Public Input Coordinator…

Public Input Coordinator
Species Conservation Policy Branch - Wildlife Section
300 Water Street, 5th Floor, North tower
Peterborough, ON K9J 3C7

The Honourable John Yakabuski,
Minister of Natural Resources and Forestry
minister.mnrf@ontario.ca

Christie Curley: Acting Director of Species Conservation Policy Branch
christie.curley@ontario.ca

Premier Doug Ford,
premier@ontario.ca

September 26, 2019

To Whom It May Concern:

Comments re ERO numbers 019-0405 and 019-0406

Recommendation:

We recommend that the Minister of Natural Resources and Forestry:

1. Stop the implementation of the changes proposed by Big Game Management Advisory Committee (BGMAC) in ERO numbers 019-0405 and 019-0406; and

2. Before implementing the proposed changes to moose hunting for 2020 and 2021, implement a strategy that will protect the moose population by:

a) Phasing out calf hunting;
b) Limiting the use of all-terrain vehicles during the hunt;
c) Ending party hunting and reducing the length of the hunt to 4 weeks;
d) Continuing to monitor moose populations in relation to the changing climate; and
e) Managing habitat at the ecosystem level to protect all moose and other wild species, monitor the effects of climate change on all wildlife, including range changes, increased parasite loads, altered vegetation, invasive plant species and wildfire patterns.

Background:

We are writing to express our opposition to the recommendations made in ERO number 019-0405 and 019-0406. The Ontario’s Minister of Natural Resources and Forestry (MNRF) is revisiting a proposal to liberalize hunting of wolves and coyotes across 750,000 km2 of northern Ontario.

Thousands of Ontario residents opposed a similar proposal in 2016 because of its lack of a scientific rationale demonstrating that killing wolves and coyotes would boost dwindling moose populations. At that time the previous government abandoned the proposal.

1. BGMAC Report:
This time the BGMAC has recommended a similar proposal based on hunter concerns about wolf predation on moose.
In Recommendation #14 BGMAC states that “MNRF should address hunter concerns about the potential impacts of predation on moose populations to complement efforts to restrict hunter harvest”. BGMAC recommendations include removing the game seal requirement for wolves and coyotes and eliminating the bag limit for coyotes in northern Ontario (WMU 1- 37). It also recommends reviewing the harvest limit of two wolves per hunter per year in these WMUs to ensure that it is scientifically supported, not unnecessarily restrictive and sufficient to result in positive effects on the moose, elk and caribou population. (files.ontario.ca/mnrf-moose-management-review-bgmac-recommendations-report-2019-08-09.pdf)
The BGMAC report presents no population data for wolves, coyotes or moose or number of animals killed by hunters. The report cites no studies or scientific research papers that would support such a recommendation. Yet this exact recommendation is now posted on the Environmental Registry for public comment.

2. Ministry position does not support the BGMAC recommendation:

a) Wolves:

Studies conducted by Ministry staff show that killing wolves does not ensure increased moose populations. The document entitled, “Factors that affect moose survival”, found on the Ministry’s web site, calls into question the efficacy of such proposals. Under the sub-heading, “Results of wolf removal”, the Ministry makes the following statements: (https://www.ontario.ca/page/factors-affect-moose-survival):
“The number of moose killed per wolf pack will not significantly decrease as the pack size is reduced, so removing just a few wolves from each pack will not decrease overall predation on moose. Only the removal of an entire pack can substantially reduce predation but this practice may not be ecologically or socially desirable. Changing hunting and trapping regulations to allow more wolves to be harvested is unlikely to remove an entire pack. Pack removal often requires intensive removal techniques such as aerial gunning or poisoning applied over several years. Only in limited circumstances may small reductions in pack size result in minor reductions in predation that benefit moose populations in localized areas.
“Some provinces and states have undertaken wolf control efforts. After control measures were discontinued, wolf populations in Alaska, British Columbia, Quebec and Yukon soon recovered to pre-control levels. For example, in the Papineau-Labelle Wildlife Reserve in Quebec, wolf numbers recovered to previous levels less than a year after a 71% reduction in wolf numbers. Once wolf populations recover, moose populations typically return to pre-control levels.
“The Strategy for Wolf Conservation in Ontario directs wolf management in the province. The goal of wolf management is to ensure ecologically sustainable wolf populations and the ecosystems on which they rely for the continuous ecological, social, cultural and economic benefit of the people of Ontario. Achieving this goal requires the consideration of both ecological and social values and interests.”
The recommendation by the BGMAC is entirely at odds with the Ministry whose studies showed that killing individual wolves would simply not reduce predation on the moose population and that changes to hunting and trapping regulations to allow more wolves to be killed would not reduce predation for the very same reason.

b) Coyotes:

In addition, eastern coyotes are not major predators of moose. Under the section on “Factors affecting moose survival”, the Ministry sites wolves, not coyotes, as predators of moose.
Since the Ministry’s own website states that coyotes are not listed as having an impact on moose populations. The question becomes why is the BGMAC and the Minister targeting coyotes for increased killing? All indications are that BGMAC is using the guise of moose conservation to appease hunters who incorrectly see coyotes and wolves as competition for moose.

c) Moose:

The Ministry’s own website clearly identifies the impact of hunting on moose populations by comparing the difference between hunting moose in the early 1980s and today. The chart below shows that there are very real hunting issues that it are detrimental to the moose population. These issues need to be addressed. They include: a longer hunting season; increased road access in many WMUs; more use of all-terrain vehicles are now commonly used; hunting parties are allowed; the calf harvest, which was limited in the 1980s is now substantial in many WMUs; and hunter success rate has increased substantially.

MNRF Chart Comparing Factors Affecting Moose Survival from the early 1980s to today
(Source:ontario.ca/page/factors-affect-moose-survival#section-4)
NOTE: There are moose population numbers but not the
number of moose killed by hunters.

Moose hunting trends in Ontario: Moose hunting has changed a great deal since the early 1980s, when the selective harvest system was introduced. Hunting success rates for moose are higher today. As a result, fewer adult validation tags can be issued today to achieve the same level of moose harvest.

Early 1980s Today
Moose population 80,000 91,200 (115,000 peak)
Hunters 100,000 91,000
Season length 2-4 weeks 2-3 months
Road access Less road access in many WMUs Increased road access
All-terrain vehicles Limited use Very common use
Wireless communication Limited use Very common use
Party hunting No party hunting (no party harvest) Party hunting
Success rate 20-30% gun; 5-10% bow 40-50% gun; 20-30% bow
Calf harvest Very limited Substantial in many WMUs
Tags Est. 47,000 adult validation tags (1984) 10,757 adult validation tags for
resident hunters (2018)

Conclusion

The BGMAC provides no population data or scientific papers to support its recommendations to increase the wolf and coyote hunt and since the Ministry states that such hunting will not reduce wolf predation on moose and since coyotes are not significant predators of moose, we urge the Minister to adopt our recommendations and implement a comprehensive moose protection programme.

The BGMAC has not addressed the changes in moose hunting identified by the MNRF. We urge the Minister to address those issues before trying to determine how many moose can be killed during the moose hunting season.

Sincerely,

Animal Alliance of Canada

Animal Protection Party of Canada

Born Free USA

Canadians for Furbearing Animals

Humane Society International/Canada

Ottawa-Carleton Wildlife Centre

Zoocheck