Your rulings in this matter…

Your rulings in this matter are very important, not only for bear survival but for the integrity of the ecosystem of which they are a part, particularly now with the effects of climate change. Ecologists sometimes refer to bears as “ecosystem architects” or “ecosystem engineers.”

Human-bear conflicts are known to increase in years of low natural food availability.” One of the guiding principles laid out in your document entitled “Black bear management framework” is that “Black bear movements and annual reproductive capacity are strongly influenced by annual forage abundance and distribution." I would like to argue that by hunting the black bear in some areas where their numbers have dwindled, that forage abundance will decline, and consequently human-bear conflicts rise rather than achieving your goal. Ensuring food abundance and distribution is key to minimizing bear movement into human occupied areas.

Returning to the concept that bears are ecosystem architects or engineers, bears are one of the most crucial ingredients in a healthy ecosystem. They disperse the seeds which grow into the plants they eat, such as berries, nuts, acorns and succulent vegetation. These plants are their staples, along with insects. Meat and other less succulent greens are eaten only when preferred vegetation is scarce. More importantly, as the paper points out “In years when major food crops fail, black bears wander more widely and can remain away from their spring ranges for 3 to 4 months.” This wandering could push encroachment into areas where people are apt to live and hence complaints increase, giving the illusion that there are more bears. Thus, it is important that there are enough bears to successfully maintain their ecosystem engineering capacity and thereby their food abundance.

If too many bears are lost, then more people will complain as they see more bears in their vicinity, but this inductive reasoning would be false, as there are fewer bears but they are roaming farther and closer to human habitation in search of food.

Another concern is that extrapolation of numbers based on habitat potential for each bear population may not be accurate. As this paper states, “It is difficult to estimate black bear population size and trends.” According to the International Union for Conservation of Nature (IUCN), six of the eight bear species globally are listed as vulnerable to extinction. A telling sign of the challenges faced by the black bear. The paper on “Black bear management framework” on your website also states that “The black bear’s inherently slow rate of recovery from low population levels increases the risks for local populations where harvest pressure and other mortality are high.”

Adding to the pressures on bear populations is the interplay of threats from habitat loss from deforestation or mining; of climate change; vehicle and train collisions are a few of the adverse impacts of human behaviour adding to the constraints on black bear populations.

The spring bear hunt was only supposed to last for seven years, when reintroduced. For the above reasons, as well as those of others submitted to your registry, a ban on the hunting of black bears should be re-enacted under the province’s Fish and Wildlife Conservation Act.

Regards.