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Yukon Submission

Dec 3, 2018



Submission to:


Yukon Fish and Wildlife Management Board

Whitehorse, Yukon

We compliment you on your draft Conservation Plan for Grizzly Bears especially the recommended implementation based on the precautionary principle within an adaptive management framework.

Our comments follow here:

Recommended Action Item 2.7 makes no reference to current park systems. It should be undertaken in the context of such.

Lines 432 and 433 could be read as “…permitting process (that) requires…measures that fully avoid…impacts on…grizzly bears and their habitat.” Read as such, this is a ZERO GROWTH policy.

Line 524 and elsewhere, where is “respectful” defined?

Line 531, as an International Hunting group with worldwide affiliates we would be able to assist in the Mandatory Hunter Education and Ethics Development Training

Lines 565-570, we can assist in developing Goal 7.

Recommended Action 4.3 and elsewhere are “Political Populations”. This dilemma affects this discussion.  See “Political populations of large carnivores”, Chris T. Darimont, Paul C. Paquet, Adrian Treves,  Kyle A. Artelle,  Guillaume Chapron.  2018

Recommended Actions 5.1 – 5.4 there is no discussion of increasing bear viewing opportunities.

Line 631 implies or assumes that current conservation efforts are ineffective, without reference.

Line 660, “evaluated” against what?

Goal 4, Implementation 4.1 Indicator point 2 “national and international”, UHF and SCI can help with this. I couldn’t find this point, so recommend putting in a page number.

Line 889 and elsewhere the term “relatively stable” is used. Nowhere is there reference to carrying capacity and populations which may be at or above carrying capacity. Could “Relatively stable” indicate maximum population size?

Line 1108 references 2005 “concerns” without commenting on whether those concerns were valid or not.

How will you respond within your adaptive management framework to the recent tragic incident involving Valerie Theoret and her infant daughter Adele Roesholt?






David Little


on behalf of the UNITED HUNTERS FUND




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