Conflation of Omnivory with Indifference to Foods and Habitats—Geographic and temporal variation in food availability and resulting diets of grizzly bears in the Northern Continental Divide Ecosystem (NCDE) have had major ramifications for demography and distribution of this population. U.S. Fish & Wildlife Service (FWS) and Montana’s Fish Wildlife & Parks (FWP) researchers have failed to address this variation in their research designs, asserting instead that because bears are omnivores, environmental and dietary changes are inconsequential. As a presumed logical derivative, managers have then contended that they are relieved of any burden to monitor foods and habitats in the NCDE.

Neglect of Variation in Diets and Habitats—Abundance of key foods has varied substantially during the last 40 years with demonstrable effects on demography and distribution of the NCDE grizzly bear population. A berry famine on the west side caused increases in bear mortality and distribution, coincident with terminal losses of whitebark pine in mountains of the East Front. The frequency and extent of wildfires also increased substantially since the mid-1980s, with resulting effects on habitat productivity. At the same time, stocking rates of cattle along the East Front declined and then recovered to record levels, coincident with substantial declines in mule deer populations. FWS and FWP researchers have failed to account for any of these changes in grizzly bear habitats, foods, and diets in their assessment of trends, threats, or projected future risks, and thereby fail to offer a realistic or insightful basis for management and recovery planning of the NCDE grizzly bear population.

Flawed Approaches to Demographic Research and Monitoring—Estimates of population growth for the NCDE grizzly bear population are entirely retrospective and, with passage of time, tethered to increasingly aged and irrelevant data that thereby make these estimates progressively more insensitive to current population trend. This failing is compounded by deficiencies in models and software (i.e., RISKMAN) used by FWP researchers to simulate population dynamics, resulting in substantial unacknowledged risks implicit to methods used to manage grizzly bear mortality. There is thus no credible basis for estimating current population size or recent growth rate for the NCDE grizzly bear population, and therefore no credible input into calculations that would presumably yield estimates of allowable mortality.

Neglect of Relations Between Environmental Variation and Increases in Distribution—Increases in grizzly bear distribution were uncoupled from increases in population size during the 1980s-2004 and 2009-2014 in the NCDE. Distribution increased by 3-4-fold more during these periods relative to any probable increases in numbers of bears, largely because of changes in habitat, food availability, and diet. The roles of habitat, food availability, and diet in driving changes in population distribution have not been addressed in any substantive way by FWP researchers, which fatally compromises any government analysis of distributional dynamics for the NCDE grizzly bear population.

Neglect of Spatial Demographic Structure—When adjusted to correct for much lower odds of detection compared to other human-causes, poaching emerges as the most important reason why adult grizzly bears die in the NCDE (roughly 30% of all deaths), in part driven by the extent of road systems in landscapes with industrial-scale logging. These extensive road systems are concentrated in western portions of the NCDE, where proportionally much more land is devoted to timber production. Despite the extent to which mortality is associated with roads, FWP researchers have not produced a spatially-explicit analysis of grizzly bear population demography that addresses this structure, including likely source-sink dynamics.

Neglect of Foreseeable Environmental Change—Projected climate change will likely result in loss of much of the berry-producing shrubs in most places with resulting adverse consequences for grizzly bears in portions of the NCDE where berries currently comprise a critical part of the bear diet. Climate change will also cause major changes in vegetation composition directly because of changing weather norms and extremes and, indirectly, because of increased frequency and extent of wildfires. Increases in human populations and infrastructure will compound climate-driven habitat degradation, especially in the Flathead and Mission Valleys and the environs of Missoula. Despite the severity of these foreseeable changes, FWS and FWP researchers have not meaningfully addressed any in demographic analyses and projections.