I object to the continuation…

I object to the continuation of the spring black bear season beyond 2020 for residents and non-residents in all Wildlife Management Units where there is a fall black bear season. The annual spring season from May 1st to June 15th should end on June 15th, 2020. The reasons for my objection are as follows:
• The OMNRF has not released to the Ontario public the OMNRF’s analysis of the 7-year black bear spring season pilot (which started as 2 years in 2014 and was extended another 5-years in 2016). As a result, the public cannot use the OMNRF’s analysis of the black bear spring season pilot, which directly relates to this proposal, to assess the scientific validity of the current proposal.

• The OMNRF has not released to the Ontario public the data from the Bear Wise program to show that a regular spring bear season should be implemented. As a result, the public cannot assess the success of the stated purpose of the pilot project and therefore cannot fully respond to the current proposal. When OMNR introduced the spring bear hunt pilot in 2014, Minister David Orazietti stressed that the purpose of the 2 year pilot was to “reduce human-bear conflicts and improve public safety.” The MNRF Black Bear Management Framework published February 28, 2019, updated December 10, 2019) indicates that “further considerations for bear management comes from recommendations of the Nuisance Bear Review Committee Report (August 2003) and the Auditor General of Ontario’s 2007 Annual Report (see 2.0 Scope) and that the OMNR also moved forward on recommendations from the Nuisance Bear Review Committee Report by initiating the Bear Wise program to address public safety concerns about human-bear conflicts.” In addition, under section 7.0 “Key Management strategies and associated tactics”, objective #1 states that “ongoing monitoring and research is critical for informed decision-making, sound policy development and implementing an adaptive management approach. Research should focus on addressing key knowledge gaps and risk assessment, as well as evaluation of the effects of specific management actions on bear populations on the landscape and on their habitat.” Why has OMNRF not reported back to the public on the evaluation of the specific management actions of the Bear Wise program in reducing human-bear conflicts and improving public safety?

• The population growth rate of black bears has been significantly impacted by the spring bear hunt pilot. The MNRF Black Bear Management Framework indicates under section 4.0 “Guiding Principles”, in principle #4 that “harvest management strategies must recognize that black bears have an inherently low reproductive capacity relative to other harvested large mammals and that, as with other long-lived species, population growth rate is most sensitive to changes in adult survival, particularly survival of adult females.” Under section 5.0 “Challenges”, challenge #2 acknowledges that it is difficult to estimate black bear population size and trends. Given these statements, it is directly relevant that the black bear harvest data from the Ontario Data Catalogue shows that as a result of the black bear spring season pilot (which started as 2 years in 2014 and was extended another 5-years in 2016), the black bear harvest in Ontario increased by 21% between 2014 and 2018 (32,197 bears) compared with the previous 5 years (2009 to 2013) at 26,709 bears.

• The spring bear hunt pilot project was not justified, nor does the current proposal provide adequate justification for the implementation of a regular spring black bear season. The Ontario government should not be ignoring the Environmental Commission of Ontario’s (ECO) November 2015 annual report which harshly criticized OMNRF’s 2-year spring bear hunt project. Included in this report is the Environmental Commissioner’s view that the Ontario government ignored its own research that calls into question the utility and justification of the pilot project and had ignored the existing advice of the committee created to review the nuisance bear issue.

• A 2010 study by MNR scientists indicated that there was “no evidence that the spring bear hunt {in 1999} caused the perceived increases in the bear population or human-bear conflicts.” The 2003 report from the independent Ontario Nuisance Bear Committee found that increased nuisance bear activity was not related to the cancellation of the spring bear hunt, but rather the scarcity of natural foods.

If the proposal proceeds, it should be amended to take into account the following factors:
• The fall black bear hunting season should be reduced if Ontario implements a regular spring black bear season. The proposal does not take into account he 1999 expansion of the Ontario black bear hunt (currently 2 ½ to 3 months).
• The proposal should to prohibit hunting with dogs during the spring bear hunt. The Nuisance Bear Review Committee recommended that any spring bear hunt should prohibit the use of dogs.
• The prohibition should include significant penalties for harvesting bear cubs and female bears accompanied by cubs. The prohibition of the harvest of bear cubs and female bears accompanied by a cub is not adequate to ensure that numerous bear cubs will not be orphaned by the spring bear hunt. OMNR estimated that at lease 274 bear cubs were orphaned in the 1999 spring bear hunt. Ontario has chosen not to publish current estimates of orphaned bear cubs and so I cannot quote more current data. Current data should be released to the public.

I agree with the proposal to reduce the bear hunting and trapping season to one-week from May 1 to May 7 in WMUs 82A, 83 and 84 (and to close the fall season) to support the long-term sustainability of the local black bear population on the Bruce Peninsula, but I do not think it goes far enough. The MNRF Black Bear Management Framework published February 28, 2019, updated December 10, 2019) indicates under under 5.0 Challenges that “the black bear’s inherently slow rate of recovery from low population levels increases the risks for local populations where harvest pressure and other mortality are high.” For this reason, I think that the one-week season from May 1 to May 7 should also not be implemented.