The Action Plan for Conservation of the Brown Bear in Romania

In attention of: Mrs. Gratiela-Leocadia Gavrilescu, vice prime minister, Minister of Environment

To: Government of Romania, Ministry of Environment


RE: The Action Plan for Conservation of the Brown Bear in Romania to determine the Level of Intervention for brown bears in the Interest of Health and Safety of the Population and in Order to Prevent Serious Damage 

26th April 2018


Dear Mrs. Gavrilescu,

Agent Green and Humane Society International / Europe welcome the Ministry of Environment’s initiative to ensure public safety, guard against damage to livestock and agriculture, and to protect Romanian brown bears in their natural habitat. We take this opportunity to comment on and support certain elements of the Action Plan drafted by the National Institute for Research and Development in Forestry, as well as to express our concerns and recommendations regarding the resumption of bear trophy hunting and the implementation of hunting quotas.

The brown bear,Ursus arctos, is one of the most iconic endangered species that the European Union is struggling to protect. As this Action Plan for Conservation of the Brown Bear in Romania asserts, the brown bear’s survival is threatened by habitat degradation and fragmentation, low social acceptance among citizens and interest groups, and poaching. To ensure the species’ conservation, Ursus arctosis legally protected at the international and European level, including through the Bern Convention and the EU Biodiversity Strategy.

The EU Habitats Directive imposes the obligation on the Member States to create national action plans which would ensure, based on the latest and accurate information, management and maintenance of a favorable conservation status for brown bears for the longer-term.

 Stakeholders access to evidence showing the alleged increase in damage and conflicts caused by bears.

Action 1.5 of the Plan for Conservation of the Brown Bear in Romania, entitled “Hunting as a management measure of the brown bearinRomania”, states that“the population is increasing as well as the level of damages and conflicts”. We would like to know whether the Ministry has kept a record of the conflicts and damages that have allegedly occurred in previous years. In the event that the Ministry is in possession of such a record, we would like to know if it would be possible for stakeholders involved in the resolution of human-bear conflict and species conservation in Romania to be granted access to these records.

As of now, our organizations do not have access to the information that the Ministry may possess, and we would find this information helpful to qualify and quantify these conflicts and damages, as well as to analyze the supposedly increase of conflicts.

There are serious threats to the survival of Ursus arctos(habitat destruction, human persecution, climate change, etc.), which warrant extreme precaution and a conservative hunting quota. 

The Action plan proposes a hunting quota of around 10% of the population which is estimated by the authorities to be in the range of 6050-6640 bears. Such a quota would allow the harvest or capture of more than 600 brown bears each year.

However, we strongly urge the Ministry that any consideration of lethal population control, or the use of other methods that may detrimentally impact bear survival, be treated with utmost precaution given the variety of threats faced by brown bears. Brown bears must have secure habitats and avoid human persecution (Weaver et al. 1996, Estes et al. 2011, Ripple et al. 2014, Darimont et al. 2015). A brown bear needs large habitat devoid of human conflict in order to search for food, mates, cover and den sites. An ideal brown bear habitat must have adequate food distribution and abundance in order for bears to thrive. Furthermore, another critical threat to bears is the incursion of motorized activity in their habitats (Craighead 2002). The extent to which the proposed maximum quota considers these types of compounding threats is unclear and further study is required to determine what is sustainable.

Furthermore, many bear researchers have concluded that climate change will have detrimental effects on bears by further altering the availability of food sources in their habitat. Their conclusions demonstrate that the Romanian government must treat climate change impacts on brown bears with the utmost gravity. For example, Bojarska and Selva (2012) conducted a seminal worldwide review of bear food selection relative to their geography (latitude, longitude, altitude) and a multitude of environmental variables such as snow depth and duration. They found that “temperature and snow conditions” constituted some of the “most important factors affecting the feeding ecology of the brown bear.” (Bojarska & Selva 2012). They found that it may be expected that climate change will greatly affect brown bear food habits through changes in food availability, hibernation patterns, nutritional and energetic demands, and foraging behavior. Globally increasing temperatures are yielding shorter winters with less snow, especially in northern latitudes and higher elevation areas (Sagarin & Micheli 2001, Wilmers & Post 2006). Early snow melt substantially reduces the amount of late-winter and early-spring carrion, which is vital for bears after hibernation and until other food resources become available (Wilmers & Post 2006). Climate change may affect brown bear feeding habits also through changes in plant distribution and phenology. As a response to warmer temperatures, Rodríguez et al. (2007) documented a long-term decrease in the contribution of boreal and temperate food items in brown bear diet during the hyperphagic season, when brown bears typically consume high amounts of fruit to accumulate fat for winter dormancy and for successful reproduction. Changes in the timing and intensity of fruiting and ripening of fruit and mast and declines in the availability of high-quality fruits may have important consequences for brown bear population dynamics (Rodríguez et al. 2007). If key brown bear food resources disappear without the corresponding change in the timing of alternative food resources, a serious food bottleneck could develop.  (Bojarska and Silva 2012 pp. 133-4). The best available science is clear: climate change has and will continue to threaten brown bears by detrimentally altering their habitat.

We are concerned that the proposed 10% maximum quota far exceeds sustainable levels, given these additional compounding threats and in the absence of accurate population data (see discussion below).

The population estimates on which the proposed hunting quota for brown bear are based, are biased and biologically implausible.

Under the Action Plan for Conservation of the Brown Bear in Romania, hunting of a vast number of bears each year is proposed despite the absence of knowledge about the exact size of the population, or other important population parameters such as death and birth rates of the bear population in Romania. Natural population growth is a variable and conditioned by several factors, which are hard to predict and to calculate (habitat’s quality, meteorological conditions, existence of diseases, of the poaching, etc.). A hunting quota that exceeds the natural growth rate of the population would seriously risk irreversible decline of brown bears in Romania and represents a direct threat to the survival of the species.

A recent study by Popescu et al. (2016) evaluated the “biological plausibility” of reported brown bear population estimates used in setting harvest targets in Romania. By comparing growth rates of well-studied populations elsewhere in Europe to those claimed by wildlife managers in Romania, the researchers found that 22 of 26 counties (84.6%) in Romania that reported brown bear populations had “unrealistically high population growth rates” in at least one year between 2005 and 2012. The frequency of over-estimations over the seven-year period varied among counties (Figure 1).

Figure 1.From Popescu et al. 2016. Number of years that estimated growth rates exceeded maximum growth rates of other European populations.

Furthermore, Popescu et al. (2016) found that the estimated population trajectories based on these unrealistic growth rates caused an overestimation of the size of bear populations in 32% of cases (Figure 2). Also, for bears, the researchers found a positive correlation between the size of the population over-estimate and the number of bears hunted (in other words, the larger the overestimate, the more bears were hunted). The authors concluded that Romania’s “management systems have lacked biological realism” and called on the need for “reassessing credibility of management systems that are subject both to data limitations and incentives for biased approaches to management.”

Figure 2.From Popescu et al. 2016. Number of years, out of seven, where bear population sizes were overestimated compared to population trajectories from other well-studied European populations.

Regarding bias, Popescu et al. (2016) point out that, in Romania, “Public and private game managers are the beneficiaries of much of the revenue generated by hunting activities.” Furthermore, “hunting targets are set based on rough abundance estimates derived from a mixture of track data, sightings at feeding stations and expert opinion, without incorporating uncertainty” and there is “limited monitoring.” Population estimates for bears, which provide wildlife managers with the greatest source of revenue (~3500 EUR for trophies <350 CIC points and ~6000 EUR for trophies >350 CIC points), were most exaggerated, and those counties with the highest bear hunting levels had most biologically implausible population estimates. Popescu et al. (2016) state that this suggests that “incentives other than carnivore ecology and demography might drive reported population estimates” and that, indeed, management decisions are partly driven by economic incentives rather than species biology. Popescu et al. (2016) state, “When managers that benefit from hunting are responsible for reporting abundances, there is a clear need for independent assessments of the veracity, and biological plausibility of the abundance estimates.”

In conclusion, Popescu et al. (2016) infer that Romania’s large carnivore management system is “poorly supported by the population data reported by game managers and that current hunting decisions are often based on biologically unrealistic population data.” Furthermore, in Romania “reported populations for U. arctos, but not C. lupusand L. lynx, are overly optimistic, and consequently, setting hunting quotas based on these estimates could lead to long-term population impacts.” Therefore, if the proposed maximum quota was determined using the inflated population estimates, it cannot be sustainable and must be dramatically reduced.

Further, data contained in Popescu et al. (2016) (Appendix S2), from the Romanian Ministry of Environment, show that in 2011 (the most recent year reported), the Transylvania region alone contained about 58.8% of the total estimated number of bears in the country (5,423 of 9,220) (Table 1). Popescu et al. (2016) consider these estimates to be biased over-estimates that are not based on science (Figure 3). Furthermore, based on these data, 64.2% of the annual brown bear hunting quota in 2011 (224 of 349) was allocated to counties in the Transylvania region. Finally, 74.9% of brown bears legally hunted in Romania in 2011 (182 of 243) were hunted in the Transylvania region.

Figure 3. Top map is of Romania, showing Transylvania region. Bottom map is from Popescu et al. 2016, showing number of years that estimated growth rates exceeded maximum growth rates of other European populations.

Dorresteijn et al. (2014) studied human-brown bear coexistence in Transylvania, Romania. The researchers found that “bears and humans coexisted relatively peacefully despite occasional conflicts.” Key to this coexistence were: 1) availability of forest blocks that are connected to bear populations in the Carpathian Mountains; 2) use of traditional livestock management to minimize damage from bears; and 3) some tolerance of shepherds to occasional conflict with bears.

Dorresteijn et al. found that bear activity was not related to human settlements and compensation for livestock losses did not influence people’s attitudes toward bears.

It is apparent from these studies that human-bear conflict is low in the region of Romania where hunting levels, and supposedly bear populations, are highest. Clearly the claims that hunting is needed to address human-bear conflict in this region are false.


According to the EU Habitats Directive, lethal management control can be used by EU Member states only if no satisfactory alternative has been found.

We recall that, following the integration of Romania into the European Union and according to the Emergency Government Ordinance no. 57/2007 on the regime of protected areas, natural habitats, wild flora and fauna, as amended, and to the Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora(Habitats Directive), the brown bear is protected by law being declared as a strictly protected speciesof Community interest. For these species capture or killing of the species located in their natural environment is prohibited, as are deliberate disturbance during the period of breeding, growing, hibernation as well as holding, transportation, selling or trading the species taken from their environment.

The Romanian national law complies with the EU Habitats Directive, which grants Member States the right to use derogations allowing management control of protected large carnivores at the national level to stop “serious damage” to livestock and crops and protect the public’s health and safety provided there is “no satisfactory alternative and the derogation is not harmful to the maintenance of the populations of the species concerned.”[1]

Without relying on factual and scientific data collected from the field, the Action Plan for Conservation of the Brown Bear in Romania considers that hunting can help mitigate conflicts and prevent damages. Since Romania entered the European Union, hunting has been the only solution chosen by the government to prevent damage done by bears, while alternative measures such as electric fences or repellents were never tested and implemented to protect people, farms and crops.

While for years the experts and the civil society have been demanding a scientific census of the bear population, the authorities seem to have chosen to rely on the numbers provided by the hunting industry.


Non-lethal management measures are effective and relevant to solve human-bear conflicts while hunting can often be detrimental to conflict mitigation and species conservation.

It is unclear from the language of the Action Plan if any non-lethal mitigation will be required prior to resorting to either lethal take or capture of the bears. We call on the Ministry to add to the Action Plan language requiring that non-lethal mitigation techniques are first exhausted prior to lethal take or capture of the animals.

Some effective non-lethal mitigation techniques include electric fencing of beehives and calving areas, carcass collection and disposal programs, bear-proof garbage disposal facilities, and regulations for carrying pepper spray and properly securing remains of hunter-killed animals. In addition, we believe that efforts to educate and assist affected livestock owners can be more effective at reducing human-wildlife conflict in the long term than lethal wildlife controls.

In fact, we note that the efficacy of lethal methods aimed at managing populations has never been scientifically demonstrated. Treves et al. (2016) asserted that lethal methods are often implemented without first considering experimental evidence of their effectiveness in mitigating predation-related threats or avoiding ecological degradation. This study recommended that “policy makers suspend predator control efforts that lack evidence for functional effectiveness and that scientists focus on stringent standards of evidence in tests of predator control.”

It is absolutely critical that co-adaption and coexistence measures are given first priority, before resorting to lethal take and capture of brown bears.


The need for improved bear management and resolution of human-bear conflicts should not be used as an excuse to serve the trophy hunting industry’s commercial interests.

We are deeply concerned that this Action Plan aims to manage brown bear populations and mitigate conflicts using only lethal measures for the next 10 years.

Among other actions presented, this Action Plan describes:

–      Hunting as a management measure of the brown bear in Romania (provisions: the extraction of the population surplus by sex and age classes through specific hunting actions which will take place annually within the hunting seasons at a maximum intervention level up to the level of the natural growth and even beyond it);

–      Hunting as a prevention measure of the disputes and damage (provisions: the application of this measure will be implemented throughout the year in the areas where damage and disputes have been found).  

In addition to our opposition to the inclusion in the Action Plan of hunting as the only measure to manage the brown bear population and preventing disputes and damages, we also strongly recommend that thecollection and capture of bears should only be conducted by an official technician mandated by the Government, and prevent any other individual from killing or capturing these protected animals.

We are further concerned about language in Action 1.5 which suggests allowing brown bear specimens to be “collected outside of the hunting seasons”. It is unclear for what purposes such collection would occur, or whether there would be any limits by number, sex or age. As such, this could turn out to be highly detrimental to the species conservation. Adopting such a proposition would provide an open door to bear hunters who are interested in hunting bears during autumn and winter when bears’ fur is of good quality.

Several traits particular to the social structure and life cycle of brown bears make them especially sensitive to hunting and lethal population control.

Brown bears are large-bodied carnivores sparsely populated across vast areas; they invest in few offspring; they provide extended parental care to their young; and social stability promotes their resiliency. See, e,g., Weaver et al. 1996, Wielgus et al. 2013, Creel et al. 2015, Wallach et al. 2015. Human persecution affects their social structure (Darimont et al. 2009, Wielgus et al. 2013, Bryan et al. 2014, Wallach et al. 2015) and harms their persistence (Wielgus et al. 2013, Zedrosser et al. 2013, Darimont et al. 2015). The consequence of these characteristics is that the effect of human persecution of brown bears is “super additive,” meaning that hunting kills result in mortality exceeding the simple 1:1 ratio and generates pressures on the population that far exceed what would occur in nature (Wielgus et al. 2013, Darimont et al. 2015, Gosselin et al. 2015).

Bear hunting and lethal population control have direct effects on population growth rates because of increased mortality, but also habr devastating indirect effects such as disrupting the sex and age structure of a population (Wielgus et al. 2013, Gosselin et al. 2015). Gosselin et al. state: “In species with sexually selected infanticide (“SSI”), hunting may decrease juvenile survival by increasing male turnover.” Studies show that hunting mortality, specifically, can harm social organization of species, because it promotes male turnover and thus increases sexually selected infanticide upon cubs of deceased males. Gosselin et al. 2015, at 1.

Therefore, we are concerned about the detrimental impact to the social structure and life cycle of bears that actions taken under this Action Plan will have on the Romanian bear population. We believe it is critical that the Ministry re-evaluates the 10% bear hunting quota to determine if it is sufficiently conservative and comports with the latest accurate population data.


Co-adaptation and co-existence with Romania’s brown bears are key to the safety of the human population, livestock, and agriculture.

We strongly recommend that the Action Plan should strongly urge co-adaptation and coexistence with Romania’s brown bears. Co-adaption and coexistence must happen if bears are to persist; that means that humans must be willing to share habitat and tolerate the small level of risk they pose (Dubois et al. 2017; Carter and Linnell 2016; Chapron, Guillaume et al. 2016). Humans must curb their own “hyperpredation” of other species and their habitats (Darimont et al. 2015, Chapron and López-Bao 2016).

In 2015, a group of academics, industry representatives, and nongovernmental organizations from five continents met for a 2-day workshop to develop the first international principles for ethical decision making in wildlife control. The conclusions of this group were published and are as summarized as follows:

“They determined that efforts to control wildlife should begin wherever possible by altering the human practices that cause human–wildlife conflict and by developing a culture of coexistence; be justified by evidence that significant harms are being caused to people, property, livelihoods, ecosystems, and/or other animals; have measurable outcome-based objectives that are clear, achievable, monitored, and adaptive; predictably minimize animal welfare harms to the fewest number of animals; be informed by community values as well as scientific, technical, and practical information; be integrated into plans for systematic long-term management; and be based on the specifics of the situation rather than negative labels (pest, overabundant) applied to the target species. We recommend that these principles guide development of international, national, and local standards and control decisions and implementation.” (Dubois et al. 2017)

We are aware that, in rural areas, it can be difficult to live with bears. When property is damaged (including houses, crops, herds, commercial forestry, etc.) compensation should be promptly delivered, with the help of the local authorities. In this way, people’s tolerance toward bears will improve, reducing the risk and the frequency poaching for revenge.

In extreme situations, where the bears are really presenting a risk to the human population and/or their property, the Ministry of Environment should have an emergency plan (on a national or an administrative level) so that it might intervene, from case to case, to eliminate dangerous situations. This emergency plan should be permanently separated from any kind of harvest quota that can possibly be allocated to the managers, and it should be made clear that its specific and unique scope is to address the extreme cases. The trophies from the approved interventions should not be the object of the commercial transactions, thus preventing fraudulent bear killing under the guise of an emergency.

We therefore consider it necessary that the State authorities should establish some specific conservations targets, based on environmental, social and economic targets – the basis for timely, concrete information about the species. In order to facilitate the collaboration between the interested parties, there is a need for decision-making transparency and predictability to establish the targets, the measures and the proposed actions. Only in this way it is possible to facilitate not only the maintenance of a balanced social climate, but also the maintenance of an ethics and non-discretionary framework in the bear management system in Romania.

In addition, we support proposals to conduct studies regarding the impact of mushroom and berry-picking activities on the brown bear population and to determinethe impact of brown bears on prey species (stag, deer, boar), with implications on the hunting, forest and farming sectors. However, we would recommend that such studies be conducted by independent agencies so as to ensure the outcomes will not be biased to serve any private interests.

On behalf of both Humane Society International/Europe and Agent Green, we thank you for this opportunity to provide comments and recommendations on this Action Plan for Conservation of the Brown Bear in Romania and reaffirm our belief that co-adaption and coexistence measures should be given first priority before resorting to lethal take and capture of brown bears.




Ruud Tombrock

Executive director

Humane Society International / Europe

Avenue des Arts 50, 7th Floor

1000 Brussels, Belgium


Gabriel Paun


Agent Green

11 Sergent C-tin Boghiu

014383 – Bucharest, Romania




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