Tuesday February 18th 11:30…

ERO number

019-1112

Comment ID

44981

Commenting on behalf of

Texas and Sons Guides and Outfitters since 1972

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Tuesday February 18th 11:30 am, 2020
MY RESPONSE TO EBO POSTING # 019-1112
>>With regard to the Proposal to implement a regular spring black bear season.
I think it’s a long overdue decision that will help the local tourist economy, bear outfitters as well as the general public that have been plagued by nuisance bears the past two and a half decades. I’m all for it. Thank you.
>>With regard to the Proposal to address Bruce Peninsula black bear population concerns.
I’ve been down that way a few times and also have friends (including former BMA holders) there that have moved south from the Sudbury area. My friends are not pleased at all with the hunt being shortened to one week only in the spring and no hunt in the fall. Another thing they told me was there was next to no public information put forth on this subject in their area.
My recommendation for this part of the EBO 019-1112 would be put it on hold and have some local open houses and then consider it in another EBO along with other changes regarding bears.
>>With regard to the Proposal to Updates to black bear regulations to improve fairness .
1. With regard to Non-Resident property owners not being allowed to hunt without the services of an Outfitter.
I’ve been an outfitter for Black Bears since 1972 and have also as an individual hunted in jurisdictions other than Ontario for big game. Nova Scotia, Quebec, Manitoba, Alberta, British Columbia, and the Yukon in Canada and South of the border in New York, Pennsylvania, Maryland, Ohio, Indiana, Texas, West Virginia, South Dakota, Colorado and Florida. In none of these provinces, territories or states was I required to use an Outfitters services.
My personal pocket book/wallet determined the use of an outfitter rather than foolish laws. Why on earth would you restrict Non-Resident Ontario Property owners? The property taxes they pay is the same rates as Ontario property owners. They also have higher transfer taxes then residents.
Ontario taxes are high with mill rates in Northern Ontario of 0.17 and up as high as 2.18 in some jurisdictions. Its only the property owner that can get a form 33 from the MNRF to hunt in that specific WMU not all his friends or relatives. In 49 years as a Black Bear outfitter I never had a problem with the scant few of these folks in my area. Four (4) separate parties in over 40 years in my BMA’s. In fact, some of them that were able to get one (1) form 33 came to me to outfit other family members and relations so it’s a win win situation.
As near as I can come up with an amount of non-residents that make use of this is under 100 in the entire province of Ontario.
I’ve heard rumours that if these form 33’s are suspended then they will be reallocated to Bonafede licensed bear operators in each area. I do not believe such. What is the plan to give less than 100 forms 33’s to over 2000 Licensed BMA holders? That’s less than 0.05 form each! Not near enough of a significant plus to offset the negative impact of Property Owners rites and privileges.
My personal thought is that the MNRF just don’t want to bother with it any more.
Give the non-resident property owners a fair shake for their tax dollars and don’t delete this insignificant item. Thanks
2. With regard to individuals or businesses having to have a “License to Provide Black Bear Hunting Services” to provide guiding services to residents within a Bear Management Area.
I think it’s a long overdue change that will increase the fairness for all concerned. It will resolve conflict between Licensed BMA holders and unlicensed folks that probably don’t even pay any income taxes on their business ventures. This is a win win situation for everyone. Thank you.
>>There is another Major Concern I have as a Licensed BMA holder and that is the re-allocation of Vacant and Dormant BMA’s.
The MNRF has not made any available in the Sudbury/Espanola District for over 15 years. I have tried numerous times to get additional area where the BMA’s have become inactive to increase my hunting area as well as help alleviate the Local Nuisance Bear problem to no avail. All I received was a myriad of fairly lame excuses. Then it was said there is a moratorium until the pilot spring hunt is ended. Now is the time to do something about it. Perhaps the old application system should be revised some what and I would be glad to provide input into that phase of it.
These dormant properties are hindering established BMA holders from expanding as well as losing the tax payers of this Province income that could be well used by the MNRF with its limited funds. This needs to be addressed forthwith.
>>One other Major Concern I have is the method of issuing of Form 33’s. over the life and History of the BMA creation there was no limit on the amount of form 33 allocation until the Province wide spring bear pilot project. There was one exception and that was in the Chapleau District and it worked well. Where rather than restricting the form 33’s they restricted the number of bears harvested. A very sensible solution I thought. I did follow up in 2016 with telephone chats with the folks in Chapleau MNRF on this matter and they said their system worked well from both an enforcement and a sustainable harvest view.
If you remember when the Spring hunt was canceled in January of 1999 the Outfitters (BMA holders) were given a token compensation based on the number of form 33’s they had used in 1998. This seems to have carried over to 2016 when the form 33’s given to BMA holders were an average of what they had used the previous 3 years with no regard to earlier years at all. This was a band aid that did not and does not work well.
This whole process needs to be rethought and some serious effort be given to make the rite decisions. One important factor that has never been used is the experience of long time bear outfitters that goes way back to before the introduction of BMA’s and that is the knowledge that these folks can share.
In my case in particular this is my 49th year as a Black Bear Outfitter in Ontario. Do you really think if I had overharvested that I would still be in business? There are many other outfitters with experience that predates the 1999 Spring hunt cancellation that would be willing to share.
You are seriously hindering the tourism industry by limiting the form 33’s rather than limiting the harvest ratio. I figure if you have say 20 form 33’s then you can harvest 20 bears. If your normal success rate it about 30% then why would you not be allowed 60 form 33’s of if you did the calculation it would be 66.66 forms or 67. Chapleau sure had the rite idea and it worked well so the wheel does not entirely have to be reinvented.
Thank you very much.