March 9, 2004

Mr. Bradley M. Campbell
Commissioner, Department of Environmental Protection
401 E. State Street
P.O. Box 402
Trenton, N.J. 08625-0402

Transmitted by facsimile: 609-292-7695

Dear Commissioner Campbell:

On behalf of the 250,000 members and constituents of The Humane Society of the United States in New Jersey, I would like to express our appreciation for your recent letter to the New Jersey Fish and Game Council in which you recommended the omission of a bear hunt from the game code for 2004–2005.

We understand that this is a difficult and controversial issue and that you have devoted considerable attention to determining the biological and ethical impacts of a bear hunt. Though we continue to disagree with your contention that a sport hunt of New Jersey's bears was justified last year, we fully support your assertion that more progress is required in the further development of non-lethal management strategies. In particular, as you point out in your letter, efforts in the areas of public education, enforcement of the bear feeding ban, and development of other non-lethal strategies (such as further development of techniques to aversively condition "nuisance" bears, as well as research on immunocontraception) deserve considerable focus at this time.

Your letter also references recent data on the size of the bear population suggesting that this bear population may not be rapidly expanding as was previously supposed. We have had serious concerns over the state's bear population data and analyses for some time; many of these same concerns were voiced by members of the Independent Bear Panel. The extraordinarily high percentage of females in the bear kill in 2003 only heightened our concerns. We are pleased to see your appropriately cautious interpretation of the revised bear population estimate.

Regardless of the true size of the bear population in New Jersey, there is little reason to believe that a sport hunt would contribute to a reduction in human-bear conflicts. Development continues to encroach on remaining black bear habitat in New Jersey, and new residents often have little knowledge regarding the common-sense means of avoiding problems with bears. There is also little reason to believe that sport hunters in particular could somehow accurately target nuisance bears. Animal protection and conservation groups are not alone in criticizing the use of hunting in reducing human-wildlife conflicts. Biologists have also criticized the effectiveness of hunting to reduce damage: "Harvests intended to reduce crop and livestock losses have limited effectiveness…. Private hunters and government culling agents often do not selectively target the individuals that cause economic losses…. Hunters can even increase the risk of conflict if they wound rather than kill carnivores…. In short, hunting is unlikely to reduce human-carnivore conflict and might even increase it [emphasis added]."¹

On the other hand, there is strong evidence for the effectiveness of exactly the types of comprehensive management programs you emphasize in your letter. For example, public education to properly secure garbage and other attractants,² the use of electric fencing to protect crops and apiaries³, livestock guarding animals⁴, and motion-activated or other frightening devices⁵, can all be effective for preventing and reducing conflicts with bears. These common-sense tactics—in combination with aversive conditioning or selective removal of individual problem bears—should all be part of a comprehensive strategy for minimizing human-bear conflicts.

We thank you for your swift action on this matter, and look forward to working with you in the coming months on developing durable and humane solutions to the on-going challenge of managing interactions between people and native wild animals.

Sincerely,

Wayne Pacelle
Senior Vice President
Communications and Government Affairs

CC: Governor James McGreevey

1. Treves, A. and Karanth, K.U. 2003. Human-carnivore conflict and perspectives on carnivore management worldwide. Conservation Biology, 17(6): 1491–1499. And references cited therein.

2. Inglis, J.E. 1993. An analysis of human-black bear conflicts in Algonquin Provincial Park, Ontario (1973–1990). Proceedings of the 11th Eastern Black Bear Workshop, New Hampshire, USA.

3. Huygens, O.C. and Hayashi, H. 1999. Using electric fences to reduce Asiatic black bear depredation in Nagano prefecture, central Japan. Wildlife Society Bulletin, 27(4): 959–964.

4. Andelt, W.F. 2001. Effectiveness of livestock guarding animals for reducing predation on livestock. Endangered Species UPDATE, 18(4): 182–185. And references cited therein.

5. Shivik, J.A., Treves, A., and Callahan, P. 2003. Nonlethal techniques for managing predation: Primary and secondary repellents. Conservation Biology, 17(6): 1531–1537.