Letter: Protection of grizzly bears should be strengthened in the expansion of the Species at Risk Act

While we are encouraged by Environment and Climate Change Canada’s proposal to expand federal regulatory protection for a number of terrestrial species, such as wolverine, the focus of this submission is on the Government of Canada’s forthcoming decision whether to legally list the western population of grizzly bear as a species of “special concern”.

On January 18th, Faisal Moola, Wildlife Policy Associate for Raincoast Conservation Foundation and an Associate Professor of Conservation Leadership and Policy at the University of Guelph, submitted a letter on our behalf to the Canadian Wildlife Service. The existing proposal to expand federal regulatory protection, via Schedule 1 of the Species at Risk Act (SARA), for a number of terrestrial species, such as wolverine, is good. However, we are concerned that the forthcoming decision of whether to list grizzly bears as a species of “special concern” is not a strong enough protection. Given the historical decline in population and the threat of extirpation, grizzly bears require additional protection under SARA.

To: Canadian Wildlife Service
Environment and Climate Change Canada 15th Floor, Place Vincent Massey
351 St. Joseph Boulevard
Gatineau, QC
K1A 0H3

Submitted by email to:

RE: Order Amending Schedule 1 to the Species at Risk Act

January 18, 2018

To Whom It May Concern:

The Raincoast Conservation Foundation supports the proposal to list 13 new terrestrial species to Schedule 1 of the Species at Risk (SARA). While, we are encouraged by Environment and Climate Change Canada’s proposal to expand federal regulatory protection for a number of terrestrial species, such as wolverine, the focus of this submission is on the Government of Canada’s forthcoming decision whether to legally list the western population of grizzly bear as a species of “special concern”.

The Raincoast Conservation Foundation supports adding the western population of grizzly bears to Schedule 1 of the SARA. However, we remain concerned that the proposed special concern listing will not provide a strong enough regulatory mandate for the protection and recovery of a number of sub-populations of grizzly bears, in Alberta and south-central British Columbia, that are in precipitous decline and could face extirpation without immediate action to address threats to their survival.

Raincoast has been working to protect grizzly bears and other large carnivores since our inception in 1996. We are a team of conservationists and scientists empowered by our research to protect the lands, waters and wildlife of British Columbia. We use rigorous, peer-reviewed science and community engagement to further our conservation objectives.

The conservation of grizzly bears has featured prominently in our work for close to three decades and our peer-reviewed and published science has helped to inform policy outcomes that have directly benefitted the species. For example, our analysis of human-caused mortality of grizzly bears in British Columbia (Artelle et al. 201311) featured prominently in a recent performance audit by the BC Auditor General’s Office of provincial grizzly bear policy. This research showed that grizzly bears have been killed at rates that exceed government mortality targets across the province, largely due to uncertainty in population estimates and the failure of government policy to adequately account for uncertainty in non-hunting mortality (such as road and rail accidents, animal control kills, poaching). Raincoast has also published research on the habitat needs of the species, including ensuring long-term food security associated with the availability of salmon prey (Adams et al 20172). Over the last few years, our organization has also worked closely with local First Nations to acquire and extinguish non-resident trophy hunting quotas within guide-outfitting territories that we have purchased in BC’s Great Bear Rainforest.

The importance of grizzly bears

Grizzly bears are a vital species to the ecological, cultural and economic health of Canada. They are an important focal species and play critical functional roles in the ecosystems that they are part of. For example, grizzlies aid in plant reproduction and dispersal by transporting the seeds of the plants that they consume. They are also an important vector for the transfer of nutrients from marine to terrestrial ecosystems by transporting the salmon they consume far inland from the streams where they were caught, fertilizing the forest. Incomplete consumption of salmon carcasses also provides food for scavenging species. While grizzlies have a diverse diet and feed on a plethora of plants, insects, mammals, salmon and intertidal invertebrates, as an apex predator they interact with and help to regulate prey species, such as moose, caribou, elk, muskoxen, mule deer, mountain goats and other wildlife.

Grizzlies also feature prominently in the culture of many Indigenous Nations and are central to story, ceremony, art and spirituality, as well as the intergenerational sharing of traditional knowledge. A number of First Nations in BC receive considerable direct economic benefits through the non-consumptive use of grizzly bears, such as with cultural and eco-tourism. A 2003 study by Raincoast and the Centre for Integral Economics (Parker and Gorter 2003)3 calculated revenue generated by grizzly viewing ecotourism at over $6.1 million a year in British Columbia. A more recent study by the Center for Responsible Travel (CREST)4, found that bear- viewing in the Great Bear Rainforest generated more than eleven times more direct revenue for the BC government, and more than twelve times as many full-time equivalent jobs as grizzly bear hunting.

Finally, grizzly bears also enjoy widespread interest and sympathy among the public, as revealed in several recently published public opinion polls and the results of public consultations pertaining to the reform of grizzly bear policy in B.C.5

The need to list grizzly bears under the SARA

A century and a half ago, grizzly bears roamed as far south as Mexico and as far east as the Manitoba-Ontario boarder. Today, the species has lost an estimated 50% of its former range and abundance since the mid-1800s, and it has been eliminated from 98% of its historical range in the United States and Mexico. In Canada, the grizzly bear historically occupied nearly all of western Canada and central regions of the country as well. Today, it’s range has shrunken considerably and the species now only occupies a quarter of Canada’s land mass. While, there are some parts of country, largely in the vast northern regions of B.C. and the Great Bear Rainforest, where grizzly bear populations are thought to be stable, in western Alberta and southern B.C., the species occurs in small, isolated and threatened subpopulations that are at considerable risk of extirpation. This includes nine groups (known as Grizzly Bear Sub-Populations or GBPUs) in south-central British Columbia and Alberta’s entire grizzly bear population, which remains vulnerable despite a recent hunting ban in that province.

A 2016 assessment by the IUCN’s Bear Specialist Group has drawn particular attention to how dire the situation is with regards to the imminent extirpation of a number of these sub- populations. The IUCN’s Bear Specialist Group has concluded that three Canadian sub- populations are critically-endangered (Stein-Nahatlatch, North Cascades, Fountain Valley-Hat Creek), one is endangered (Yahk-Yaak) and one is vulnerable (South Selkirks) due to geographic isolation, low numbers and the ongoing loss and fragmentation of core grizzly bear habitat with industrial, agricultural and urban expansion and development.

Table 1

Grizzly Bear PopulationIUCN Red List StatusBC StatusPopulation Estimate
Stein-NahatlatchCritically EndangeredThreatened15 – 25 (IUCN 2016)
North CascadesCritically EndangeredThreatened<10 (IUCN 2016)
Fountain Valley-Hat CreekCritically EndangeredTBD<10 (IUCN 2016)
Yahk-YaakEndangeredThreatened48 (IUCN 2016)
South SelkirksVulnerableThreatened93 (IUCN 2016)
Squamish-LillooetN/AThreatened59 (BC 2016)
South Chilcotin RangesN/AThreatened203 (BC 2012)
Garibaldi-PittN/AThreatened< 5 (IUCN 2016)
Kettle-GranbyN/AThreatened86 (BC 2012)
Blackwater-West ChilcotinN/AThreatened53 (BC 2012)

Table 1. Conservation status of threatened grizzly bear populations in British Columbia. Reprinted from submission by Bruce Passmore, CPAWS-BC to Canadian Wildlife Service, dated January 10th 2018.

None of these sub-populations receive any effective regulatory protection under provincial or federal law currently. Nor will legal listing of the species, as special concern, under SARA provide the necessary protections needed to prevent extirpation (namely habitat protection and reducing human-caused mortality by managing road density6), unless the Government of Canada is willing to recognize their dire population condition and focus its attention on recovery. Indeed, given the urgency of the situation for a sub-set of populations of grizzly bears in Alberta and south-central British Columbia, we urge the Government of Canada to work with the Provinces to ensure that recovery of these sub-populations is a priority in the species’ Management Plan, as mandated under the Act.

This includes addressing all of the adverse human impacts which threaten the species.


  1. habitat loss and fragmentation due to agricultural, residential and industrial development, climate change and roads;
  2. reduction in habitat effectiveness due to proximity to humans;
  3. persistent organic pollutants (POPs) that accumulate in the bodies of apex predators like the grizzly;
  4. direct human-caused morality including poaching, animal control kills and vehicle collisions.7

Despite being a large and powerful animal, grizzlies are especially vulnerable to human impacts. Their low reproductive and dispersal rates make populations of grizzly bears very sensitive to population declines and thus immediate action is needed, once the species has been added to the SARA, to prevent ongoing population declines and imminent extirpation in some portions of its current range.

Yours truly,
Dr. Faisal Moola, PhD

Associate Professor
Department of Geography
University of Guelph

Wildlife Policy Associate
Raincoast Conservation Foundation

  1. Artelle et al. 2013. Confronting uncertainty in wildlife management: performance of grizzly bear management. PLOS One. 8 (11).
  2. 2 Adams et al. 2017. Intrapopulation diversity in isotopic niche over landscapes: Spatial patterns inform conservation of bear–salmon systems. Ecosphere. 8 (6)
  3. Parker and R. Gorter, 2003. Crossroads: Economics, Policy, and the Future of Grizzly Bears in British Columbia. Victoria: Centre for Integral Economics and Raincoast Conservation Society.
  4. Center for Responsible Travel (CREST), Economic Impact of Bear Viewing and Bear Hunting in The Great Bear Rainforest of British Columbia. Washington, DC: Center for Responsible Travel (CREST).
  5. https://cdn.shopify.com/s/files/1/1768/2515/files/McAllister_Opinion_Research_Final_Results. pdf?9213636316651088832
  6.  Lamb et al. 2018. Effects of habitat quality and access management on the density of a recovering grizzly bear population. Journal of Applied Ecology. 1-12.
  7. Truesdale et al. 2014. Request for an audit and examination of the failure of the B.C. Ministry of Environment to carry out its duty to sustainably manage human-caused mortality of grizzly bears. Submission to the Auditor General of British Columbia. Prepared by the Environmental Law Clinic, University of Victoria.

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