I oppose these changes for a…

I oppose these changes for a number of reasons and urge the government to not implement this plan.
First, the Spring Bear Hunt results in orphaned bear cubs. There is no denying this - hunters make mistakes and kill mothers with cubs even though regulations were designed to prevent this from happening. Mother bears are known to forage without their cubs in the spring and the ability to determine the sex of a bear is not easy and will result in females being killed and cubs being orphaned. This is inhumane but also adversely affects bear populations.
The proposal recognizes populations being in decline on the Bruce Peninsula but fails to limit or acknowledge the hunting impacts in other areas of the province. The fall hunting season has doubled in length in some places since the spring hunt was cancelled so to reinstate the spring hunt now means that the bears are under pressure for a much longer time each year (the fall season is from 2 1/2 to 3 months long depending on the location and now adding another 6 weeks in spring increases the total hunting season to 4-5 months) This will add stress that has not been seen since before management strategies were in place and I'm not at all convinced that it allows for sustainable bear populations.
It is known that black bears have one of the longest reproductive cycles of any land mammal in North America. Females only have cubs every 2 to 3 years and do not reach breeding age until they are 5 years old. Bear populations are known to be vulnerable and to fluctuate in seasons when food is scarce and due to hunting pressure. I have not seen anything in the regulation about monitoring of populations. Putting additional pressure on the bear populations at a time when we are experiencing climactic changes is not a responsible approach given the difficulty of knowing actual population data.
In the government documents on management it clearly states: "life history traits of black bears make it difficult to assess the effectiveness of landscape level management actions and the ecological sustainability of populations. The adequacy of inventory, monitoring and assessment activities to support management decisions needs to be routinely reviewed to ensure that black bear populations are sustained and that there is an appropriate landscape and ecologically based approach...and,
"research has shown that no more than 40% of female bears should be represented in the annual harvest if the management objective is to maintain current population levels (Yodzis and Kolenosky 1986, Howe et al. 2007, McLaren et al. 2008)"
In data gathered regarding hunter harvesting, it was found that already 30-35% of bears killed were female so it seems very risky to me to open up the spring hunt and It's crucial that decisions of this sort are based on ecological principles and accurate data and not economically driven. The Enhanced Black Bear Management Strategy of Ontario clearly states this : "Ongoing monitoring and research is critical for informed decision-making, sound policy development and implementing an adaptive management approach. Research should focus on addressing key knowledge gaps and risk assessment, as well as evaluating the effects of specific management actions on bear populations on the landscape and on their habitat. Population management decisions, and the assessment of their impacts, should occur on an ecologically based, landscape level."
In summary, opening up the spring bear hunt is not following these ecological principles. It fails to acknowledge actual pressures on bears that are affecting their populations.
A quote from the management documents (EFFM 2009)
"1. 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.
2. It is difficult to estimate black bear population size and trends.
3. Humans and bears can be in conflict, and there is a need to find ways to reduce human-bear conflicts while recognizing the importance of bears from a biodiversity perspective.
4. Black bear harvest is currently managed under a relatively open allocation system where tourist outfitter harvest can be limited."
and later in the document,
"Black bear populations throughout Ontario may be affected by the predicted effects of climate change due to rising air temperatures and decreased precipitation. This could contribute to increasingly frequent droughts and less food for bears."
In conclusion, I would like to see current and future management policies reflect these realities.
Black bear management needs to focus on reducing human-bear conflicts by investing in coexistence education. Policies such as bear baiting increase the incidence of "problem bears" and the number of bears killed because of problem behavior creates additional stress on bear populations. Please base management decisions on sound data and ecological policies.