Florida Fish and Wildlife
Conservation Commission
620 S. Meridian St.
Tallahassee, FL 32399
commissioners@myfwc.com
RE: Opposition to Proposed Florida Black Bear Hunt and Associated Methods of Take
Dear Commissioners,
On behalf of the Bergeron Everglades Foundation, we continue to strongly oppose the proposed Florida black bear hunt. As multi-generational Floridians with deep roots in this state’s land and traditions, we want to be clear: this is not a letter against hunting. Our family hunts, and we have members of our Foundation board who hunt. We fully support hunting as a valid and necessary tool for wildlife management—when it is backed by science and conducted responsibly. However, the current proposal lacks a sound scientific foundation and incorporates controversial methods of take, specifically baiting, the use of dogs, and the removal of physical check stations, that are inconsistent with ethical, science-based wildlife management.
1. Inadequate and Outdated Data: The population estimates informing this proposal are based largely on data collected between 2010 and 2015. Updated studies have not been released for the majority of Bear Management Units (BMUs). The Central and South BMUs (both targeted for this hunt) will not have updated data until 2026–2027. Moving forward without the updated data is premature and irresponsible.
2. Obsolete Demographic Modeling: The most recent demographic data for the Central BMU stems from a study conducted between 1999 and 2007. That study is 18–26 years old. Reproductive rates, cub survival, and female mortality have all likely changed, particularly given explosive development, habitat fragmentation and climate impacts. It is scientifically indefensible to assume these outdated models accurately reflect current reproductive rates or mortality risks. Basing policy on obsolete data is unacceptable.2
3. Questionable Mortality Threshold: The 20% threshold is derived from a 1980 study of northern bear populations. Florida black bears exist in entirely different ecological and climatic conditions. This standard is outdated and biologically inappropriate. Your own 2019 Bear Management Plan acknowledges the need for site-specific, science-based thresholds. Simply put, bear harvest decisions should be based on region-specific data, not generalized thresholds from dissimilar bear populations.
4. Non-Representative Public Opinion Data: The public support cited relies on nine-year-old phone surveys ( 2016 ) with fewer than 200 participants per BMU—irrelevant for a state with a population in excess of 23 million. Citing this outdated and statistically insignificant data is not only methodologically flawed, but it also fosters public mistrust, implying an effort to manipulate rather than inform public opinion.4
5. Use of Bait: Baiting to lure bears for hunting conditions bears to human food sources and undermines the highly effective BearWise program. It introduces unnatural food attractants into ecosystems, disrupts foraging behavior, and violates the principle of fair chase.
6. Use of Dogs: Pursuing bears with dogs in Florida’s climate and terrain poses risks to wildlife, hounds, and public safety. It causes extreme stress to bears, increases the risk of orphaned cubs, and creates enforcement challenges. It can also be dangerous for the dogs involved. Even states with larger bear populations are moving away from this method.
7. Lack of Physical Check Stations: The 2025 proposal removes mandatory weigh and check stations, replacing them with self-reporting via cell phone. In 2015, staffed check stations provided real-time harvest tracking, biological sampling, and public transparency. Eliminating them reduces oversight, increases the risk of misreporting, and erodes public confidence in the hunt’s integrity. For a policy this controversial, there must be independent, on-the-ground accountability. If the FWC believes this hunt is scientifically and ethically justified, then it should commit to full transparency—just as it did in 2015. Anything less raises legitimate questions about credibility and erodes public trust.
8. Habitat Connectivity and Genetic Diversity Concerns: Expanding and connecting bear habitat across Bear Management Units (BMUs) plays a critical role in supporting population resilience, enabling gene flow between subpopulations, and promoting long-term species health. Fragmented habitats increase risks such as genetic bottlenecks, road mortality, and isolation, all of which can contribute to population decline over time.
The importance of large, connected landscapes is well established in FWC’s own Bear Management Plan, yet implementation of wildlife corridors and barrier removal appears to have received limited emphasis. As decisions are considered regarding population management, greater attention to habitat connectivity may offer more sustainable, science-based benefits for the future of the species than a hunt based on incomplete or outdated data.
Our founder, former Commissioner Ron Bergeron, Sr. was the only FWC Commissioner to vote against the 2015 bear hunt. He did so because the science was not there. Specifically, there was no stock assessment showing that bear populations had exceeded the natural food supply. As he stated at the time: “A hunt is only appropriate when there are more bears than the natural food supply can support—when it’s in the best interest of the species. Until then, a bear hunt is inappropriate. Icon species deserve that extra layer of protection.” That science still does not exist.
We are not opposed to a bear hunt if and when the data clearly supports a targeted, science-based approach, guided by transparent protocols and accountability measures. However, the current proposal lacks both – timing and sound science based method. We respectfully urge the Commission to defer action on this item.
Alligator Ron Bergeron
Founder and President, Bergeron Everglades Foundation
Diamond Bergeron
Vice President/Executive Director
Bergeron Everglades Foundation
