Black bear populations are…

Black bear populations are being over-harvested in several to many WMUs in northeastern and south-central ON, exceeding sustainable harvest levels and exceeding other sustainability indicators. The spring bear hunt pilots unfortunately exacerbated sustainability concerns and to date no adequate harvest management tools on the resident bear hunts have been provided to remedy the concerns.

There are large gaps in:
• black bear harvest allocation policies;
• regulatory and procedural tools to carefully manage sustainable black bear harvests, especially resident hunts (i.e., there are no WMU-specific 1st resident black bear tag quotas, which could be distributed on 1st-come-1st-served basis, using similar approach re: additional deer tag quotas);
• transparency to stakeholders and public on the status of WMU black bear population estimates, annual trends in bear harvests by sector, and annual trends in sustainability indicators.

Mandatory registration / submission of premolar teeth from harvested black bears should be implemented such that sustainability indicators can be reliably determined at appropriate scales. Most years, less than 10% of resident bear hunters submit premolar teeth from their harvested bear(s), yet annual resident bear harvests approach 80% or more of total bears harvested in many WMUs.

The current harvest tools used by MNRF is to impose BMA operators with black bear hunting validation certificate quotas, without any WMU-specific quotas on 1st resident black bear tags for resident hunters (i.e., resident bear harvests are wide open). This inequitable approach has resulted in WMU and black bear ecological zone level bear harvests to be excessive, inappropriately managed, with bear populations being over-harvested.

The opportunity to engage stakeholders, Indigenous communities, municipalities and the public on appropriate black bear harvest allocation policies and procedures, and regulatory and procedural tools to carefully manage sustainable black bear harvests, would have best been done with the initiation of the spring bear hunt pilots. However, that did not occur and the next logical time to do so is now as the pilot spring bear hunts come to an end.

The ER proposal (https://ero.ontario.ca/notice/019-1112) to implement a regular spring black bear season, should be accompanied by analyses and lessons learned to inform and engage stakeholders, Indigenous communities, municipalities and the public on appropriate black bear harvest allocation policies and procedures, and regulatory and procedural tools to carefully manage sustainable black bear harvests. In its current form, I cannot ethically and professionally support the proposed regular spring black bear season and am therefore opposed. There should be no fear in implementing the right course of action, i.e., WMU-specific 1st resident black bear tag quotas where required – it is the right thing to do.

As indicated in the ER proposal, “Since the mid-2000s there has been ongoing collaborative research conducted on the black bear population on the Bruce Peninsula. Research indicates that there has been a decline in bear numbers and that human-caused mortality should be reduced to support sustainability of this genetically isolated population.” While it is good to see a proposed action towards addressing the Bruce Peninsula black bear population concerns, a 7-day spring season without any quota on 1st resident bear tags is highly likely to be insufficient to prevent the decline of this genetically isolated bear population. Even white-tailed deer, which have much, much higher reproductive potential compared to black bears, are afforded a 5-day gun season with 1st resident deer tag quotas on the Bruce Peninsula. There should be no fear in implementing the right course of action, i.e., WMU-specific 1st resident black bear tag quotas – it is the right thing to do. Without WMU-specific 1st resident black bear tag quotas, then the bear hunt seasons on the Bruce Peninsula should be eliminated entirely.