February 16, 2020 I am…

February 16, 2020

I am writing in strong opposition to the PROPOSED CHANGES TO BLACK BEAR HUNTING REGULATIONS – Environmental Registry of Ontario Number: 019-1112.

Since the termination of the “Spring Black Bear Season” in 1999, groups such as the Ontario Federation of Anglers and Hunters and some tourism operators have encouraged the public to report any and all “problematic” human/bear interactions to the MINISTRY OF NATURAL RESOURCES AND FORESTRY (MNRF) or police. Thus, people have related incidents that would previously have been unreported (e.g., bears moving through private, rural properties), which were then highlighted by the media. Consequently, negative incidents have been emphasized and exaggerated, giving the impression that there has been both an increase in black-bear populations and in troublesome interactions between bears and people since 1999. Establishment of the MNRF Nuisance Bear Review Committee further encouraged input on any negative human/bear interactions, which likely overstated the true numbers of these occurrences and resulted in inaccurate data.

Any conclusions that are drawn from this imprecise reporting data are, therefore, highly suspect because there is no way to determine whether or not there has been genuine growth in the number of troublesome human/bear contacts, or if this “supposed” growth is simply a result of an increase in the number of incidents that have been reported. It is also noteworthy that many so-called problematic encounters that people have with bears are the result of carelessness on the part of humans (e.g., improper garbage disposal – which may encourage bears to come in close proximity to cottages and homes). This is why the “Bear Wise” program has been such a useful educational tool.

During extremely dry summers in Ontario, the quantity and variety of food sources for bears has been reduced. Consequently, bears have had to travel further (and to non-traditional sites) in search of food, which increased the likelihood that people would see them. This is not necessarily indicative of an increase in bear populations, but simply a reflection of the number of bear sightings. For example, several people may have several different sightings of an individual bear – yet, this could be reported as sightings of multiple bears. One person could also have multiple sightings of an individual bear, and again this could be assumed to be multiple bears, thereby inaccurately inflating bear population numbers.

I can also comment on human/bear interactions from an anecdotal standpoint, because I live in a rural area near Parry Sound. Since 1999, my family has seen fewer bears – either on our property or during our wilderness excursions (e.g., hiking and canoe trips). I have also previously lived in (or near) the pilot-project target communities of Timmins, Thunder Bay, and North Bay, and have never experienced a negative encounter with a black bear. In addition, I know many people who currently live in all of the pilot-project communities. None of them (or their friends and acquaintances) have personally experienced an increase in the number of negative human/bear interactions over the last two decades. They have, however, confirmed that an embellished and inaccurate approach has been utilized in their districts to artificially increase the number of negative human/bear interactions which are reported.

Furthermore, there appears to be substantial difficulty in accurately determining baseline bear populations. I’ve read estimates from differing sources that vary significantly in this regard. This imprecision therefore results in “sustainable” harvesting figures which result from guesswork, at best. Add to this the fact that it is extremely difficult to accurately determine the mortality rate for bears within a particular year from natural causes or human activities (e.g., traffic fatalities, poaching). Decisions regarding the number of bears which can be harvested on an annual basis (while maintaining a biologically-healthy population) are, therefore, based upon insufficient data. The MNRF reports that bear populations are “healthy”, but provides no evidence to support this assertion.

The “Spring Black Bear Season” is also a significant problem from a biological standpoint. Although harvesting female bears with cubs is prohibited, it is not always possible to determine the gender of a bear from a distance (and female bears do not always keep their cubs where they can be seen by hunters). If mother bears are killed, their orphaned cubs will mostly likely die, as well. Hence the bear population is depleted in two ways. The difficulty in attempting to estimate this depletion arises from the fact that the number of orphaned cubs is really an unknown entity. Another unknown factor regarding mortality is the number of bears which are killed annually due to poaching. Thus, the number of black-bear fatalities cannot be determined with any degree of precision. Again, this makes it extremely problematic to accurately determine the mortality rate for bears, thereby resulting in harvesting figures which are determined from inaccurate and/or incomplete data.

Another serious issue regarding the “Spring Black Bear Season” is that it is simply unethical. How can one possibly assert that it is "sporting" to place bait to lure weak and hungry bears, who have recently emerged from hibernation, at sites where hunters are waiting to shoot them? Killing bears when they are at their most vulnerable (and when some have cubs) indicates a definite lack of concern with respect to ensuring that hunting activities are implemented in a sustainable, ethical, and humane manner.

Despite the fact that hunters and some people in the tourism industry desire certainty on the future of the spring season, their self-serving demands should not be the over-riding concern regarding the proposed reinstatement of the “Spring Black Bear Season”. They have access to ample bear-harvesting opportunities during other times of the year.

In conclusion, there is a lack of evidence to demonstrate that killing black bears during the spring would not be problematic with respect to maintaining biologically-sustainable bear populations in Ontario, or that this practice will improve human safety and/or reduce nuisance-bear activity. Supporting materials listed on the ERO website are simply MNRF policy documents and regulations. They include no studies from the Ministry (or anyone else) to support this proposal. Thus, in keeping with ecological precautionary principles, the “Spring Black Bear Season” should never be reinstated. Furthermore, the current pilot program should be discontinued in all provincial Wildlife Management Units in which it was established in 2014 and 2016.