For the first time in decades the B.C. government is asking for feedback on grizzly bear stewardship. It’s time to get loud: demand meaningful public engagement and planning that puts grizzlies first.
Between July 12, 2023 and October 6, 2023 the B.C government is accepting feedback, in form of a survey, on their new Grizzly Bear Stewardship Framework, a 75-page document outlining how grizzly bears in British Columbia are to be managed. This is the first time there has been an update for grizzly conservation in almost 30 years. Please take some time to engage and respond to the survey.
Deadline October 6, 2023 at 4:00pm
As outlined in the draft, the purpose of the framework is to provide “structure and guidance for discussion and action to the people and governments in the Province of British Columbia to steward and co-exist with grizzly bears” (p. i).
Though the survey provides only limited options for comment, it is the most assured way to have your feedback included.
For additional ways to make your voice heard on this issue see our letter writing guide.
What to expect in the survey
- The survey consists of seven sections, with each section containing between 1 – 6 questions. There are 16 questions in total.
- Response options include YES/NO boxes, comment boxes, and 5-point agreement scales. Comment boxes do not have a character limit.
- Each section directs respondents towards a specific section of the framework, meaning that two tabs are required to respond to the survey – one tab for the survey, and a second tab for the Grizzly Bear Stewardship Framework. We find that using a desktop computer and keeping both tabs open makes responding to the survey easier.
The Province has estimated a twenty-minute completion period for the survey, but we feel that a two to three-hour minimum is required to read the entirety of the framework and adequately respond to the survey.
The Survey Step by Step: Talking Points to Consider and Areas of Concern
The draft framework was written in consultation with First Nations communities and is the outcome of an amalgamation of Indigenous and Western knowledge.
We encourage you to read the full draft of the framework.
Below you will find our notes on each portion of the survey. We encourage you to put your responses in your own words.
Question 1: Do you feel the Background section (2-7) provides enough detail for you to provide feedback on the rest of the framework?
Answer Options: Yes / No / Maybe
Our Answer: No
Comment box is provided.
- The framework could benefit from a list of terms providing definitions on key ideas such as “Stewardship” and “Coexistence.” The framework should also include citations throughout for proper transparency.
- On page 9 of the report (Section 4.2), The B.C government has provided a population estimate of 15,000 grizzly bears province-wide as of 2018. The document confirms that the population estimate is mostly based on expert opinion, models, or expert opinion and models. Although this approach to obtaining population estimates was hotly contested before the recreational hunt was banned, and was questioned again in the Auditor General’s 2017 report, the methods appear to remain unchanged. Since 2012, only 8 population units have been updated, meaning that most data is over a decade old. Data concentration has been focused on the southern region of the province, leaving most of the population in the remaining part of the province unaccounted for. Without a precise, updated population count and inventory of remaining grizzly bears, management plans are not scientifically informed, and therefore cannot be sustainable.
- As per SPCA, “Publicly available data should be published annually on the number of bear conflicts, bears killed, and human injuries and deaths.”
Question 2: Section 6 lists ten primary threats facing grizzly bear stewardship. In your opinion, are there any threats missing from this list?
- Residential and commercial development
- Energy production & mining
- Road and rail corridors, including population connectivity
- Resource use including forestry
- Human intrusion and disturbance
- Natural events such as wildfires
- Climate changes & severe weather
Answer Options: Yes / No / Unsure
We selected ‘Yes’.
Question 3: What do you feel is missing?
Comment box is provided when ‘Yes’ is selected as a response to Question 2.
- Missing Threat: Potential of a future licensed grizzly bear hunt.
- On page 22 of the report (Section 6, Threats), the report identifies human-caused mortality as a significant threat impacting grizzly bears. In the report, human-caused mortality includes licensed hunting, ceremonial hunting, bears killed in conflict with people, illegal kills, and bears killed in rail or road accidents. However, the report claims that human-wildlife conflict is the most significant threat faced by grizzly bears, and emphasizes the importance of reducing wildlife conflict through public education, or coexistence measures including the WildSafeBCProgram. Within this paragraph, the report states that “before licensed and regulated hunting of grizzly bears was closed across B.C. in 2017, it is possible that it was a threat to grizzly bears in some areas, but given the conservative rates of harvest, that risk was very low … and no declines were attributed to overharvest under regulated hunting” (p. 23), suggesting that licensed hunting might again be reinstated. Though human-caused mortality is mentioned in the introduction paragraph in Section 6, it is not assessed using the NatureServe elemental calculator, and no explanation is provided for why the impact of this threat is not considered alongside the other eleven identified threats.
- Gaps in Scientific Data:
Though hunting is presently allowed for social, ceremonial, and food purposes by Indigenous peoples, trophy hunting was banned in B.C in 2017. The report seems to strongly indicate that licensed hunting again might be considered and implemented at a regional and local level without provincial oversight or regulation.
As of 2018, Grizzly Bears are listed under the federal Species at Risk Act (SARA) as a species of Special Concern and 31 out of 55 grizzly bear population units are listed as moderate, high or extreme conservation concern. The last time a population of grizzly bears was added to SARA (the prairie population) was in 2003 when it had already been designated as locally extinct for over 10 years. SARA’s executive summary states “The settling of land and conversion to agriculture along with human intolerance and hunting were the main reasons for the grizzly bears’ demise on the Prairies.” There is no reason to repeat this history a second time for the western population grizzly bears.
A 2017 report by the Auditor General titled “An Independent Audit of Grizzly Bear Management” found that a harvest rate of 6% is a maximum sustainable quota but “only when there is good biological information about the population” (2017, p. 39). This rate, however, did not account for uncertainty in populations, unreported mortalities, and the sex and age of those unreported grizzly bears killed. In their earlier study, Mowat et al. (2013) admitted that models pre-2013 over-predicted the density of grizzly bear populations in some areas, indicating imprecise and uncertain population numbers. The consequences of overestimating the population were confirmed by Mowat and Lamb (2016) who noted that 12 population units surpassed allowable kill rates, with the South Rockies experiencing a 40% decline in numbers from 2006 to 2013. Incorrect population counts were responsible for an increase in grizzly bear mortality.
On page 54 (Section 9.9) of the report, the claim is made that the 2017 closure of licensed grizzly bear hunting was attributed to an “ethical or moral opposition” towards grizzly bear hunting, and that the decision was not founded on a conservation concern about the health of dwindling grizzly bear populations. This statement is further substantiated with a claim made on page 23 (Section 6, Threat 1) that argues that risk of population decline from hunting is low and with conservative rates of harvest “no declines were attributed to overharvest under regulated hunting” (p. 23), and that licensed hunting of grizzly bears does not contribute to a population decline.
While grizzly hunting might not have been singled out as the single biggest threat, it is indisputably one of them. Threats interact in unpredictable ways and they have to be considered on the landscape scale as interacting factors. Without a precise population count and inventory of remaining grizzly bears, the reintroduction of recreational hunting will be catastrophic to grizzly bears. Incorrect population counts can result in incorrect status designations for Grizzly Bear Population Units (GBPUs), leading to a potential increase in grizzly bear mortality. The decision to close the hunt was a conservation decision, and was firmly rooted in science.
- Missing Threat: Habitat Loss.
- Despite habitat loss severely and immediately harming grizzly bear populations, and identified in the 2017 Auditor General’s report titled “An Independent Audit of Grizzly Bear Management” as the greatest threat to grizzly bears, habitat loss is not listed as one of the eleven primary threats faced by grizzly bears. Rather, the draft framework claims on page 23 (Section 6, Threat 1) that mortality resulting from human development is a greater threat. By failing to identify habitat loss as a threat, habitat recovery and the preservation of adequate habitat to support self-sustaining grizzly bear populations is not emphasized. Any further habitat fragmentation can significantly impact grizzly bear populations, by limiting food availability, disrupting their movement, and increasing human conflicts. Any slight changes in habitat availability could lead the species to an ecological threshold, and trigger tipping points that lead to population decline or local extinction. Increasing habitat connectivity, minimizing remote access, and ensuring long-term food security are essential to grizzly bear survival and need to be included in this stewardship framework.
- Loss of Habitat Due to Logging:
On page 28 of the report (Section 6, Threat 5), the recommendations and threat assessment of the forestry industry are likely to harm bears in the long-term. Recommending the spacing of logging practices by using selective cutting and winter harvesting suggests that the approval of extractive industries will continue, and habitat loss and fragmentation will continue to be unaddressed. The claim that extractive industries can be immediately beneficial to grizzly bears, and that “habitat quantity can potentially be improved by logging” (p. 29), or function in a similar way to fire in a landscape by opening up a landscape to food sources including huckleberries, does not seem to justify the longer-term harm bears face from permanent linear features carved into the landscape. As well, the immediate, short-term benefits that a seral forest provides before tree canopies fill in does not take into consideration other vital aspects of bear habitat that are decimated by unsustainable forestry practices. Post-logging, food sources are available only until a tree canopy closes, and accelerated reforestation and a shortened seral period (when food availability is highest for bears) is shortened. The practice of herbicide spraying and mechanical spacing of new trees by the forest industry suppresses growth of food in newly opened areas. With a strong emphasis on food sources, potential impacts on bear habitat beyond just forage availability also need to be considered. Logging can alter denning sites, cover, travel corridors, and overall ecosystem structure. Grizzly bears often avoid logging roads in favour of secondary roads, which can be unpredictable and result in increased human-wildlife conflicts and grizzly bear mortality. Other mitigation factors to limit this threat to grizzly bear habitat, like reducing the allowable annual cut, are not mentioned. It is essential to consider a broader range of impacts on bear habitat and food sources aside from forage availability.
This threat does not adequately address the loss of quality of habitat necessary to support a healthy bear population. For example, habitat fragmentation can significantly impact grizzly bear populations by limiting food availability, disrupting their movement, and leading to changes in bear behavior that may affect their reproduction. Even slight changes in habitat availability could push the species toward an ecological threshold, triggering tipping points that result in population decline or local extinction. Identifying threats is insufficient if their severity is not adequately articulated, and if the cumulative impacts are not considered.
- Wildfires and Climate Change: listed as “negligible”
On page 31 of the report (Section 6, Threat 7), the framework claims that the threat from wildfires is negligible, and states that the “implications of this novel fire regime [intense wildfire exacerbated by anthropogenic-induced warming] on grizzly bears are uncertain but are likely beneficial” (p. 31). Comparing out-of-control novel fire regimes to small-scale fire disturbances or prescribed burning is an unfair comparison and mis-representation of the severity and unpredictability of these fires. This past wildfire season has resulted in the decimation of 1.5 million+ hectares of habitat. Despite the claim that natural “wildfires … improve grizzly bear habitat” (p. 31), there are no studies included to support this. Rating this threat as ‘negligible’ ignores the complex interactions between fire and interconnected ecosystems. Though small-scale fires or prescribed burning might promote the growth of understory like huckleberry in the short-term, wildfires destroy forests and rivers that function as essential spawning grounds for salmon, a primary food source for grizzlies. Some bears, including cubs, are also likely to perish in raging wildfires. Of a 75-page document, only three paragraphs are focused on the impacts of climate change on grizzly bear populations. The Framework claims that the threat from climate change and severe weather is negligible to low for individual GBPUs. On the contrary, climate change can have far-reaching consequences for grizzly bears, many of which are not fully understood. Climate change can alter primary food sources, including berries, sedges, and various prey species. The impact on salmon populations is already evident due to rising temperatures. With insufficient salmon, grizzlies will likely not be able to accumulate enough fat to survive months of hibernation and reproduce successfully. The Framework purports that grizzly bears can instead rely on berries, like grizzly bears in Alaska who have “reduced their consumption of salmon in favour of red elderberries” (p. 33). The report fails to consider that berry crops can be destroyed by drought and wildfires and that they do not have the nutritional requirements for self-sustaining populations of grizzlies.
- Missing Threat: Food Security
Protecting salmon and salmon habitat is essential for grizzly bear survival.
- Missing Threat: Legally culling grizzly bears due to regional predator management schemes
Missing Threat: Legal culling grizzly bears by the B.C. conservation service because of conflict with humans or by BC residents under the Right to Farm Act
Question 4: How effective do you think the current approach to managing grizzly bears and their habitat (outlined in Section 7) has been at ensuring their sustainability and conservation?
Answer Options: Extremely effective / Very effective / Somewhat effective / Not so effective / Not at all effective
Comment box: “Please list the top two reasons you chose that answer.”
Suggested talking points:
- Somewhat effective. Since the Government of British Columbia banned recreational hunting of grizzly bears 2017, grizzly bears have endured less human-caused mortality. However after grizzlies were listed as a Species of Concern in the Species at Risk Act in 2018 a management plan on both the species and its habitat was required to be filed 3 years after grizzly bears were listed. Now about 6 years has passed. If a plan with management objectives has already been drafted, why is the Ministry of Forests instead releasing a Stewardship report that has no real objectives and makes no commitments about grizzly bear management? Why should “Together for Wildlife” break up management decisions among local and regional advisory committees when it already has a provincial level Wildlife Advisory Council? Who will be held accountable going forward to recovering grizzly bear populations which are recognized as a species of concern both provincially and federally? The current centralization of the decision-making process at the Provincial level has ensured, for the past six years, that recreational hunting has been Provincially banned. Allowing for community or regional management and decision-making, in so long as special interest groups like pro-grizzly bear hunters and guide outfitter organizations have an influential spot at the table, the potential for reinstating grizzly bear hunting is likely, and true stewardship cannot exist. Ensuring that the current ban remains in place is critical for the well being of grizzly bear populations.
Somewhat effective. Shifting the underlying philosophy from wildlife management to wildlife stewardship can be improved. Wildlife in B.C. is currently managed using a North American Model of wildlife management, which was developed as a response to over-hunting. It is based on ‘harvest’ limits for species, in which human dominance is the overarching decision-making factor. Coexistence principles, which underly most First Nations and settler stewardship approaches place humans in relationship to rather than in dominance over. This framework does not define what it means by coexistence. The underlying philosophy is still about pushing extraction to its limits instead of putting biodiversity, ecosystem health and the intrinsic value of the non-human animals reliant on these systems first. How will the Ministry of Forests handle the conflict of interest managing both the forestry industry in B.C. and preventing habitat loss for grizzly bears?
Question 1: How would you rate each of the five goals on the Grizzly Bear Stewardship Framework (see Section 8 for more details)?
Answer Options: Rate each method: Strongly agree / Agree / Neither agree nor disagree / disagree / strongly disagree
Comment box is not provided. Note: you can skip questions that are unclear.
- Guide and advise on methods, research, data, approaches, and decision-support tools available to regional or local communities to increase the potential to realize locally desired outcomes for grizzly bears and their habitat: Disagree.
- Provide an ecosystem-based approach for the co-development of regional or local grizzly bear stewardship plans bases on western science and Indigenous knowledge. These plans will consider inter-species relationships and cumulative effects of industrial activities, other human activities, and natural processes on grizzly bear conservation: Disagree.
- Support reconciliation with Indigenous Peoples through collaboration and partnership directed towards co-governance and joint, collaborative or consent-based decision making on initiatives related to grizzly bear conservation, management of human activities, and ecosystem-based stewardship: Strongly Agree.
- Promote safe and respectful co-existence between grizzly bears and people: Strongly Agree.
Inform, educate, and be transparent and open about grizzly bear stewardship in British Columbia to the public, Indigenous governments and legislators: Strongly Agree.
Question 1: Rating the Priority of Approaches
Grizzly bears are one of most intensively managed wildlife species in B.C. Stewardship activities are required to reduce human-caused mortality (e.g., rail and road mortality), reduce conflicts with humans, and ensure community safety. Stewardship also ensures habitat protection and enhancement, as well as population recovery in certain areas. The following questions relate directly to the draft Grizzly Bear Stewardship Strategy. Please read before answering these questions.
Answer Options: Rate each method on a scale of Extremely high priority → Not a priority at all
- Approach 1: Tracking of human caused grizzly bear mortality: Extremely high priority
- Approach 2: Local planning: Low priority
- Approach 3: Inter-jurisdictional planning: Moderate priority
- Approach 4: Population inventory (point in time): Extremely high priority
- Approach 5: Trend monitoring (over time): Extremely high priority
- Approach 6: Habitat protection and restoration: Extremely high priority
- Approach 7: Species and population stewardship: High priority.
- Approach 8: Hunting: Extremely low priority
- Approach 9: Viewing: High priority.
Question 2: Are there any aspects of grizzly bear stewardship that are missing from the list of approaches above?
Answer Options: Yes / No / Unsure
Our Answer: ‘Yes’.
Question 3: Which aspects do you feel are missing?
Answer Options: Comment box.
Suggested talking points:
- Taking an “adaptive approach” is mentioned on page 40 of the framework. A past example of an “adaptive approach” occurred with the management of B.C wolves and caribou. An adaptive approach determined the number of wolves purportedly needed to be killed to sustain a determined healthy population of caribou. We’ve seen with the wolf cull that this approach has failed to identify the root cause of caribou decline, habitat loss, and that caribou populations continue to decline despite the Provincial predator reduction program in place. It’s unclear how this proposed adaptive approach for grizzly bears will manage self-sustaining grizzly bear populations without reinstating trophy hunting at a local and community level.
- Approach 3 references joint collaboration or consent-based decision making with First Nations, communities, and regional districts, which is necessary and important. However, it is also imperative to ensure continuous transparency and communication with other parties with a vested interest in grizzly bear stewardship including the public and ENGOs.
- The framework lacks clear definitions such as for “stewardship” making the “species and population stewardship” an unclear approach.
Question 4: Overall, do you agree that the Draft Framework does a good job of providing guidance to steward bears and their habitat at the territorial, regional, and local levels?
Answer Options: Strongly Agree / Agree / Neither agree nor disagree / disagree / strongly disagree
Comment box: “Please describe how these approaches could be improved to better support territorial, regional and local decision making.”
Our Answer: Disagree.
Suggested talking points:
- The implication of decentralizing decision-making regarding grizzly bear stewardship in a “no one fits all approach” means that there would no longer be a Provincial ban on trophy hunting of grizzly bears. Rather, decision-making surrounding grizzly bear recovery will be in the hands of communities at a local and regional level. This raises many questions around how to manage accountability to provincial and federal commitments to grizzlies: Grizzlies are listed as a species of special concern on the provincial blue list and federally in the Species at Risk Act. The framework does not explain how these committees would be set up, nor does it include a Terms of Reference defining what the committee is authorized to do.
- How will regional committees work alongside Indigenous led stewardship and how will this be coordinated across the province? Bears know no borders and the same bears will be affected differently in different regions.
- The Framework has NO stated goal to protect or conserve grizzly bears. This is a glaring omission because grizzly bears are federally listed as Special Concern and 65% of Grizzly Bear Population Units (GBPUs) are ranked moderate, high or extreme conservation concern. Three units are extirpated. Eight units that are rated high concern are also highly or totally isolated. Two units are moderately isolated units that are rated high concern are also highly or totally isolated. Two units are moderately isolated.
- The Framework has NO commitment to conservation actions such as creating connectivity corridors, reducing the allowable annual cut of logging, creating new parks, or a plan to reverse the decline of salmon. A number of scientific panels have said that BC must increase fully protected areas to 50% to maintain grizzly bears over the long term. Currently, most of the province has only 12-17% protected. The draft Framework does say that the government has promised to protect 30% of the province, but it does not put that in a Terms of Reference or policy framework.
- The Framework does not define central terms important to the interpretation of the document such as stewardship or coexistence.
Question 1: Please note your level of support for the performance indicators (Section 10).
Answer Options: Rate performance indicators on a scale of Strongly support → Strongly oppose
Our Answer: Oppose.
More mention of grizzly bear well being is needed. The only place grizzly bear well being appears is in Performance indicator #15.
This Framework points to the need to evaluate and implement grizzly bear conservation measures locally or regionally. There are currently no processes in place for doing this, so the first step is to create or identify local working groups to begin the conservation planning process. Once a group has been established or identified, there are several similar tasks that are required for each area. The following questions relate directly to the draft Grizzly Bear Stewardship Strategy. Please read before answering these questions.
Question 1: Please note your level of support for each of the 5 noted next steps for territorial, regional and local working groups (Section 11).
Answer Options: Rate performance indicators on a scale of Strongly support → Strongly oppose
Our Answer: We suggest skipping this section since the options and answers available are very unclear, and there is no option to oppose the suggested approach on the whole – fragmenting the stewardship of grizzly bears to regional groups could be very destructive to grizzly bear recovery.
- Assess whether the mapping of the distribution of the population is accurate or should the population boundaries be amended?
Our answer: n/a
- Discuss whether the 2019 Threat analysis is accurate. Examine the accuracy of the data that went into the evaluation of each threat. Were local measures considered appropriately? For example, were access closures considered in the road metrics? Were current on the ground measures such as habitat protection orders, population monitoring, or conflict reduction efforts considered in the review? Finally, revise the threat level based on the local evaluation of threats if needed.
Our answer: n/a
- Consider whether grizzly bear recovery is acceptable throughout the unit and if it is not how would management actions differ in the areas where recovery is not acceptable? Our answer: n/a
- Create a series of stewardship goals for the population and rank these goals for action. Our answer: n/a
- Consider updates to the Wildlife Act that will support grizzly bear stewardship.
Our answer: n/a
Question 2: Are there any priority next steps for territorial, regional and local working groups which you feel are missing?
Answer Options: Yes / No / Unsure
Our Answer: Yes
Question 3: Which priority next steps do you feel are missing?
Answer Options: Comment box is provided when ‘Yes’ is selected in Question 2.
Suggested Talking Points:
- The framework does not explain how these committees would be set up, nor does it include a Terms of Reference defining what the committee is authorized to do. The stewardship framework displays gaps in their scientific basis.
- The implication of decentralizing decision-making regarding grizzly bear stewardship in a “no one fits all approach” means that there would no longer be a Provincial ban on recreational hunting of grizzly bears. Rather, decision-making surrounding grizzly bear recovery will be in the hands of communities at a local and regional level. This raises many questions around how to manage accountability to provincial and federal commitments to grizzlies: Grizzlies are listed as a species of special concern on the provincial blue list and federally in the Species at Risk Act.
Question 4: How effective do you think the proposed Stewardship Framework will be at ensuring the sustainability and conservation of grizzly bears and their habitats?
Answer Options: Rate performance indicators on a scale of – Extremely effective / Very effective / Somewhat effective / Not so effective / Not at all effective
Our Answer: ‘Not so effective’.
Suggesting talking points:
Overall, the Grizzly Bear Stewardship Framework is vague, lacks key definitions, does not set clear objectives for grizzly bear recovery, and is missing information on the intended implementation of said stewardship such as legislation and governance. Some of these missing key definitions include: stewardship, coexistence, and ecosystem-based management. Suggesting that governance of grizzly bear stewardship is to be handed off to regional groups, raises many questions around how to manage accountability to provincial and federal commitments to grizzlies. The framework does not explain how these committees would be set up, nor does it include a Terms of Reference defining what the committee is authorized to do. The stewardship framework displays gaps in their scientific basis. References in the document do not reflect all the available research specifically excluding important contributions made by conservation organizations and independent scientists. While the Grizzly Bear Stewardship Framework references collaboration with First Nations and has replaced use of the word management with stewardship, the document is clearly largely informed by the North American Model of wildlife management which is based on ‘harvest’ limits for species, and in which human dominance is the overarching decision-making factor. Coexistence principles, which underlie most First Nations and settler stewardship approaches place humans in relationship to – rather than in dominance over – other species. Discussion of animal welfare is notably absent from this document. The indication that the reinstatement of licensed hunting is on the table is appalling. This ban was sought for over a decade and represented the will of the majority of British Columbians (74%), including the majority of hunters surveyed (58%). Since the ban was put in place, the western population of grizzly bears has been officially listed under the Species at Risk Act (SARA) as a species of Special Concern. There is now a legal obligation to protect these animals and ensure that they do not become endangered, yet the new draft framework suggests a shift to regionally managing grizzly bears. Nothing has changed, save for an increased need to ensure a ban on hunting grizzly bears with the loss of 1.5 million+ hectares of habitat in British Columbia due to wildfires exacerbated by climate change.The idea of B.C. bringing back the grizzly hunt at a time of such uncertainty and dropping grizzly populations outside of B.C. is appalling.
Respond accordingly. This section is optional.