On behalf of the Ontario…

   On behalf of the Ontario Federation of Anglers and Hunters (OFAH), its 100,000 members, subscribers and supporters, and 740 member clubs, we have reviewed the discussion paper “Building a Wildlife Management Strategy for Ontario” and have the following comments.

  General Comments

 There is general support for the purpose of this discussion paper which is to engage stakeholders, Indigenous communities and the general public, and seek input on the development of a draft wildlife management strategy. We also acknowledge the value in developing a policy framework to help clarify the roles of existing wildlife management policy but, more importantly, we believe this strategy can provide stand-alone policy direction for actively managed wildlife species (e.g. game species).

  We appreciate the Ministry of Natural Resources and Forestry’s (MNRF) mandate to manage all of Ontario’s wildlife resources and believe that all wildlife are important components of the province’s biodiversity. Ontario’s Biodiversity Strategy effectively outlines objectives and principles for biodiversity conservation, which ensures the conservation of non-game wildlife species. There are fundamental differences in the way we manage game species relative to other wildlife, and therefore they must be separated from a strategic guidance perspective. We strongly believe the Wildlife Management strategy must be more focused in scope in order to be effective and to avoid duplicating the content of the Biodiversity Strategy.

  Note: We will refer to wildlife management of game species as ‘wildlife management’ throughout the remainder of our comments.

  Purpose and Scope

 The purpose of the strategy should be clear. We strongly recommend replacing “activities related to wildlife” with “hunting and trapping as activities…” The purpose of the Provincial Fish Strategy, while similar, clearly includes ‘fishing’ as an activity. Why is there a reluctance to specifically identify hunting and trapping as activities?

  Issues such as species at risk, climate change, and invasive species are all relevant and important to consider in this strategy. However, they must be looked at through a wildlife management lens for two reasons: 1) all of these issues already have broader strategic policy direction; and 2) we are concerned that a broad focus in this strategy will not allow the MNRF to effectively develop tangible objectives for actively managed wildlife species that are needed. We appreciate the three levels of guidance, but we would also like to see “broad” replaced with “long-term” aspirational goals; recognizing that some of the goals will require time and appropriate planning to achieve.

  Although the questions posed in the Discussion Paper are very broad and some of them give the impression that the MNRF is asking for specific wildlife management changes (though it states that this is not the intention of the strategy), we have made every effort to answer them appropriately.

 1)Which wildlife management aspects or activities (e.g. hunting, trapping, protection of property, possession, buying, selling of wildlife, wildlife health, habitat) do you believe are most important to address within a Wildlife Management Strategy for Ontario?

  As mentioned, we do not see value in duplicating the Biodiversity Strategy. The Wildlife Strategy should focus on the MNRF’s role in the activities listed above, but should also include wildlife in captivity.

  The Strategy should also emphasize a reliance on adaptive management and a commitment to investing in monitoring and inventory programs to ensure sustainability of populations and assess the effects of management actions.

  2)How do you think wildlife management in Ontario might need to change to respond to the trends

 and issues identified in Section 4?

  We are encouraged to see a willingness to broaden participation in hunting and trapping in response to changing demographics. The financial sustainability of our provincial fish and wildlife program is determined by participation in sustainable use activities, and the MNRF must anticipate and address the factors that might jeopardize the sustainability of the Special Purpose Account.

  We support an increased reliance on partnerships, but this should not be limited to habitat management. We recommend that the MNRF seek out and foster partnerships for all manner of programs, including mentoring and education programs, citizen science initiatives, etc.

  We agree with the need to encourage participation in wildlife viewing, but it will be important for the MNRF to actively demonstrate to the public that consumptive uses (hunting and trapping) are compatible with, and beneficial for, non-consumptive uses such as wildlife viewing.

  The Discussion Paper highlights the benefits provided by new technologies for the timely and efficient collection and analysis of information, as well as the opportunities to increase citizen science activities. The three opportunities associated with this driver all benefit the MNRF in some way, and the potential benefits to the public are largely ignored. New technologies also make it easier for the MNRF to report back to the public, which helps to foster support for the submission of information in the future. The Strategy should include a commitment to improved two-way communication between the public and the government. A prime example is the timely communication of hunter activity and harvest information to the public.

  We are encouraged to see recognition of the socioeconomic benefits of modern hunting and trapping, and we sincerely hope this important driver (and opportunities) will be carried forward in the development of the strategy. We believe there is an opportunity to further enhance hunting and trapping opportunities; and there should be a business component that acknowledges the need to invest in resource management in order to optimally use and benefit from wildlife resources.  The MNRF should also commit to ensuring that it is getting fair value for its natural resources (land use permits, stumpage fees, etc.).

  3)Do you agree with the goals and guiding principles in Section 5? Do you have ideas for other goals or principles that could be added?

  In general, we support the stated goals, but we still have concerns with some of the guiding principles, specifically Principle 1. Many of the MNRF’s management activities can only occur at a particular scale (e.g. the allocation of moose and deer tags can only occur at the WMU scale). We support, in theory, the concept of managing at broader scales as long as it does not jeopardize the MNRF’s ability to ensure the sustainability of wildlife populations. Also, it is not clear what is meant by “Use social and economic factors to adjust scale…”

  In order to facilitate adaptive management as described in Principle 4, the MNRF must commit to investing in improved monitoring and assessment. Adaptive management is impossible in the absence of timely, detailed information. This information is required to assess and evaluate management actions and provide an understanding of what changes, if any, are needed.

  We appreciate the recognition of the roles that hunters and trappers have (and continue to) play in the sustainable management of wildlife. Hunting and trapping receive considerable ‘recognition’ in a historical context, is referenced as an opportunity, and is listed as Principle 5; however, we believe this section could be further strengthened by highlighting the current status of actively managed wildlife species to highlight the sustainability of modern hunting and trapping activities.

  4)What are some actions and activities that government, organizations and individuals could take

 to improve wildlife management in Ontario?

  We strongly believe there is significant potential for the MNRF to do more than simply recognize the ‘interests and contributions of hunters and trappers.’ We recommend active promotion and marketing of the benefits and relevance of regulated hunting and trapping. This would help to better inform social attitudes and increase social acceptance and understanding of the benefits of regulated hunting and trapping. The MNRF has a key role to play in this regard; therefore, active promotion and marketing should be a priority objective.

  5)What do you think are the advantages of MNRF moving toward managing wildlife over broader areas and longer time frames?  What aspects will require particular caution or attention?

  While we appreciate that the Discussion Paper introduces the concept of managing wildlife at broader scales with new wildlife landscape zones (WLZ), there is still not enough information for us (or the public) to comment on the advantages/disadvantages of this new approach.  It is vital that the MNRF provide the public with the background information that was used to delineate the WLZs – without this information, the public will continue to question the need for, and validity of these zones. To our knowledge, the primary benefit of these zones is administrative in nature; these zones will not contribute to wildlife conservation, the sustainability of wildlife populations, or an optimization of the social, cultural, recreational and economic benefits of our natural resources.

  In closing, healthy ecosystems and wildlife populations will benefit all Ontarians. The OFAH strongly believes the following should be included within a wildlife management strategy for Ontario: science-based decision making, commitments for additional funding, opportunities for community-based conservation, commitments to strengthen effective collaborations and partnerships, a statement of deliverables which are achievable, measurable, and associated with a timetable.

  We appreciate the opportunity to comment and look forward to working with the MNRF on the development of a wildlife strategy for Ontario.

[Original Comment ID: 196678]