February 18, 2020 Premier…

February 18, 2020

Premier Doug Ford
Premier's Office
Room 281
Legislative Building, Queen's Park
Toronto, ON M7A 1A1
premier@ontario.ca

The Honourable John Yakabuski
Minister of Natural Resources and Forestry
Whitney Block, Suite 6630
6th Floor, 99 Wellesley St. W
Toronto, ON
M7A 1W3
minister.mnrf@ontario.ca

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

To The Public Input Coordinator,

Environmental Registry #019-1112:
Proposed Changes to black bear hunting Regulations.
Ford doubles down on bad Liberal decision

The organizations listed below are writing to express strong opposition to the proposed changes to black bear hunting regulations, namely the implementation of a permanent spring bear hunt.

History:

In 1999, Premier Mike Harris and the Progressive Conservative government ended the spring bear hunt. At that time, the Minister extended the fall hunt into mid-August, compensated outfitters and established what was considered one of the most progressive Bear Wise programme designed to resolve human/bear conflicts without taking lethal action.

Fifteen years later, in 2014, Premier Wynne and the Liberal government implemented a 2-year black bear spring season pilot from May 1st to June 15th in eight Wildlife Management Units in northern Ontario. The political excuse used for the introduction of the pilot project was to address human/bear conflicts. The Liberal government refused to acknowledge the scientific literature which demonstrated that conflicts occurred in greater numbers when food was scarce and declined significantly in food plenty years.

In 2016, Premier Wynne and the Liberal government extended the black bear spring season pilot for an additional 5-years and expanded it to include all Wildlife Management Units (WMUs) where there was an open season for black bear in the fall. The rationale for this move was to appeal to northern voters.

It is shocking to find out that the Progressive Conservative Party of Ontario would overturn an ethical and humane decision made by fellow Conservatives and so blindly follow such bad decisions about bear management as those made by Premier Wynne.

Argument against the spring bear hunt:

The arguments against spring bear hunting are well known and based in science and fact.

1. Cubs are orphaned in the spring. No matter how careful hunters might be, mistakes are made and mother bears with dependent cubs are shot and killed.

When orphaned during the spring hunt, the cubs are too small to care for themselves so they die from starvation, dehydration or predation. Ministry staff do not collect data about the number of lactating bears killed during the spring hunt. However, in the late 1990s, during the previous fight to end the spring hunt, the Ministry staff did examine hunt data and determined that approximately 274 bear cubs would be orphaned as a consequence of the spring hunt.

Determining sex of the bear is additionally compromised with the use of dogs. A paper by Thomas Beck et al titled, “Sociological and Ethical Considerations of Black Bear Hunting” addresses the issue of nursing female bears and the use of dogs during the spring hunt. The six authors of this study were all representing Fish and Game Departments from six US states.

The article reads as follows, “The biggest issue is the killing of nursing female black bears. There is no way to prevent this from happening in the spring bear season, either through hunter education or timing of season. Nursing female black bears often forge at great distances from their cubs. When pursued by hounds, the female bear usually leaves the cubs in a tree and continues eluding the hounds. When she trees, she is seldom with her cubs. Many nursing females do not bring cubs to bait sites initially but will as they grow older and she becomes less wary at the site. There remains great contention between hunters and bear biologists/managers as to the ability of hunters to accurately assess nursing status of bears. The conclusion of most biologists is that it is quite difficult to accurately determine nursing status on free-roaming black bears, even when a bear is in a tree or at a bait. The appearance of nursing females in the kill each spring supports this notion. During the last year of spring hunting in Colorado, the number of nursing female black bears checked was within three of the number predicted based on breeding rates of females and total female kill. In other words there was no selection even with regulations prohibiting the taking of nursing females.”

2. No other big game species is hunted in the spring when there are dependent young or for so many months of the year. In Ontario, bears are hunted for 6 weeks in the spring and 14 weeks in the fall (varies depending on the WMU). Five of the nine months that they are not hibernating, Ontario black bears are hunted: in the spring when they are ravenous from months of not eating while in hibernation; and in the fall when they are continuously searching for food to put on enough body weight to get through hibernation.

This is addressed in the Guiding Principles section of the Framework for Enhanced Black Bear Management in Ontario-EFFM-June 2009 which states 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.” (page 3)

3. Bear hunting and specifically spring bear hunting does not reduce human/bear conflicts as demonstrated by Martyn Obbard, the Ministry’s own bear biologist, now retired. Despite evidence to the contrary, the hunting community has long advocated the spring hunt as a way to reduce human/bear conflicts. Mr. Obbard’s research found that conflicts were not reduced because of hunting but occurred when food was scarce. Mr. Obbard et al published a 2014 paper on the subject titled “Relationships among food availability, harvest, and human-bear conflict at the landscape scale in Ontario Canada.”

In addition, after the spring hunt was cancelled in 1999, the Ministry formed an independent Nuisance Bear Review Committee to review the issue and found that “there was no evidence that spring harvest reduced nuisance bear activity.”

Finally, the government’s own framework, cited in the Environmental Registry posting, (Framework for Enhanced Black Bear Management in Ontario-EFFM-June 2009) also acknowledges that “Human-bear conflicts are known to increase in years of low natural food availability.”(page 3)

4. According to the Environmental Registry posting, the Ministry conducted two spring bear hunt pilot studies about the impact of the hunt on human/bear conflicts. It failed to release the results of those studies in the ER posting despite the obvious relevance of the findings. This government is acting in the same manner as the Liberal government, hiding data and ignoring the science in order to justify its position to permanently reinstate the spring bear hunt.

5. The effects of a rapidly changing climate on species is unknown. For example, the decline in moose populations in Ontario and various other parts of their historical range has been attributed to climate change. The Ministry acknowledges that it is difficult to estimate black bear population size and trends. It also acknowledges 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.” (IBID pg. 4)

Combine the difficulty determining population levels and problems with slow rates of recovery from low populations with unknown effects of climate change and concerns with the spring bear hunt are increased substantially. The Ministry states, “Black bear populations throughout Ontario may be affected by the predicted effects of climate change due to rising air temperatures and decreased precipitation. This could contribute to increasingly frequent droughts and less food for bears leading to increasing human-bear conflict and, potentially, reproductive failure in bears.” (IBID pg. 4)
Bear hunting and trapping on the Saugeen-Bruce Peninsula:

The Environmental Registry posting acknowledges the decline in black bear numbers on the Saugeen-Bruce Peninsula. The registry states that “human caused mortality should be reduced to support sustainability of this genetically isolated population”.

In an interview with the Owen Sound Sun Times (February 12, 2020) retired Ministry research scientist Martyn Obbard states “that the entire hunt on the Bruce Peninsula should be cancelled due to the declining number of bears…” He continued by stating that “…any further loss of black bears would further limit the genetic diversity of the Peninsula black bear population.” (https://www.owensoundsuntimes.com/news/local-news/province-proposing-to…)

For this reason, the government should extend the closure of the fall hunt to also include the spring hunting and trapping season.

Recommendations:

For all the above reasons, we recommend:

1. the withdrawal of the Environmental Registry #019-1112;
2. the reinstatement of the ban on the spring bear hunt;
3. end the spring hunt and trapping in the Saugeen-Bruce Peninsula;
4. the tightening of the fall bear hunt to include no hunting of mothers with cubs (family groups); and
5. the reintroduction of the Bear Wise programme.

Submitted on behalf of:

Animal Alliance of Canada
Animal Protection Party of Canada
Born Free USA
Canadians for Bears
Zoocheck