On behalf of Ontario…

On behalf of Ontario Federation of Anglers and Hunters Membership (OFAH), Ontario’s largest, non-profit, fish and wildlife conservation-based organization, representing 100,000 members, subscribers and supporters, and 675 member clubs, we have reviewed ERO 019-9441: “Modernizing fishing and hunting licence products and processes to support the development of Ontario’s new fishing and hunting licensing system” and offer the following comments for consideration.

The OFAH supports the general aim of modernizing Ontario’s fishing and hunting licensing system. With potential to remove unnecessary steps and complexity, a streamlined and more technologically relevant licensing system is helpful for all parties. In particular, the addition of hunter accreditation and falconry licences under the proposed app, and the creation of an outfitter portal for moose and black bear outfitters, represent welcome, albeit long overdue efficiencies. We are also glad to see our licensing system come home rather than being based in the USA. However, the OFAH has several questions and concerns about certain aspects of this proposal.

Added complexity
The OFAH fully appreciates the enforcement value of requiring a licence or identifying information to be affixed to a carcass when it is not accompanied by a hunter. However, the necessity of this requirement threatens to undercut the primary benefit of a digital tag system - namely, convenience. If the majority of hunters will at some point leave a carcass before processing, then it stands to reason that, under the proposed regulations, most hunters must carry paper, a writing instrument, and a weather-resistant method of attachment. In effect, hunters will be required to carry all the same materials they do under the current paper licensing system, and more. With added concerns around legibility that will undoubtedly accompany these new requirements, we must ask: What incentive is there for hunters to use a digital tag at all? There is a need for clarity on this point.

If the Ministry chooses to proceed with the requirement to affix information to an animal when it is not accompanied by the hunter, irrespective of electronic tagging, this may be an opportune moment to consider new safeguards for the transport of processed game meat. At present, an illegally harvested deer, once processed, could easily be passed off as a gift or share of someone else’s harvest without the requirement for specific checks and balances. The creation of a "transport tag" or a requirement to affix basic tag information to processed meat could prove extremely useful for enforcement in identifying poachers who currently rely on the lack of such requirements to avoid detection.

Legal registration
There appears to be no consideration in this proposal for the issue of registration following the end of legal shooting hours. Due to standard practice and ethical considerations, locating downed big game animals after dark is very common. For this reason, hunters frequently notch their tags after shooting light. With the automatic date and time registration proposed for the digital system, a responsible hunter who waits until after shooting light to retrieve an animal may now appear noncompliant. While a manual entry option (allowing the hunter to record the time of the shot rather than the time of retrieval) might resolve this on the surface, it does not address the underlying issue: legal status of blood tracking at night in Ontario. This legal grey area has long been a source of concern and confusion for Ontario hunters, in addition to causing certain legislative complications. The OFAH has been a vocal proponent of explicitly authorizing nighttime blood tracking under specific conditions for many years and now may be the ideal time to implement these recommendations, thereby resolving a long-standing issue and supporting the successful implementation of a modern licensing system.

Licence abuse
Despite repeated assurances from the Ministry, the proposal’s inclusion of printable tags suggests that the long-standing issue of duplicate licences would remain unresolved if these changes were to proceed. The issue of duplicate licences has led to significant and unacceptable resource abuse since the inception of Ontario’s paper tag system. We therefore strongly urge the Ministry to take concrete steps to resolve this issue during the current overhaul of the licensing framework. Many solutions are possible, including a user-pay model that allows hunters to obtain a durable tag similar to the previous system for a small fee.

Concerns regarding fraudulent applications and accounts will, it seems, also continue under this new framework, underscoring the need for an enhanced approach to auditing. Current issues include the use of accounts belonging to deceased individuals and the creation of accounts by non-residents with property in Ontario. It is also possible that the introduction of digital tags will create entirely new loopholes as well. We therefore recommend the province invest in new and innovative auditing mechanisms to ensure fairness and to prevent abuse of Ontario’s natural resources.

Liability and privacy
Potential liability concerns exist related to the use of personal cell phones during interactions with law enforcement, which will become more common with the introduction of a mobile app and digital tags. The requirement for Conservation Officers to assume physical control of a hunter or angler's device during a routine inspection or active investigation raises serious privacy issues and is likely to be a source of conflict in the field. It also introduces a risk of damage to phones from exposure to the elements. Hunters and anglers must be clearly informed that officers may take physical possession of their devices and that this may, at times, occur outside the owner's presence.

Communication
Finally, we wish to highlight the critical role that communication must play in any new licensing framework. In order to avoid unintentional noncompliance, it is very important for the province to clearly articulate the details and associated considerations of a system overhaul, especially in the first few years of implementation. The requirement for hunters to choose either paper or electronic tags (not both), for example, could easily be misunderstood by hunters. The OFAH would be glad to work alongside the MNR to achieve its education and outreach goals.

The OFAH supports the modernization of Ontario’s licensing system in principle but urges the Ministry to ensure that any new requirements genuinely reduce burdens on hunters, close existing enforcement gaps, and reflect the realities of responsible hunting. We appreciate the opportunity to comment on these matters and look forward to working alongside the province now and into the future.