1 December 12, 2002 Larry Koller Box 3B, Comp 12 Tulameen, BC V0X 2L0 Phone or Fax (250) 2956502 To: Honourable Joyce Murray Minister of Water, Land and Air Protection Room 124 Parliament Buildings Victoria, BC V8V 1X4 VIA FACSIMILE 604 775-2121 Dear Madam, On July 9, 2002 you appointed me to the North Cascades Grizzly Bear Taskforce. You have asked me to make recommendations, with supporting rationale, on the completion and implementation of a Grizzly Bear recovery Plan based on a review of: (1) the draft Grizzly Bear Recovery Plan for the North Cascades of British Columbia(January 19, 2001) (Draft recovery plan) (2) the Input received during the Public Consultation Period (Public Input), (3) the Proposed responses to this input from the North Cascades Grizzly Bear Recovery Team (Team Responses), and, (4) Any additional technical/scientific input. In addition to this, for the first eight meetings we had the privilege of a resource person from the recovery team to guide us through the above. You have to appreciate that the taskforce represents a wide range of stakeholder interests. Even with a two-month extension, aside from general agreement that there should be a conservation strategy for the grizzly bear your expectation of a consensus on recommendations for completion and implementation of the recovery plan is overly optimistic. Now, because of the timeframe for submitting (Dec. 15) and finding that we have exceeded our budget, I am breaking away from trying to reach consensus recommendations; keeping to the Terms of Reference re: Decision-making. I was nominated by Dave Chutter MLA (Yale-Lillooet) to represent local residents on the North Cascades Grizzly Bear Taskforce. Local residents are opposed to the draft Grizzly Bear Recovery Plan for the North Cascades of British Columbia (January 19, 2001) (#153 of Public Input). This position was re- enforced at meetings in Tulameen and in conversations with constituents throughout the Taskforce process. The idea of augmentation, even an augmentation trial is unanimously opposed. For clarity, augmentation in this 2 document refers to the artificial increase of the grizzly bear population in the North Cascades through the translocation and/or introduction of grizzly bears from another remote population. It is the reason for the Draft recovery plan. Recommendation1: The existing grizzly bears of the North Cascades need more research. Inventory techniques should be designed and implemented to determine the absolute abundance of grizzly bears and to monitor population trends. Rationale: If we find out the facts to eliminate speculation there will be less chance for mistakes. There is uncertainty in the material the taskforce had to review: “The scientific knowledge of the North Cascades grizzly bears is quite incomplete,” page 24 of the Draft recovery plan “It is not known whether grizzly bears currently move between the north Cascades and the Stein/Nahatlatch “(#7, Team Responses) “Grizzly bear home range in the North Cascades is not known.” (#9, Team Responses). There are also inconsistencies throughout the material the taskforce had to review with regards to numbers: “with augmentation by 2005 there will be a minimum of 30 grizzly bears” (Page 9, Draft recovery plan), 17 grizzly bears in the taskforce presentation of Aug. 8, 02, (enclosed), 25 bears (executive summary of the Draft recovery plan) and 30 to 35 grizzly bears (#4 Team responses). If 17 grizzly bears have a “threatened” status one has to wonder whether twice that many should have the same status. I emphasize this because it became clear through the Taskforce meetings that this status, without scientific justification, is a contributing factor restricting investment in the resource rich North Cascades and its local communities. Recommendation #2: Continue the current efforts to conserve the existing grizzly bear population in the North Cascades. These efforts include anti- poaching laws, conservative hunting regulations, and education of the Public. Rationale: The grizzly bear population in the North Cascades is stable according to our resource person and #1 of the Team responses. The area has been closed to hunting as part of the cooperative Grizzly Bear management and recovery efforts which have been ongoing with the various State and Federal wildlife agencies in the USA for more than 30 years. Recommendation #3: Discard the draft Grizzly Bear Recovery Plan for the North Cascades of British Columbia (January 19, 2001) My rationale for saying this includes, but is not limited to, the following: 3 Rationale#1: “some common sense points need to be kept in mind… These include: the fact that grizzly bears continue to occupy 89% of their historic range in the province and this range has not changed noticeably in the last 30 years…human population density and the associated impacts” is a factor “explaining why grizzly bears are no longer found in some areas”1 Rationale#2: The Draft recovery plan supposes2 to a time when grizzly bears didn’t have to compete with the surging populations of the Twenty-first century. It wants to recover closer to the assumed2 historic highs of yesteryear through the introduction from other, remote grizzly bear populations, providing habitat, and managing bear/human conflicts. The Draft recovery plan says in its executive summary: “Avoiding grizzly bear/human conflicts will be critical to the success of the Recovery Plan.” The North Cascades is situated between the two largest population centers in the province (Okanagan and the lower mainland). It seems a poor location, given the fact there are more remote areas in the province with the same “threatened” status as the North Cascades, to try this Pilot Project. Peer comments are basis for skepticism of the viability of the Draft recovery plan; especially with respect to this large human population. 9 “opportunities (for recovery) are limited because of their use as livestock range, heavy use for back country recreation and their close proximity to settlement”3 9 “human caused mortalities of grizzly bears increase with higher levels of human settlement”4 Rationale #3: Translocations and/or introduction of grizzly bears to augment the population are the basis of the Draft recovery plan. This may have a negative impact on the existing population in the North Cascades (i.e.: mortalities, territory, and genetics). It will certainly influence the source population (where the introduced bear(s) came from) in the annual harvest or it’s conservation status. The Draft recovery plan, team responses and the resource person are all vague on which Grizzly Bear Population Unit (GBPU) to use as the source population. 1 Matt Austin in his letter of January 28, 2002 to Dave Fraser, Convention on International Trade in Endangered Species (CITES) Scientific Authority (BC) Endangered Species Specialist 2 Clare Hewson B.Sc. Forestry Registered Professional Forester 1973-2000 Re: North Cascades Grizzly Bear Recovery Program- Justification of Program Doubtful 3 Demarchi M.Sc. R.P. Bio., Halliday M.SC. R.P. Bio., and Munro M.Sc. R.P. Bio. Re: Grizzly Bear Harvest Management in BC 4 Dr B. N. McLellan, on behalf of BC’s Grizzly Bear Scientific Advisory Committee from Matt Austin’s letter of January 28, 2002 to Dave Fraser, Convention on International Trade in Endangered Species (CITES) Scientific Authority (BC) Endangered Species Specialist 4 Rationale #4: The US issue must be considered. Not enough research was done on the legal aspects with regard to the State of Washington (RCW 77.12.035) or the US Federal Government, which recently re-evaluated a decision [Federal Register: June 22, 2001 (Volume 66, Number 121)] to introduce grizzly bears into an area because of a lawsuit filed by the State of Idaho (DOCSSC1:280172.3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA CIVIL DIVISION). It would be prudent to err on the side of caution and diplomacy rather than to find ourselves in litigation because the BC Government has introduced grizzly bears into Washington State to accommodate a special interest group. Rationale #5: Peer reviews of the Draft recovery plan questions its credibility in certain areas. ” The attitude in the Draft plan that all uses that are going on now, and more that will yet come, can be “stuffed” into the existing landscape and still fit within “current management practices” is naïve…” 5 “Most translocations fail. I strongly urge you to develop a rigorous design for your project that considers all the pertinent variables prior to initiation”6 “The potential capability of the ”spine” to support 199 bears seems unrealistically high…” 7 “promoting negative silviculture practices…at the expense of the citizens of British Columbia”8 Different stakeholder groups (#107 of Public Input) also question the credibility of the draft recovery plan. Rationale #6: The prevailing comments of the Draft recovery plan are “human/ bear conflicts” and “access management”. The North Cascades of BC is a resource extraction area, which will be affected by restrictions on access. This will have an economic impact on stakeholders and, in turn, a social impact on the local populations. The Draft recovery plan does not adequately cover this. These same prevailing comments in the plan are going to impact recreation in the North Cascades. Rationale #7: There are far too many revisions in the responses by the North Cascades Grizzly Bear Recovery Team for the taskforce to distinguish from the Draft 5 Dr. Brian L Horejsi, May, 2001 Comments on the draft recovery plan 6 Rich Reading Ph.D. Conservation Biology Director, Denver Zoological Foundation. Letter to Matt Austin re: draft recovery plan 7 North Cascades Ecosystem Subcommittee-Grizzly Bear Technical Team Comments on the draft recovery plan May 16, 2001 8 Clare Hewson B.Sc. Forestry Registered Professional Forester 1973-2000 Re: Recovery Plan for Grizzly Bears in the North Cascades Lack of Knowledge of Habitat Effectiveness 5 recovery plan it was mandated to make recommendations on.