Download Full Report here: http://www.bcauditor.com/sites/default/files/publications/reports/FINAL_Grizzly_Bear_Management.pdf
Grizzly bears are an indicator of government’s overall effectiveness in managing B.C.’s wildlife and maintaining healthy ecosystems. In B.C., grizzly bears invoke heated debate as to how they are managed. Much of this attention comes from the ecological, economic and cultural importance of grizzly bears, and the fact that B.C. is one of the last places in North America with grizzly bears in their natural habitat.
We expected the Ministry of Environment (MoE) and the Ministry of Forests, Lands and Natural Resource Operations (MFLNRO) to be effectively managing grizzly bear populations throughout B.C. We expected the ministries to have instituted a program that includes a cycle of continuous improvement—the Plan-Do-Check-Adjust cycle (see Audit Approach) and to be reporting out to the public on their performance.
There is no plan to implement the strategic direction for grizzly bears in B.C.
MoE and MFLNRO are responsible for grizzly bear management. They are guided by a grizzly bear strategy from 1995 and a high-level wildlife program plan from 2010. However, although management plans have been developed for other species, there is no grizzly bear management plan to provide priorities and clear accountabilities for implementing the direction provided in these two documents.
In the absence of a grizzly bear management plan, we expected that MoE and MFLNRO would still be carrying out activities to manage grizzly bears. We focused on four key components: inventory and monitoring of populations and habitats, managing
human-related threats, recovering populations of concern, and providing secure habitat.
There is a lack of organized inventory and monitoring of grizzly bears in B.C.
In the 1995 Grizzly Bear Conservation Strategy, government made a commitment to increase its research on grizzly bear ecosystems, including a province-wide inventory and assessment of grizzly bears and their habitats. We expected the ministries to have an inventory and monitoring strategy that identifies and prioritises areas based on risk.
We found that such a strategy was put in place in 2010 but is no longer being used, due to MFLNRO’s change in the way it extrapolates population estimates. However, MFLNRO’s method still requires inventory and monitoring to improve the population estimate.
Currently, there is no organized inventory and limited monitoring of grizzly bears. We found that one of the reasons this work is not being carried out is that there is no dedicated ministry funding; instead, government has created a user-pay model for funding conservation efforts. To hunt a grizzly bear, a resident of B.C. must pay $80 for a license, of which $16 is a surcharge.
and a non-resident must pay $1,030, of which $30 is a surcharge. The surcharges go to the Habitat Conservation Trust Foundation for grizzly bear conservation, who carry out conservation activities (which can include inventory and monitoring), and the remainder of the fee that is collected goes into government’s general revenue. For 2015, the ministry collected $366,400 in total from hunters of which approximately $34, 000 went to the foundation. We could find no evidence as to how either the allocation of what goes to the foundation, or the fees that are being charged for hunting, were determined.
Management of human-related mortalities has improved in some areas
In only a few hundred years, human activities have resulted in the extirpation (local extinction) of over half the grizzly bear population that once roamed North America. In B.C. historically some populations experienced significant declines and today there are areas where populations are extirpated. However, grizzly bear populations in some areas of B.C. are now increasing. To ensure that populations are either maintained or increase, government will have to carefully manage human threats.
We focused on four key areas for managing human threats: i) grizzly bear hunting ii) reducing illegal activities iii) reducing grizzly bear/human conflicts iv) regulating bear viewing
i) Grizzly bear hunting
Over the years, MFLNRO has made advances in its hunting policy and procedures. However, reviews of grizzly bear hunting by external experts in both 2003 and 2016 indicated that government can still make improvements. Both reviews called for areaspecific management objectives, which have not yet been established.
In the absence of objectives, MFLNRO is guided by the Grizzly Bear Harvest Management Procedure (2012). According to this procedure, hunted grizzly bear populations should be managed to avoid a decline in that population. However, this procedure does not adequately account for uncertainty in populations and unreported mortalities, and is not transparent as to how the ministry considers uncertainty when allocating hunting licences.
ii) Reducing illegal activities
The Conservation Officer Service (COS) within the Ministry of Environment works to reduce illegal activities such as poaching, attracting wildlife, or failing to report a bear killed due to conflict. We expected the COS to be evaluating the tools and resources it has available (warnings, tickets and formal charges) to ensure they are effective and sufficient, but no such evaluations have taken place.
iii) Reducing grizzly bear/human conflicts
From 2006 to 2015, there have been 389 grizzly bears killed from human/bear conflict (non-hunt
8Auditor General of British Columbia | October 2017 | An Independent Audit of Grizzly Bear Management
mortalities). This has resulted in an increasing number of grizzly bear incidents attended by a Conservation Officer. The COS has revised its procedures to evaluate the conflict and not automatically assume that a grizzly bear should be destroyed.
The COS relies on WildSafe BC to deliver an education program to prevent conflict with bears but the program is limited and the COS has not evaluated it for its effectiveness.
iv) Regulating bear viewing
Bear viewing is on the rise in B.C. It may seem like a harmless activity, however, it can have negative impacts, such as grizzly bears temporarily abandoning important feeding sites or changing their behaviour. Government is aware of these impacts but does not regulate bear viewing, even though it is noted as an issue in the Grizzly Bear Conservation Strategy.
Limited recovery actions taken for threatened grizzly bear populations
Out of the 56 grizzly bear populations, nine are threatened. The government’s primary objective for these is to recover them to sustainable levels. However, sustainable levels have not been defined and there have been limited recovery actions taken for these populations.
Government has created a recovery plan for one population (the North Cascades) but it has not been implemented. This lack of implementation has not been publicly disclosed. Instead, government has
stated, “A plan of action was created to focus recovery efforts on the North Cascades population—its small size and isolated location made it the highest conservation priority.”
Key tools that mitigate industries’ impacts on grizzly bear habitat have not been evaluated for their effectiveness.
Ensuring healthy grizzly bear populations throughout B.C. is only possible if government is able to provide secure habitat for this species. We examined the following tools to determine if they are effective in mitigating industries’ impacts on grizzly bear habitat:
Land use plans
Many land use plans have objectives for maintaining grizzly bear habitat. We found that over half of these plans have not been monitored or evaluated.
Forest stewardship plans
MFLNRO’s Forest and Range Evaluation Program has not provided an overall evaluation as to whether the forest stewardship plans have been effective in achieving their objective of protecting wildlife, and specifically, grizzly bears (which the program lists as a high priority).
Proposed Natural Resource Roads Act
We found very few mitigation measures that government has undertaken to address resource roads. Government has been working on the
development of a Natural Resource Roads Act since 2011, but two years ago, removed access management planning from the draft in favour of “resolving access management conflict.” It is not clear how government will resolve conflict when there is no overall plan for resources roads.
MoE’s oversight of the Oil and Gas Commission (OGC)
MoE, under the Oil and Gas Activities Act, has the power to order an independent audit of the performance of the oil and gas commission to ensure the protection and effective management of the environment. However, to date, MoE has not carried out an independent audit of the OGC, nor are staff clear as to how such an audit would be triggered.
Environmental assessment certificates
The Environmental Assessment Office (EAO) had not evaluated whether certificate conditions related to grizzly bears are effective in mitigating impacts. EAO has recently put in place a requirement for a qualified professional to monitor effects to ensure the certificates are meeting the intended outcomes.
Draft Cumulative Effects Assessment Protocol for Grizzly Bear in British Columbia
We found that the draft Assessment Protocol for Grizzly Bear in British Columbia compiles known information on grizzly bears and their habitat. However, there is little direction to decision makers on how to evaluate activities within threatened grizzly bear population
units—other than to say that government will develop a process to confirm management direction. We also found that this protocol neither accounts for uncertainty in the data, nor identifies the need for a precautionary approach in the decision-making process when data is limited.
Key tools that conserve grizzly bear habitat have not been evaluated for their effectiveness
We examined the tools that MoE and MFLNRO have in place for providing secure, connected habit for grizzly bears. We examined Wildlife Habitat Areas, Grizzly Bear Management Areas and Parks and Protected Areas.
Overall, we found that none of these tools have been evaluated for their effectiveness and there has been little effort to address the issue of connectivity for grizzly bears or to provide wildlife corridors and safe transition areas for those populations in the south that may have limited migration and may experience genetic inbreeding.
The recently announced Great Bear Rainforest Agreement was too new to gauge its effectiveness, but it has the potential to be effective in providing grizzly bear habitat conservation.
Monitoring and evaluation are critical tools to track progress and facilitate decision-making. Evaluation should be systematic and include an unbiased assessment of the activities, programs and policies that government has instituted to ensure it is meeting
10Auditor General of British Columbia | October 2017 | An Independent Audit of Grizzly Bear Management
its objective of healthy grizzly bear populations. MFLNRO has undertaken two reviews of its hunting procedures. However, as noted in the previous sections, neither MoE nor MFLNRO have evaluated the effectiveness of other activities and policies that are designed to mitigate impacts on grizzly bears and their habitat.
MoE and MFLNRO do not have a process for ensuring continuous improvement
Neither the Grizzly Bear Conservation Strategy nor the Wildlife Program Plan have been adjusted for several years and government has not indicated how it intends to implement the recommendations from the 2016 review of hunting. We found the main reason is that neither MoE nor MFLNRO have a formal process for improving grizzly bear management in B.C. This is of concern, given the amount of change that is happening on provincial Crown lands.
MoE and MFLNRO are not being transparent about their management of grizzly bears
We found that government is publicly reporting on grizzly bear populations and mortalities in the province via its website. What it doesn’t describe, is the level of confidence as to the accuracy of these estimates. There is no clear indication as to when the website information will be updated. The population information is from 2012, and although there is some discussion at MFLNRO on updating the estimate, there is no policy requirement to do so.
In addition, MoE’s website contains information that is incomplete. For example, the website states that there is a plan for recovery of the North Cascades grizzly bear population, but it does not state that the plan was never operationalized.
Overall, we found that even though there is transparency of information regarding grizzly bears, there is little information on management activities and performance measures.
Why is implementation of the grizzly bear program not working?
So why is the grizzly bear program not working? A primary reason is that MoE and MFLNRO have an unclear organizational structure and unclear accountabilities for wildlife management.
We found that, while MoE retains the sole responsibility “to manage, protect and conserve all water, land, air, plant life and animal life…” MFLNRO has the authority to manage wildlife. The result is that the two ministries have overlapping roles and responsibilities. MFLNRO has most of the authority to make decisions that impact grizzly bear populations and habitat, leaving MoE with limited powers to carry out its mandate to manage and protect. This creates a tension between the two ministries that is unresolved.
11Auditor General of British Columbia | October 2017 |An Independent Audit of Grizzly Bear Management
SUMMARY OF RECOMMENDATIONS
WE RECOMMEND THAT THE MINISTRy OF FORESTS, LANDS AND NATURAL RESOURCE OPERATIONS AND THE MINISTRy OF ENVIRONMENT: 1 create and implement a grizzly bear management plan that includes: clear indication of how the plan fits into the ministries’ overall wildlife management planning (where is it in the priority) clear goals and targets prioritized activities and timelines, including accountabilities for those activities resources and expertise required to undertake the activities in the plan requirement for monitoring of program effectiveness a process for evaluating and adjusting activities as needed 2 develop and implement an adequately resourced inventory and monitoring strategy for grizzly bears.
WE RECOMMEND THAT THE MINISTRy OF FORESTS, LANDS AND NATURAL RESOURCE OPERATIONS: 3 revise its policy and procedures to determine how uncertainty will be accounted for when determining grizzly bear hunt allocations and to be transparent about the process.
WE RECOMMEND THAT THE MINISTRy OF ENVIRONMENT: 4 ensure the Conservation Officer Service has the appropriate resources and tools for preventing and responding to grizzly bears/human conflicts.
12Auditor General of British Columbia | October 2017 | An Independent Audit of Grizzly Bear Management
SUMMARy OF RECOMMENDATIONS
WE RECOMMEND THAT THE MINISTRy OF FORESTS, LANDS AND NATURAL RESOURCE OPERATIONS AND THE MINISTRy OF ENVIRONMENT: 5 develop clear policies and procedures for bear viewing. 6 identify those grizzly bear populations that are in need of recovery and outline what actions will be taken and when. 7 evaluate and adjust as needed the tools used to mitigate industries’ impacts on grizzly bear habitat. 8 evaluate and adjust as needed the tools used to conserve grizzly bear habitat. 9 report out to the public and legislators on how well they are managing grizzly bear populations throughout British Columbia.
WE RECOMMEND THAT GOVERNMENT: 10 review the legislation, policies and accountabilities for wildlife management and ensure that roles, responsibilities and accountabilities allow the Ministry of Forests, Lands and Natural Resource Operations and the Ministry of Environment to be fully effective in delivering on grizzly bear management.
A muddled mess of plans that were never implemented, unclear accountability, lack of organized monitoring and spotty oversight has been at the root of the provincial government’s management of grizzly bear populations for more than two decades, Auditor General Carol Bellringer found in a highly critical report released Tuesday.
The report confirms many of the concerns frequently raised by conservation groups. A lack of firm population numbers. Resource extraction in grizzly bear habitat. Lax regulation of the grizzly bear trophy hunt.
“This is a scathing indictment of the poor management of grizzly bears by successive B.C. governments, going back decades,” said Faisal Moola, director of the David Suzuki Foundation, which requested an audit in 2014 along with University of Victoria’s Environmental Law Centre.
To understand where things went wrong, we’ve got to rewind to 1995 when the government committed to a “Grizzly Bear Conservation Strategy” with a goal to maintain healthy grizzly bear populations and the ecosystems they depend on.
But the Environment Ministry and Ministry of Forests, Lands and Natural Resources never clarified responsibilities and priorities in terms of actually implementing the strategy.
“Currently, there is no organized inventory and limited monitoring of grizzly bears. We found that one of the reasons this work is not being carried out is that there is no dedicated ministry funding,” says the report.
In other cases, government created plans, such as the strategy for recovering the endangered North Cascades grizzly population, but plans were never implemented.
“In many cases they have not developed policies and procedures necessary to ensure the survival of grizzly bear populations and, when they have had plans, they have failed to effectively implement them,” Moola said.
Government figures estimate there are now 15,000 grizzly bears in B.C. — one of the last areas in North America where grizzly bears live in their natural habitat. But that figure is questioned by some scientists — and nine of the province’s grizzly bear populations are on the verge of elimination.
A century ago, 35,000 grizzly bears lived in B.C, while other populations flourished from Alaska to Mexico to Manitoba, according to the Suzuki Foundation.
Some populations of bears have increased, Bellringer noted, but that is not the result of management strategies.
Habitat Destruction Key Threat to Grizzly Bears
Despite the public controversy that has raged around the grizzly bear trophy hunt, with 250 to 300 bears killed every year, the greatest threat is not hunting, but human activities that degrade grizzly bear habitat, Bellringer wrote.
“For example, there are 600,000 kilometres of resource roads with, on the order of 10,000 kilometres more added each year. This expansion allows greater human access into wilderness areas, which results in illegal killing of grizzly bears and greater human-bear conflicts,” she wrote.
Forests, Lands and Natural Resource Operations Minister Doug Donaldson and Environment Minister George Heyman said the government is accepting all 10 recommendations in the report and will develop a grizzly bear management plan with clear objectives, roles, responsibilities and accountabilities.
The recommendations include improvements in monitoring populations and threats, developing an adequately funded inventory of bears, increased transparency, ensuring the Conservation Officer Service has enough resources to respond to grizzly/human conflicts, developing clear policies and procedures for bear viewing, mitigating the effect of industry on bear habitat, adjusting tools needed to conserve habitat and reviewing wildlife management in B.C.
Some Areas Need to be ‘Off Limits’ To Industry to Protect Habitat
Members of the public may send comments to the Fish and Wildlife Branch at email@example.com until November 2, 2017 –
The letter below is a sample of letters that have been emailed to Fish and Wildlife Branch….
Quote taken from hunter’s Facebook page before it was closed to the public on Oct 23’17 “Big Teddy is hanging out at my buddy’s place in Vancouver BC while I wait for all the permits to cross the border.” – US Trophy Hunter
Oct 23, 2017
Dear Fish and Wildlife Branch at firstname.lastname@example.org
Re: Possible loopholes in the plan to regulate the grizzly hunt in our province
I just read a post about a grizzly bear that was killed recently. It was a record-sized grizzly bear which apparently is the second largest grizzly ever shot in BC.
I believe that an unconditional ban must be put on this deplorable hunt. It is not acceptable, on any level, to snuff out the life of a living, breathing creature, for fun and for profit.
All loopholes that may allow trophy (and they are all trophy!) hunts must be closed. I hope and pray that I never again have to view a picture like the one I saw this morning – a hunter smiling over his kill of the “second largest grizzly ever shot in BC”. This was a beautiful creature that did not deserve to die. The “hunter” was just one of many heartless, thrill seeking individuals –maniacal psychopaths really; who kills for fun other than psychopaths? – who use our beautiful wilderness for their fun-seeking, destructive and selfish pleasure. We must not allow it. British Columbia is better than this – our government must protect all life in this province.
I voted for this government on their promise to “end the grizzly hunt” – to end it! I even told our MP, Ralph Sultan, that I was voting NDP because the Liberals would not end the hunt. However, from what I have read, I fear that the hunt “will not end unless the NDP Government closes loopholes in their plan to regulate the grizzly hunt in our province.”
Please ensure that there are no “loopholes” – and that grizzly bear hunting will be banned completely – not just “regulated”. I trust that the government will fulfill its promise and that my vote was not wasted.
Thank you for requesting our input.
PS: with regard to “Bear Meat”– On The Mayo Clinic Website under
Diseases and Conditions -Trichinosis – https://www.mayoclinic.org/diseases-conditions/trichinosis/basics/causes/CON-20027095
It states that “Wild animals, including bear, continue to be sources of infection.”
Never believe it when these creeps lie that “bear meat” is for consumption – it’s not!
Executive Director, Natural Resources
Resource Stewardship Division, FLNR Ministry ( see emails and initial response below)
Oct 19, 2017
Dear Mr. Trotter,
I wish I could thank you for your response. However, I can’t. It’s difficult to thank for a generic email that was sent to everyone and doesn’t address any of the concerns I highlighted in my letter regarding the grizzly hunt. I truly hope that this public consultation will be different than the ones we had under the liberal government.
I reiterate my strong opposition to grizzly hunt and I am asking for a full and complete ban on hunting grizzly bears all over BC. We are being asked to comment on how to manage the ‘meat’ hunt, but the majority of British Columbians clearly stated that there should not be grizzly hunt of any kind. I respectfully want to remind you that this is the view of the same majority that voted for change. I would like to ask, thus, my government to address our wishes instead of ignoring them and asking us to comment on the ‘meat’ hunt.
I also wanted to stress that among those who oppose the grizzly hunt, there are also hunters who truly hunt for food. They view the grizzly hunt as “socially and environmentally unsustainable” – an unethical practice that has no place in modern society, and conservation”. They say that statement about eating grizzly meat from both Guide Operators and hunters “betrays an ignorance and selfishness that should never be supported by our government.” Indeed, we all know the BC grizzly hunt has never been about the “meat” hunt. It is and always has been about for a rug, a head on the wall, a photo over a dead grizzly bear, a trophy. Reviewing old hunting forums tells us a lot about hunters’ opinion about grizzly meat. For the majority, grizzly bear meat is inedible because contains parasitic diseases and needs to be handled and cooked in a particular, laborious way to make it safe. However, incredulously, over the past year or so, many grizzly bear hunters have suddenly developed the taste for grizzly meat… I do not think British Columbians can be fooled so easily. This whole idea of eating grizzly meat is really insulting the intelligence of many of your supporters.
Furthermore, as I also mentioned in my previous e-mail, the notion of sustainability of the grizzly hunt can be easily questioned… As a conservation scientist who has a training and years of experience with population models, I know how much uncertainty is involved in their predictions. And these predictions have become even more uncertain due to impacts of climate change on food supply and habitat. Even though hunters claim that they see more bears in some areas, this claim is misleading. Grizzlies respond to changes in food supply and to other human related stressors. And yes, they move across the landscape, which can give a false impression of their higher densities in some areas. This does not mean, however, that population is doing well. Far from it. In fact, we keep waking up every day to ‘surprise information’ about species going extinct. Just a recent WWF analysis looking at the long-term trends of more than 900 species of wildlife in Canada has found that half of them have seen their populations decline, including several species already listed as threatened or endangered. Is it really a surprise or are we just turning a blind eye to what’s happening to wildlife around us only to wake up one day to the stern reality that it is already too late? Please, do not let it happen to grizzlies.
Finally, I would appreciate my government to stop using the word ‘harvest’ in relation to wildlife. As a scientist, I have been trained in wildlife management and this is the vocabulary that I have been taught. Still, it does not mean that we should keep using it. Our social values change, and this change needs to be reflected in our vocabulary and in how we define our relationship with animals. We don’t view grizzlies or any other wildlife species as “resources” to be “harvested”, but, instead, living, breathing beings that has the right to live and be free from our dominance and persecution. Is this an emotional statement? Yes, it is. Still, it can no longer be brushed away because its relevance is supported by the latest science. These latest findings reveal the richness of animals’ inner lives and provide a vindication for our deep emotional appreciation of other beings. Ironically, the attempts by government’s and pro-hunting groups to paint the public’s emotional arguments in relation to animal welfare as unscientific are, on their own, blatantly unscientific — a denial of science at its most fundamental level.
I therefore plead with you to hear British Columbians when we say that we do not want to comment on the ‘meat’ hunt that they find unethical and unjustifiable. Instead we are asking our newly elected government to end all hunting of all grizzly bears across all of BC. Please, do not let grizzlies slip through the bureaucratic cracks into extinction. We can’t let it happen. Instead, let’s put our efforts into habitat restoration and education on co-existence with these majestic creatures that the whole envious world is coming to BC to see and admire.
Dr. Gosia Bryja, British Columbia, Canada
From: “Executive Division Office, FLNR:EX” <FLNR.ExecutiveDivisionOffice@gov.bc.ca>
Cc: “OfficeofthePremier, Office PREM:EX” <Premier@gov.bc.ca>; “Minister, FLNR FLNR:EX” <FLNR.Minister@gov.bc.ca>; “Minister, ENV ENV:EX” <ENV.Minister@gov.bc.ca>; “Weaver.MLA, Andrew LASS:EX” <Andrew.Weaver.MLA@leg.bc.ca>; “Tegart.MLA, Jackie LASS:EX” <Jackie.Tegart.MLA@leg.bc.ca>; “Olsen…MLA, Adam LASS:EX” <Adam.Olsen.MLA@leg.bc.ca> (also write to Grizzly.Bear@gov.bc.ca )
Sent: Friday, October 20, 2017 2:30 PM
Subject: RE: Grizzly Bear Trophy Hunt (ref: 230514/230704)
Thank you for writing concerning the grizzly bear trophy hunting. I apologize for the delayed response.
As a number of British Columbians have written with enquiries and comments on this topic, I am providing further information below. Your comments will be considered as part of all feedback received through the consultation process outlined below, which is open for public input until November 2, 2017.
Effective November 30, 2017, the ministry plans to end trophy hunting by making it illegal to possess the trophy parts of a grizzly bear harvested after November 30, 2017, along with all hunting of grizzly bear in the Great Bear Rainforest, which acts on the new government’s platform commitment. Closing the grizzly bear hunt altogether in the Great Bear Rainforest also goes beyond the previous commitments made to Coastal First Nations. Hunting for meat will be allowed to continue outside the Great Bear Rainforest.
The prohibition on possession of grizzly bear trophy parts and the grizzly bear hunting closure in Great Bear Rainforest will not apply to First Nations who harvest grizzly bears within their traditional territories pursuant to Aboriginal rights for food, social or ceremonial purposes, or treaty rights.
Government has invited public input on the trophy hunting ban and proposed regulation changes required to implement the ban. The correspondence we received from you has been provided as input to this consultation process.
Should you wish to provide additional comments, you have the opportunity to provide input until November 2, 2017, on two policy documents outlining the proposed regulation changes required to implement the ban. As part of the consultation, input is being sought on:
• Changes to manage the ban in hunting areas that overlap the Great Bear Rainforest;
• Changes that will prohibit the possession of “trophy” grizzly bear parts;
• Changes that will manage prohibited grizzly bear parts;
• Changes to prohibit the trafficking of grizzly bear parts; and
• New reporting requirements for taxidermists.
The two policy documents can be reviewed at: http://www.env.gov.bc.ca/fw
Members of the public may send comments to the Fish and Wildlife Branch at: email@example.com
If you choose to submit further input at that email, you will receive a confirmation of receipt back. Due to the expected volume of material, individual responses will not be possible.
We will also be developing, with public input, a renewed wildlife management strategy for BC. The key elements of that strategy will include dedicated funding for wildlife and habitat conservation and a collaborative process to develop short- and long-term plans for wildlife resources.
Thank you again for writing to express your concerns.
Executive Director, Natural Resources
Resource Stewardship Division