Black Bear Conservation Plan

On behalf of the California Chapter of Backcountry Hunters & Anglers (BHA) we applaud the Department of Fish & Wildlife (CDFW) for their expedited efforts to update the Black Bear Conservation Plan and appreciate the opportunity to provide comment on behalf of our many thousand members and supporters in California.

Backcountry Hunters & Anglers is a North American non-profit organization whose mission is to ensure North America’s heritage of hunting and in a natural setting, through education and work on behalf of wild public lands, waters and wildlife. BHA works to preserve for future generations the peace, quiet, and sense of freedom that make hunting and fishing unique outdoor activities that may be lost to the pressures of human population, industry, and technology. BHA believes in keeping public lands and waters healthy and accessible, in managing wildlife as a public trust, and in protecting the large natural areas and natural functions that support our hunting and fishing heritage.

We commend CDFW for its comprehensive and science-based approach to black bear management and conservation. BHA strongly supports the plan's emphasis on using robust scientific data to inform management decisions, recognizing the critical role that regulated hunting plays in maintaining healthy bear populations and ecosystems.

Support for Science-Based Decision Making

BHA applauds CDFW's adoption of an integrated population model, which utilizes data from approximately 3,000 camera trap surveys and hunter-collected age data from tooth samples. See, e.g., Chapter 4, lines 1022-1159. This innovative approach represents a substantial improvement over previous methods, providing a more accurate and reliable assessment of black bear populations across the state. By grounding management strategies in this robust scientific data, CDFW ensures that conservation efforts are both effective and adaptive to changing conditions. The data collected indicates that California's black bear population is abundant and continuing to expand into suitable habitat. This trend underscores the importance of maintaining a sustainable, healthy bear population through science-based management that should include ensuring not just an abundant bear population but a healthy bear population that is genetically diverse and capable of withstanding environmental change.

Integral to a healthy black bear population is an acknowledgement of predator-prey dynamics and the interspecific interactions of apex predators. As indicated in the plan, black bears have been documented to have an outsized impact on neonate mule deer born west of the Sierra crest where high levels of black bear predation is thought to limit deer abundance by limiting the proportion of deer that migrate to their summer range. Chapter 3, lines 663-673. The plan also acknowledges that blacktail deer populations in Mendocino are also declining likely due to kleptoparisitism and interspecific interactions between black bears and mountain lions. Id., lines 679-688. We encourage CDFW to further evaluate the regional impacts of over-abundant predator populations on ungulates, including recommendations for increasing hunter harvest of black bears in areas with an imbalance in trophic levels.

The Critical Role of Hunting in Conservation

The plan appropriately acknowledges the vital contributions of hunters to wildlife management and conservation. Chapter 1, lines 154-165. Hunting is not only a cherished tradition but also a crucial tool for maintaining balanced ecosystems. Revenues generated from hunting licenses and the Pittman–Robertson Act have historically funded a wide array of conservation activities that benefit both game and non-game species. Further, hunters play an essential role in providing scientific data through the collection of biological samples, which are critical for monitoring and managing bear populations. Id. We appreciate CDFW’s commitment to working with hunting- focused NGOs on habitat creation and protection that benefit a wide variety of species, including black bears. Id. BHA and other hunting organizations also support addressing diversity, equity, and justice issues, but we emphasize that these issues are often harmonized with hunting rather than opposed to it, and that organizations like BHA seek to provide an inclusive space for all to experience the wonders of our natural heritage. Id., 166-177.

Hunting also serves as a critical management tool to control game populations, preventing overpopulation and mitigating potential human-wildlife conflicts. Chapter 3, lines 773-797. By regulating the number of bears through controlled hunting, we can help ensure that bear populations remain at sustainable levels, which benefits both the species and the broader ecosystem. The plan cites substantial public opposition to increasing black bear harvest but does not include a credible source for polling information by referencing petition 2021-027, which was a thinly veiled attempt to ban hunting with clearly misapplied science. See, e.g., Chapter 3, lines 787-797. We recommend that CDFW remove this reference from the management plan and instead provide historical context for hunting of bears including the cultural significance and myriad uses of bear meat, fat, hides and claws which continue to this day.

Increasing Hunting Opportunities

BHA supports the plan’s goals and advocates for continued discussion on increasing hunting opportunities for black bear. Chapter 6, lines 1392-1404. Expanding hunting opportunities can provide additional data for population monitoring, help manage our state’s abundant bear population, deter human-bear conflict, mitigate impacts to ungulate species and generate more funding for conservation efforts. We encourage CDFW to explore options for increasing black bear hunting opportunities while ensuring healthy and sustainable bear populations. Given the significant bear population in the state, we look forward to working with CDFW on discussions related to changes in tags, season structure, and methods of take to reflect current population data and management objectives.

Key Conservation Goals

BHA supports the plan’s goals to:

1. Conserve Abundant and Genetically Diverse Black Bear Populations: Ensuring that black bears remain plentiful and genetically robust through careful monitoring and adaptive management practices.
2. Conserve and Enhance Bear Habitats: Prioritizing habitat conservation and enhancement to support healthy bear populations.

3. Promote Human-Wildlife Coexistence: Reducing conflicts between humans and bears through public education, effective management of human attractants, and hunting.

Addressing Human-Bear Conflicts

We appreciate the plan’s balanced approach to managing human-bear conflicts. While non-lethal conflict mitigation strategies are important, it is also crucial to recognize the role that regulated hunting can play in reducing human-bear conflicts. Chapter 3, lines 768-792. By managing bear populations through controlled hunting, we can help reduce the frequency of conflicts and ensure that bear populations remain at sustainable levels. This pragmatic approach, which includes both non-lethal and lethal measures, is essential for effective conflict management.

Movement Ecology and Connectivity

BHA is encouraged to see continued investments in GPS collars for bears to better understand their spatial ecology and vulnerability to hazards such as roads. See, e.g., Chapter 4, lines 1161- 1167. We support continued collaboration between CDFW, state and federal agencies and NGOs to conserve and connect habitat, invest in projects that promote connectivity and ensure dispersal routes for long-term population health and genetic diversity.

Conclusion

BHA strongly supports the draft California Black Bear Conservation Plan’s commitment to science-based decision-making. We believe that the plan's comprehensive and data-driven approach will ensure the long-term conservation of black bears in California, while also maintaining and potentially increasing opportunities for hunting black bears.

We encourage CDFW to continue engaging with stakeholders and the public to refine and implement this plan. BHA looks forward to ongoing collaboration with CDFW to support the sustainable management of California’s black bear populations and to discuss potential increases in hunting opportunities that align with conservation goals and managing the significant bear population in the state.