On November 1, 2017, we submitted our comments to the Director of Fish and Wildlife, Jennifer Psyllakis, Province of British Columbia.
Dear Director Psyllakis:
We would like to like to thank you and the Minister for this opportunity to comment on the proposed regulatory changes to the hunting of grizzly bears in BC. On behalf of our supporters, our scientists, and our staff, we wish to express our gratitude to the Minister and to this government for having the courage to address this important issue.
The end of the killing of grizzly bears in the Great Bear Rainforest is a very positive move that reflects the intrinsic and economic value of this iconic species. It is an important step in reconciliation with First Nations, and recognizes the huge investment that First Nations communities have made, and are making, in stewardship, research, and wildlife viewing centered on grizzly bears and spirit bears. The positive effects of the employment opportunities generated in these communities cannot be overstated.
It also recognizes the economic value of the bear viewing industry, which has made BC a global destination for remarkable opportunities to view these beautiful animals in an astounding natural setting.
Importantly, it recognizes the sentiments and demands of the vast majority of the general population and a significant majority of the hunting community.
Although we enthusiastically support these changes, we have some concerns about the mechanisms of implementation.
We believe the well-intentioned policy regarding the ending of “trophy hunting” of grizzly bears will fall short of its goal. Our scientists, staff, and supporters see potential for serious and possibly insurmountable, logistical problems with implementing and enforcing this policy. Following, we identify what we believe will be serious unintended consequences from this policy.
Comments on total ban in the GBR
- Although we understand the requirement to have a legally definable extent of the GBR, the land orders map, while convenient, reflects the smallest of the possible definitions. In addition, the redrawing of the MU’s to exclude those areas outside this narrow definition of the GBR arbitrarily divides populations and does not reflect the goal of protecting the grizzly bears of the GBR. As was powerfully illustrated by the killing of Bear 148 and Bear 125, and as we have found from extensive monitoring of bear populations in the GBR, grizzly bears are wide-ranging animals and often cross political and administrative boundaries. Our biologists suggest that to effectively end the hunting of GBR bears, it would require one or more of the following:
- The approach most consistent with the Ministry’s definition of grizzly bear populations, would be to fully close the hunt across the entirety of any grizzly bear population units (GBPU’s) that overlap the GBR land orders boundary. By definition, GBPU’s are biologically relevant sub-populations. Ending the hunt in only one part of a given GBPU would mean that it’s population would still be subject to hunting whenever individuals cross over the political boundary of the GBR.
- A similarly ecologically coherent alternative, would be to add a no-hunting transition zone of approximately 1 home range (110km) around the land orders boundary.
- Include the balance of the MU’s that are outside the land orders boundary in the closure.
- The exclusion of portions of certain MU’s will likely lead to conflict as there is already significant grizzly bear viewing in some of these areas and they are important to the bear viewing industry.
- We have concerns with the exclusion of black bears from the closure in the GBR for several reasons.
- This is the core area where the rare white phase (Spirit Bear) gene is found. Although killing a white-coated spirit bear is already illegal, distinguishing a black coated bear which carries the rare gene is impossible.
- There is a risk of dark coated grizzly bears being misidentified as black bears and being shot.
- Most importantly, the presence of (black) bear hunting in areas where grizzly and spirit bears are being viewed regularly will be very detrimental to the bear viewing. Bear viewing opportunities depend unquestionably on individual bears becoming comfortable with predictable human behaviour that brings them no harm. Continued black bear hunting will shatter this important trust. First Nations communities who depend heavily on bear viewing have expressed their concerns about this and have included black bears in their ban on bear hunting in their traditional territories.
- there is an obvious and very real safety risk involved with having hunting in areas where bear viewing is common.
Comments on the “trophy hunt” ban in the remainder of the province
While we understand that policies are made at the political level, we appreciated the opportunity, during our face-to-face meeting, to express our concerns about the problems of implementation and the likely unintended consequences of this policy. We reiterate them here.
- It was presented to us during consultation that he LEH hunt and guided hunt will be managed according to the existing LEH and allocation system and the current grizzly bear management policies. These policies have inherent weaknesses which have been identified by scientists and highlighted in the recent report of the Auditor General. Our concerns about repeated over-mortalities and population uncertainties, and insufficient monitoring are articulated well in that report, so we will not repeat them here. We have included attachments with the relevant papers and figures that illustrate these critical issues.
- We have serious concerns regarding the practical logistics around packing out “edible portions” of grizzly bears and the surrendering of trophy parts. During discussions of the possible mechanisms of verifying the surrender of trophy parts you stated:
- Three options have been identified: (i) take prohibited grizzly parts out of forest (ii) leave prohibited grizzly parts in forest, or (iii) take prohibited grizzly bear parts with scientific value out of the forest.
- We strongly believe that only the first of these is remotely capable of being monitored and enforced.
Otherwise, we can conceive of no practical means of verifying that the trophy parts were, in fact, left behind.
- In addition, if hunters are required to pack out hundreds of pounds of “edible portions” the additional burden of packing out the comparatively light trophy parts is negligible. Our overriding concern with this policy is that the ministry does not currently have adequate infrastructure in place, or the resources to put it in place, in order to deal with the monitoring or enforcement of this policy. Moreover, the physical plant to handle either the storage of the edible portions or the trophy parts is lacking.
Map: Comparison of grizzly range, areas every inventoried, and areas actively monitored. Based on provincial data from 2012 population estimates. Approximately 4% of hunted area is actively monitored.
Histogram: Year and frequency of population inventories across British Columbia. Based on Mowat et. al. 2013. On average inventories were 14 years old as of 2013.
Artelle et al 2013. Confronting uncertainty in wildlife management (PDF) . Peer reviewed article that describes the risks imbued by the current approach to management, and also offers quantitative approaches to set targets that mitigate those risks.
Artelle et al 2014. When Science-Based Management Isn’t (PDF) . Letter published in Science describing how increases in hunt targets in 2014 ran contrary to peer-reviewed evidence, raising doubts about their scientific bases.
Artelle et al 2016. Ecology of conflict (PDF) . Peer reviewed article that examines patterns of grizzly-bear human conflict across British Columbia from 1960-2014. It found no detectable effect of conflict kills or hunting kills on subsequent conflict rates, but did find a strong association with yearly natural food availability, with conflict increasing in years of low salmon returns.