steelhead. Reservoirs also degrade lamprey spawning habitat and expose them to increased predation.

Indigenous Importance

This collapse has harmed local Indigenous people. Lamprey are a key ceremonial food source of the Nez Perce and other Columbia Plateau Tribes, often caught by hand during migration. Their fatty meat is very nutritious and is often smoked and fed to children. Nez Perce Tribal elder Horace Axtell recalled:

“My great aunt was a medicine woman, and she would collect the fat that would drip off an eel as it was cooking over a fire. She would store the fat in a small bottle and use it for oil in lamps and for medicines.” (source: critfc.org)

White settlers largely overlooked the lamprey, or used them for bait. At the Celilo hatchery, (at the now-flooded Celilo falls), tens of thousands were caught and ground into fish food for salmon, basically propping up one rare species with another. It didn’t last long though. After the damming of northwestern rivers in the 1960s, populations collapsed.

In 2003, the Center for Biological Diversity and other northwest environmental groups petitioned the US Fish and Wildlife Service to list the fish on the Endangered Species Act. Unfortunately, the USFWS sidestepped listing lamprey as a threatened species, citing a lack of data.

Instead, they created a collaborative organization, the Pacific Lamprey Conservation Initiative, that has so far failed to alter the long-term declines of lamprey in the West. Such collaborative efforts are politically expedient but often legally unenforceable, undercutting the agency’s broad powers to protect our native wildlife.

In the Clearwater, populations of lamprey are functionally extinct. The 10-year average returning lamprey at the Lower Granite Dam is only 102 per year, down from perhaps tens of thousands prior to hydropower. Almost all individual Clearwater and Snake River basin populations are listed as critically imperiled or possibly extinct, as per a 2019 USFWS assessment.

The exceptions are in areas adult fish have been reintroduced by the Nez Perce Fisheries, like Asotin Creek, the Grande Ronde River, and the South Fork of the Salmon River. The Nez Perce and other Northwest Tribes have been very active in advocating for and reintroducing lamprey.

The fate of the lamprey, much like for salmon and steelhead, depends on breaching the Lower Four Snake River dams. As of 2024, political efforts to breach the dams have stalled, though staunch opposition to breaching is waning as fish populations collapse.

Friends of the Clearwater advocates for a future without the Lower Snake Dams, and with Pacific lamprey, perhaps the strangest critter in Idaho.