June 5, 2001

Dear Mr. President: Re: Proposed management for brown bears in Bulgaria

It has come to the attention of the International Association for Bear Research and Management (IBA) that new regulations have been proposed for the hunting of predators in Bulgaria entitled “Regulation of Application of the Law of Hunting and Conservation of Game.”

The IBA is a professional organization committed to conservation and restoration of the world’s bears through science-based research, population and habitat management and education. Our membership of over 700 bear specialists from over 50 countries conduct research studies and conservation management on all 8 bear species that exist today. In addition, IBA maintains close association with the International Union for the Conservation of Nature/Species Survival Commission (IUCN/SSC) by appointing the chairperson(s) of the IUCN/SSC Bear Specialist Group. Our organization can speak with authority on issues concerning management and research needs of the world’s bear species.

Based on our expertise with bear management, we raise concerns about these proposed regulations. With our comments we hope to help improve the management and conservation of bears in Bulgaria.

In Article 77(1) regulations are proposed for the killing of “blood thirsty bears and bears which have lost fear of humans.” We recognize that such bears may represent a threat to humans and that regulations are necessary to allow their removal. However, we feel that this category of bear should be more clearly defined to avoid the overuse of this provision. We recommend that the regulations should provide for a) the prevention of the development of problem bears (i.e., limit access to garbage), b) the use of aversive conditioning to stop such behavior of individual bears, and c) develop a protocol that defines specific instances in which killing of individual bears would be allowed.

In Article 77(2) reference is made to hunting of bears when they exceed the desirable concentrations and killing of bears to save “genetic purity and phenotypic features of the local type.” We recognize that hunting can be an effective measure to control bear numbers. In such a case, we suggest that hunting be regulated according to a carefully and scientifically-based hunting management program with well-defined goals that are measurable and achievable. We strongly recommend that the references to genetic purity and local phenotype be removed from the proposed regulation because it is not feasible and does not have a scientific basis.

Article 90(4) states that hunters are obliged to exterminate predators. We question the biological and ethical basis for this statement. At least, these predator species should be named in the regulation, to avoid misinterpretation.

We hope you find these comments to be constructive and helpful in drafting the final regulations. If you would like further assistance from the IBA, we are willing and happy to provide it.

We wish you success with the conservation and management of the Bulgarian bear populations that are not only unique for your country but for Europe as well.

Sincerely,


Harry V. Reynolds
IBA President

1300 College Road, Fairbanks, AK 99701-1599, USA
(907) 459-7238, FAX (907) 451-9723
e-mail: harry_reynolds@fishgame.state.ak.us

cc:

Mr. Ivan Kostov
Prime Minister
Republic of Bulgaria

Mr. Eladio Fernandez-Galiano
Bern Convention Secretariat
Council of Europe

Mrs. Evdokia Maneva
Minister of Environment and Waters
Republic of Bulgaria

Mr. Ventzislav Varbano
Minister of Agriculture and Forestry
Republic of Bulgaria