Greetings, I hold a degree…

ERO number

019-1112

Comment ID

45168

Commenting on behalf of

Pine Cliff Lodge

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Comment approved More about comment statuses

Comment

Greetings,

I hold a degree in natural resource management, was a former environmental consultant in the private sector, and I’m currently a tourist camp owner/operator and non-resident landowner in Northwest Ontario (WMU 5). I recognize the need for sustainable management based on scientific data to determine harvest rates while considering population density and habitat carrying capacity within a territory. I understand the need to decrease or increase harvest rates at any given time if the data suggests and I appreciate initiatives such as the barbed wire surveys as an attempt to reach an objective approach to determine best management practices for a sustainable and healthy black bear population. Sustainable management of the black bear population is eminent. Regulation of fish and game harvest rates are crucial. However, in many instances when attempting to regulate fish and game harvest across vast, varying landscapes such as Ontario, too often rules are passed with too broad of a brush stroke across the entire Province, which negatively impacts hunters and tourist camp operators in areas over-run with black bears. Unless the rule will open the door to more BMA transfers and an increase of allotted tags to our tourist camp, the proposed rule to eliminate the non-resident landowner tag opportunity will have a negative effect to our tourist camp operation.

My wife and I (with 3 toddlers) spent our savings to purchase our camp and moved from Texas to continue the operation as a fishing and hunting lodge along the Sioux Highway between Dryden and Sioux Lookout. We purchased the camp based on historical and projected revenue generated from lodging, boat rentals, black bear hunting, and moose hunting. We did not enter the business for financial gain, but rather to make a modest living while sharing our passion for the outdoors, our hunting/fishing heritage, and advocating good stewardship of the natural resources on the landscape. The historical and anticipated revenue generated from bear hunts is vital and a substantial component to the sustainability of the business. After purchasing the camp and submitting the application to transfer the BMA from the prior owners, we were notified by MNR that a determination had been made to halt all BMA transfers in select units (WMU 5 being on the list). This information was not published or communicated to camp owners prior to the decision being made. In some instances, this information was intentionally withheld from camp owners that were marketing their camps for sale with an associated BMA. In an acquisition such as ours, that information can be the difference between a successful business and bankrupt business. Beyond my own personal interests, these bear hunts provide an economic benefit to Ontario and local communities of Fort Francis, Dryden, and Sioux Lookout as our guests spend money in those towns to fulfill their hunting trips. These bear hunts also assist in the reduction of predation on struggling cervid populations.

Our camp has held a BMA across multiple owners for over 30 years. This relatively small BMA has historically produced an annual harvest of 10-20 bears without showing any sign of depletion throughout those years. When the previous owner began to reduce his operations due to poor health and upcoming retirement, the MNR reduced his allotted tags to 4, based on his previous 3-year average of bears harvested (12-0-0). This reduction in tags was not due to a declining bear population, but simply due to his inability to provide hunting services at that time. It is also evident that our accelerating bear population is having a direct impact on the struggling moose population, which we would like to see bounce back. Now, as a new owner of the camp trying to scratch out a living, we are struggling to get approval for the BMA transfer to receive the minimal amount of tags to manage a robust bear population that we have in the area. Since August 2019, the MNR Dryden Office has failed to respond to my inquiries and provide any data to suggest the local bear population is in decline, or any piece of legislation or statute that would justify and legitimize the halt of BMA transfers in WMU 5. Trying to find an alternative solution to receive the bear tags granted to the prior owner who still holds the BMA, we have provided the MNR with legal documentation, signed and notarized by the current BMA holder and myself, that grants me authority to act on behalf of the prior owner to pay the associated BMA fee and fulfill the validation certificates. The MNR Dryden office has held my check payment for the BMA fee for over 2 months and has yet to issue a reply to my inquiries dating back to August 2019.

I presume many tourist camp operators would favor the elimination of non-resident landowner tag opportunities, presuming that would direct more business into the hands of camp owners. However, as a tourist camp owner and non-resident landowner, I am opposed to the proposed rule-change to eliminate the tag opportunity for non-resident landowners. Currently, a non-resident landowner tag is the only means I have to manage a robust bear population around my camp. We have historically had a thriving bear population over the past 30 years, even with a consistent harvest of 10-20 bears annually within the 50 square km BMA around the camp. Since the harvest rate has been zero over the past several years, we are experiencing an unusually high rate of human-bear conflict around the camp and noticeably less moose and deer sightings in the BMA. I recognize the need to regulate harvest rates to maintain a sustainable population, while still maximizing the benefit of the resource. If the local bear population were indeed in decline, I would be on the front line sounding the horn. However, in our particular BMA, and surrounding BMAs, there are no signs or suggestions of a depleted bear population. Neighbors, nearby outfitters, and conservation officers have all suggested a robust bear population in the area, and they see no need to reduce the harvest of bears in our area. It is very common to see bears along the highway, shorelines, and in our camp.

Based on personal sightings of a variety of bears around our camp, several instances of personal property destruction, and receiving frequent feedback from guests and neighbors regarding human-bear conflict, there is no doubt that we have a bear population in our area that needs managed with additional harvest. I oppose the proposed rule to eliminate the non-resident landowner tag and forcing the non-resident landowners into the hands of the tourist camp operators. I am in favor of maintaining the current non-resident landowner tag opportunity as well as allowing BMA transfers on a case by case basis in areas where it is evident that a thriving bear population can outpace historically high harvest rates due to the high carrying capacity of the landscape. Continuing to allow the management of black bears through both programs such as the non-resident landowner tag, and tag allotments to tourist camp outfitters provides a valuable ecological and economic benefit throughout all of Ontario.