I wish to comment on ERO #…

I wish to comment on ERO # 019-3685: the proposal to allow the issuance of licences for new dog train and trial areas and the transfer of licences.

The practice of penned hunting under the guise of “training” hunting dogs, exercising hunting dogs in the off season, and running competitions between these dogs is a truly reprehensible and cruel practice – not one that is suited to the 21st century in the Province of Ontario.

Certain wildlife species (cottontails, snowshoe hares, red foxes, and coyotes) are trapped and put into pens with dogs, where they are torn to pieces while still alive. How can this be considered training? In any other context, this abhorrent treatment of native wildlife would be met with significant penalties from the Ministry of Natural Resources and Forestry. Yet in an attempt to mollify hunters (and special interest groups, such as the Ontario Federation of Anglers and Hunters), this same Ministry wants to expand the practice in Ontario by: “the issuance of licences for new dog training and trial areas through a one-time 90-day application period; and, the transfer of licences to own and operate a dog train and trial area to new persons”.

Regardless of the requirement “to conform to strict regulatory standards”, this practice and the proposal to expand such operations is cruel and barbaric.

In addition, the assertion that “the anticipated environmental consequences of the proposal are expected to be neutral” completely misses the point of how incredibly brutal and savage the training of hunting dogs using penned animals actually is.

There are only two legitimate solutions:

1. Close all areas currently regulated for these “training” practices under the Fish and Wildlife Conservation Act, 1997.

2. Do not permit the issuance of licences for new dog train and trial areas (and the transfer of existing licences) to occur.

To do otherwise would be to fail in one of the Ministry of Natural Resources and Forestry’s primary missions: protecting Ontario’s wildlife and biodiversity.