For public posting, non…

For public posting, non-confidential/personal information contained herein:

Thank you for the opportunity to comment on the ERO #019-4637 (Proposal to simplify and align provincial white-tailed deer hunting seasons).

I'd like to preface my comments with an indication of my expertise on the topic of deer management. I'm a wildlife ecologist with scientific publications specific to cervid management and ungulate ecology more generally. I live in WMU 84 and have spent extensive time afield monitoring the status of deer populations in WMU 84 and WMU 85.

With this in mind, I'd like to comment on changes proposed to the specific WMUs that I am most familiar with. My input is provided under the two proposed changes that I feel compelled and knowledgeable enough to provide comments:

(1) "Extend the gun season(s) by 1 or 2 days in WMUs 28, 29, 31, 35, 36, 37, 38, 39, 40, 41, 42, 44, 45, 53B, 82A, 82B, 83A and 84 to end on a Sunday."

I am not in support of the suggested changes for WMU 84, and my reasoning is outlined below:

The proposed change has two consequences. Firstly, the gun season will be extended by one day, providing an additional day of opportunity for hunters to be successful; in essence, the season will be extended by ~16.6% (1/6). Secondly, the extension applies specifically to a Sunday, when more prospective hunters will be available to hunt (given work schedules). These two factors combined mean that the hunter effort will increase in these WMUs and result in higher success rates during the season (both gun and bow) as a whole, and more particularly during the gun seasons.

At the most basic level, in WMU 84, hunter numbers and effort and hunter success rates relative to local deer abundance already exceed values that allow for healthy and stable deer populations in the area and an enjoyable hunter experience for those gun hunting in WMU 84. A number of factors contribute to this:

WMU 84 is a unique WMU compared to most Southern Ontario WMUs making deer populations especially vulnerable to an increase in hunter effort for the following reasons:

Firstly, WMU 84 is very large and encompasses more variable deer habitat compared to most other south-western Ontario WMUs. Four of the Seven Townships in WMU are dominated by intensive agriculture and have scattered, discontinuous, and low percentage cover for deer (Huron-Kinloss, Kincardine, Saugeen Shores, Arran-Elderslie Townships). Areas with discontinuous and low percentage deer cover are vulnerable to over-exploitation through hunting. During the rifle season (prior to deer migration to their wintering areas), the small woodlots are hunted with high success by rifle hunters.

Secondly, an extension of the muzzleloader season by one day will increase harvest rates and stress on deer that are already entering a stressful part of their annual cycle as they congregate in large numbers in wintering areas.

Lastly, hunters occupying and hunting private land in WMU84 do not modify their hunting effort or hunting 'territories' according to changes in deer abundance. As with most areas of Southern Ontario dominated by private land, individual hunters and hunter groups ('gangs') are strongly traditional in the lands they hunt, irrespective of deer abundance. This means that when areas of small woodlots are depleted of deer, hunter effort does not change much, and it is not uncommon for entire family-groups (and sub-populations) of antlerless deer to be harvested from a given area. The body of science studying the consequences of such removal all indicate that areas that have had family-groups of antlerless deer removed sustain chronic depopulation of these areas, as female deer do not broadly disperse from where they were born and do not readily immigrate to new areas to re-populate fragmented habitats. An added day to the gun hunting season makes matters worse for an issue that has been ongoing since southern Ontario's deer management moved from a system where applications for antlerless deer licenses were met with limited success (low antlerless quotas) to the current situation that has prevailed since the early 2000s where antlerless deer draw applications are awarded with 100% success. Keep in mind that in the early 2000s (circa ~2005) the antlerless quota for WMU 84 went from 1,800 antlerless deer tags issued to 3,200, a 77% increase in antlerless deer tags circulating in WMU 84. Since that time, deer populations in WMU 84 have fluctuated, but deer abundance has been markedly lower than their peak between 2005-2007. The trouble is that uninformed hunters assume that they would not be issued antlerless licenses if the populations were not able to sustain the hunting, and they are unaware of the fact that deer abundance varies greatly across the large scale of WMU 84.

In summary, deer populations in WMU 84 and the quality and enjoyment of the hunting season for deer hunters in WMU 84 will all suffer from an extension in the number of days of the deer gun season (whether that be both the rifle and muzzleloader season, or just an extension for one of these seasons).

I would however support the extension of the season (rifle only - not muzzleloader) to include the Sunday if the antler less deer quota in WMU 84 were reduced to 1,800 allocations for WMU 84. This is in line with the quota that existed prior to 2005 and that resulted in more predictable deer population abundance and, anecdotally, a higher level of hunter satisfaction (hunter saw more deer, and were able to be more selective in the deer that they shot). Hunters should also be educated as part of the annual hunting regulation summary on the consequences of killing antlerless deer. Especially the consequences of orphaning fawns, shooting females in prime reproductive age, and the consequences of removal family groups which result in prolonged depopulation of deer in fragmented habitats.

A change that would be prudent is to divide WMU 84 into two WMUs reflecting the deer habitat features within the WMU.

(2) "Permit the use of bows during the gun season(s) in WMUs 53B, 69A2, 70, 76A-E, 77A-C, 78A-B, 79C-D, 80, 81A-B, 82C, 85A-C, 86A-B, 87B-E, 89A-B, 90A-B, 93A-B, and 94B, while requiring the existing safety protocols (e.g. hunter orange)."

I support this change.

This proposed change will have little negative impact on the deer populations of the various Controlled Hunt WMUs and will offer hunters the choice about the method they wish to hunt deer in the WMUs. Bow hunters generally have lower successful harvest rates and higher rates of non-recovery of deer that are shot. Combined, I do not anticipate any material change in the actual deer harvest in the WMUs for which these changes are proposed.