January 28, 2020 I would…

January 28, 2020

I would like to provide comments on the “Proposal to implement a regular spring black bear season”. I am neither opposed to, nor in favour, of the Proposal. I am not a hunter, so bear hunting has no direct impact on me. I am not opposed to hunting. I understand and accept the recreational aspects of hunting. I am well aware of the economic benefits created by bear hunting, particularly the significant non-resident hunting that occurs through many tourism operations. I am an avid user of the outdoors in Northern Ontario and participate in activities where I have come into contact with black bears.

I believe that all harvest of natural resources, such as wildlife, fisheries or forests must be done in a sustainable manner which allows firstly for the continued existence of healthy populations and secondly for economic prosperity. Ontario contains a significant wealth of natural resources. These resources make Ontario a great place to live and have been the life-blood of communities throughout the history of the province.

I have read a discussion of bear ecology and tactics associated with dealing with so called “nuisance bears” as published by the Ontario Ministry of Natural Resources and Forestry on the internet at https://files.ontario.ca/mnrf-cr-black-bear-ecology-life-systems-intera….

I am aware, because I live in Northern Ontario, that when humans and black bears come into contact there can be conflict. Humans recreate in wild areas and live in places that are increasingly rural, therefore natural habitat for bears and recreational and living space for humans overlaps in many circumstances. For this reason, bears often become what some people see as a nuisance and, in some cases, I believe people perceive that due to the circumstances of conflict, that the bear population is quite robust and perhaps even too high.

I read that black bears are omnivores, meaning that they eat both plants and animals. Approximately 85% of a black bear’s typical diet is plant material, while the remaining 15% is made up of animal protein. Black bears will eat almost anything, such as grubs from a bumblebee nest, bird eggs, ants, voles, grasses and berries (L.J. Landriault, 2000). Berry crops account for a large part of a bear’s diet and the potential for nuisance bear activity increases in years when berry crops fail and the animals search for alternate food sources (L.J. Landriault, 2000). I understand that occurrence rates for human-bear conflict can be closely tied to the health of berry crops, with bears straying into rural and urban populated areas in search of alternative food supplies during times of low berry availability. I suspect that this may lead to a misunderstanding of bear population numbers (a perception that numbers are higher than they actually are) when human-bear conflicts increase.

The material that I read also speaks to the reproductive rate of black bears. Female black bears in Ontario may produce their first litter when they are five years old, but the average age of first reproduction is about six in central Ontario and seven in northern Ontario (L.J. Landriault, 2000). In the past in Ontario bears were considered a threat and even had a bounty placed on them until 1961 (Ontario 2009).
I note from the introduction to the Proposal that “Ontario is home to a healthy black bear population”. I see no evidence to support this statement within the Proposal, either in the details of the Proposal or within supporting documents. I would have thought that following a seven-year “Black Bear Pilot Project” that any “Proposal to implement a regular spring black bear season” would include an analysis of information gained through the pilot project and an assessment of the health of the black bear population. I see no such analyses in the Proposal.

I looked at the Regulation Proposal Notices for the “Black Bear Pilot Project” from February 25, 2014 and October 30, 2015 - EBR Registry Numbers 012-0981 and 012-5485. These Proposal Notices contain the following wording:

“The proposed pilot would provide additional data with which to assess the impacts of the spring black bear hunting season and help inform long-term black bear management activities. The pilot is also expected to increase the economic benefits derived from bear hunting for tourist outfitters and local economies. The pilot would begin in the spring of 2016 and end June 15, 2020”.

“The five-year pilot would include efforts to assess the impacts of an early black bear season in reducing human-bear conflicts in northern communities. Generally, the pilot would be assessed in a number of ways including: monitoring the number of bear hunters and the number of bears harvested, tracking the number and type of calls to the Bear Wise reporting line, working with municipalities to identify changing trends in human-bear encounters and to explore ways to reduce human-bear interactions, stakeholder perspectives, economic benefits, and other associated factors (e.g., variation in spring green-up date, and variation in availability of natural foods)”.

This wording from the original Proposals supports my expectation that I would see evidence of “additional data” and information related to the “number of bears harvested” in the current Proposal.

In the supporting materials for the current Proposal, I see a document titled Black Bear Management Framework. This document shows that it was updated in December 2019, so I assume that it forms the current basis forå managing black bear in Ontario. I did a further document search and found a document titled Enhanced Framework for Black Bear Management in Ontario. This document is dated June 2009 and appears to be quite similar, so I assume that the December 2019 document represents an update of the previous “Enhanced Framework”.

The 2019 Black Bear Management Framework includes guiding principles which include the statement: “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”. Later it goes on to say under Challenges 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”.

Another document I found separately, titled Backgrounder on Black Bears in Ontario, and dated June 2009, contains a similar statement that “black bear populations are vulnerable to over-harvest because they are a long-lived animal, reach sexual maturity relatively late in life, have a low reproductive rate that is physiologically dependent upon environmental conditions (food), and are most sensitive to changes in adult survival, particularly survival of adult females. For these reasons, their harvest must be managed carefully”.

The 2019 Black Bear Management Framework contains a myriad of Strategies and Tactics for the management of black bears and their population. These appear to be very similar to those in the 2009 Enhanced Framework.

There are several Strategies and Tactics that relate to monitoring, managing and harvesting black bear populations.

Tactic 1.1.1 states “Establish and maintain a network of population monitoring stations across black bear range to monitor population trends. Utilize recent advances in technology (e.g. DNA sampling and analysis) to validate and enhance population monitoring techniques”.

Tactic 1.4.1 states “Use landscape level and ecological considerations in the development of black bear population objectives and determination of sustainable harvest levels”.

Tactic 1.4.2 states “Finalize a system of ecologically-based harvest assessment indicators to provide tools to assess and manage the impact of harvest on black bear populations on the landscape”.

Tactic 1.5.2 states “Include local objectives that identify cultural, economic, social and biological management considerations of black bear as an important part of the natural ecosystem, an opportunistic predator, a big game species, and a source of human-wildlife conflict”.

These are the kind of tactics I would expect to see and I would expect that the Ministry of Natural Resource and Forestry would be funded to undertake them. Since these tactics have been in place since 2009, I would also expect to see some results and would expect to see the results used to develop and rationalize the Proposal.

The challenges listed in Section 5.0 of the Black Bear Management Framework seem like the kind of topics that would be addressed in the “Proposal to implement a regular black bear spring hunting season”.

I wonder why the “Proposal to implement a regular spring black bear season” does not include information related to any assessment of the population that has been done that would support the opening statement of “Ontario is home to a healthy black bear population”. And also why there is no mention about how the black bear harvest system is managed to ensure not only economic and recreational benefits, but also the sustainability of the population. These are things that are suggested as tactics in the Black Bear Management Framework.

I note the Proposal includes restrictions on hunting in the Bruce Peninsula due to concerns regarding the health of the black bear population. What is this based on and was similar information used to determine that the populations are healthy elsewhere?

I also do not see any discussion of harvest strategies. I read about the basics of the harvest system in the legislative supporting material. This does not provide a clear explanation of how the Ministry uses knowledge of the population to decide how many bears should be harvested or how to allocate harvest opportunities amongst competing interests. I understand that any Ontario resident purchasing a bear-hunting license is entitled to harvest a bear. Doesn’t this mean that there really is no control at all over the number of bears that could be harvested? What about non-residents harvesting bears through resource-based tourism operators? Is there an allocation and control system in place to manage the number of animals harvested and the impact on the population? How many bears were harvested during the Black Bear Pilot Project? Is that harvest number sustainable in the long term?

The Black Bear Management Framework speaks to the low reproductive rate of black bears and the potential vulnerability of the population to over harvest. It would seem to me that it would be paramount to have an assessment of population health and a corresponding harvest allocation and control system in place to ensure the long-term sustainability of black bear in Ontario. An assessment of population health would include factors spoken to in the Black Bear Management Framework such as population distribution, sex ratio, age ratio and the rate and impact of commercial, recreational and subsistence harvesting.

I respectfully suggest that prior to finalizing the Proposal as presented, that additional work is required to provide the following:

1. A robust assessment of black bear hunting over the past 7 years of the “Black Bear Management Pilot”, including an estimate of the rate of harvest.
2. An accounting of the health of the black bear population in Ontario.
3. A discussion of the harvest allocation system, with a clear explanation of the methodology for the control of harvest.

This information should form the basis of a revised Proposal with much stronger rationale and actual evidence of analyses to support decision-making.

Without such additional information, I submit that there is no basis for the statement “Ontario is home to a healthy black bear population”, which is the underpinning for the Proposal. As written, the Proposal appears to have no rationale for what appears to be a relatively unlimited harvest of black bears.

I am concerned that with the combination of an historic fear of bears; common human/bear conflict situations; a perception of high populations: and low reproductive capacity of black bears, that the bear harvest program in Ontario could be leading to a potentially lethal reduction in the bear population.

As I stated at the outset, I am not opposed to hunting. In fact, I believe there are many positive benefits to the harvest of natural resources, based on wise management using appropriate information and controls. I believe that this can be the case for bear management in Ontario, but I am not convinced by anything written in the Proposal or contained in the supporting materials.

References:

L.J. Landriault, M.E. Obbard and W.J. Rettie. Nuisance Black Bears
and What to do With Them. NEST Technical Note TN-017, December 2000

Ontario Ministry of Natural Resources and Forestry. Black Bear Management Framework. December 2019.

Ontario Ministry of Natural Resources. Framework for Enhanced Black Bear Management in Ontario. June 2009.

Ontario Ministry of Natural Resources. Backgrounder on Black Bears in Ontario. June 2009.