November 17, 2016…

   November 17, 2016.

  TO:The Honourable Kathryn McGarry

 Minister of Natural Resources and Forestry

 Suite 6630, 6th Floor,

 Whitney Block, 99 Wellesley Street West,

 Toronto, ON  M7A 1W3

 P:  416-314-2301   F:  416-325-1564

  FROM:Lia Laskaris, Director

 Animal Alliance of Canada

  Liz White, Leader

 Animal Protection Party of Canada

  Barry MacKay, Canadian Representative

 Born Free

  Lesley Sampson, Co-founder

 Coyote Watch Canada

  Hannah Barron, Director,

 Wildlife Conservation Campaigns

 Earthroots

  Rebecca Aldworth, Executive Director

 Humane Society International/Canada

  Sadie Parr, Executive Director

 Wolf Awareness Inc.

   Response to EBR Registry Number: 012-8249

 “Building a Wildlife Management Strategy for Ontario: Discussion Paper”.

  Thank you for the opportunity to comment on the Building a Wildlife Management Strategy for Ontario: Discussion Paper.

  Recommendations:

  1.Amend the title to read “Building a Humane Wildlife Management Strategy for All Ontario: Discussion Paper”.

  2.Develop aspirational goals that are: reflective of the ecological crisis facing Ontario’s environment and wildlife; proactive in protecting wild species; and inclusive of different interests and perspective.

  3.Redefine "management".  Management is a tool that should be used for the primary objective of conserving functional, resilient ecosystems and wildlife populations, particularly in the face of climate change. As the Ministry of Natural Resources and Forestry, MNRF, often states, management should be implemented at the ecosystem level. Such management must acknowledge the inherent and ecological value of species and natural processes, not their monetary worth, whether consumptive or not.  Conservation and management objectives should not be to insure wildlife for consumers according to maximum sustainable yield or similar theories of “sustainable use”.

  4.Redefine “conservation” to include actions of prevention, preservation, protection or restoration of the natural environment, natural ecosystems, vegetation, and wildlife.

  5.Build a wildlife management strategy for Ontario that is open to all citizens, not just certain stakeholders identified as ‘deserving’ a seat at the policy table and one that draws upon knowledge and experience from other parts of the world.

  6.Review the MNRF’s Mandate and the supporting statements of policy and strategic direction to reflect the broad aspirational goals that are to be developed for the wildlife management strategy.

  7.Stop promoting the consumptive use of wildlife and rework the MNRF funding model, specifically eliminating the Special Purpose Account to reflect the fact that the MNRF holds wildlife in trust for all people, not just consumptive users.

  8.Establish transparent processes between MNRF and Aboriginal Peoples to protect wildlife for everyone.

  9.Develop principles and objectives driven by conservation of all taxa, instead of focusing solely on species of monetary value to consumers.

  10.Replace the concept of adaptive management with precautionary principle.  The MNRF's idea of 'adaptive' is reactionary modelling and annual changes to regulations for hunting/trapping based on maximum sustainable yield theory and not a dynamic, unpredictable landscape.

  11. Assess management and conservation regimes based on results, and not on regulations that exist but lack efficacy and/or enforcement. Ideas such as ecosystem approaches and scales of management are toothless unless there is evidence that integrated decision making is occurring and resulting in measurable increases in ecosystem functioning. Without such information, it is impossible to comment on the usefulness of the proposed Wildlife Landscape Zones.

   Comments:

  1.Purpose of the discussion document:

 The stated purpose of the discussion paper is to “describe how the ministry proposes to approach the development of a strategic plan for managing Ontario’s wildlife.”  The discussion paper states that the plan should incorporate broad aspirational goals, specific objectives and a series of steps and tactics intended to advance the goals and objectives.

  This document does not provide any “broad aspirational goals” that might acknowledge the ecological crisis facing wildlife in Ontario, nor does it provide an approach that would address or mitigate those aspects of the crisis that are under the purview of the MNRF and use their influence on other agencies.

  The discussion document identifies such issues as human population growth, habitat encroachment and loss, climate change management but largely within the context of current consumptive wildlife management practices. These issues must be identified as the key drivers of wildlife declines, both for species at risk of extinction and species not yet facing extinction.

  It also sets out a conflicted vision of a “healthy and naturally diverse environment” that somehow “enables and contributes to sustainable development in Ontario”.  No explanation is given as to how the Ministry would sustain a healthy and diverse environment while consuming finite resources and altering ecosystems through development. The very fact that development continues to result in wildlife declines despite regulatory provisions that were created to prevent declines, such as the Endangered Species Act (ESA) and Crown Forestry Sustainability Act (CFSA) proves that development is not sustainable.

 The wildlife management approach highlighted in the discussion document is largely driven by hunting/trapping/fishing license fees destined for the Special Purpose Account and conflicts with broad aspirational goals and ecologically based wildlife management.  The source of these funds results in wildlife management being restricted to the species most important to consumptive users.

 The argument that the MNRF needs hunting/trapping/fishing revenues to generate funds for all the other “non-game” species management programmes is circular in that the very hunting/trapping/fishing revenues that are decreasing for the MNRF, are required in the first place, because of the need to “manage hunters” at a level not required for other non-game species. For example, very little money is needed to protect Red-backed Voles. Moreover, threatened and endangered species that require funds to be restored are almost always facing extinction due to industrial/consumptive damage to individuals and habitat that is justified because the industry or use generates a profit.

  Finally, even in human wildlife interactions, where the Ministry has professed a need for a non-lethal mitigation to resolve human wildlife interactions, the authors still describe wildlife activity as causing “damage and disturbance” and thereby “impacting human quality of life, property and health”.  It blames wildlife for foraging in garbage or nesting in buildings, damaging crops, landscaping and infrastructures, causing road safety issues and acting as disease vectors and fails to consider the human behaviour that causes the interaction.

  2.Bias in the discussion document.

  a.Bias in favour of increased exploitation and revenue generation:

  Instead of focusing on aspirational goals, the discussion document explores how the “drivers” that affect wildlife and their ecosystems can provide opportunities to increase their exploitation and generate revenue.  As examples, the discussion paper cites:

 1.Changing demographics:  The changes are seen as opportunities to broaden participation in

 hunting and trapping.

 2.Climate change:  Climate change is seen as an opportunity to potentially diversify hunting (and viewing) opportunities of “non-traditional” species;

 3.Reduced license sales:  The document sees an opportunity to offset revenue loss from reduced hunting license sales by appealing to under-represented groups such as youth and new Canadians; and 4.Globalization of trade:  Globalization is seen as an opportunity to attract the international middle class to new hunting-related tourism markets.

  b.Bias in describing invasive species:

  The document states “A warming climate will increase the likelihood that new invasive species will become established and spread to regions that were formerly outside their range.” Would the increase in such wildlife species as the Wood Duck, Mallard, Gadwall, Northern Cardinal, Eastern Cottontail, Coyote, Virginia Opossum and others be considered “invasive”, or simply “a range expansion” and “a population increase”?

 The document does not differentiate between species extending their range due to global warming or those that were introduced because of human activity such as the put and take pheasant release, the unregulated release of chukar and other game birds or the introduction of Round goby into the Great Lakes.  Nor does it address the Ministry’s own introduction of non-native salmon and trout for sport and consumptive purposes.

  c.Bias – turning an interest in healthy lifestyle and exercise into an interest in hunting: The MNR states that “...there is growing interest in society in healthy lifestyle, exercise, and the importance of a clean environment” and an “interest in conservation and private stewardship...” The authors then see the opportunity to exploit the change in lifestyle interest as a way to “increase the number and diversity of those with an interest in hunting and wildlife management.”

  In fact, hunting and trapping can negate the very opportunities to indulge in such healthy activities as mountain biking or camping or hiking.   Some parks are literally closed off to the very health-enhancing activities the document identifies to accommodate hunting.   Crown lands are off use for any safe recreational activity during the spring for bear hunting and during the fall for deer, moose and bear hunts.

  d.Bias toward hunters and trappers as valuable conservation resources:

 The document again displays the venerable bias of MNRF thinking when it states, “Hunters and trappers contribute valuable resources and information to support wildlife conservation.  Continue to recognize hunting and trapping as culturally, socially, and economically important.” Acquisition of wildlife data is an important part of conservation but much of the data collection revolves around the need for control of consumptive activities, which contrary to much hunter and trapper propaganda, are not required to control wildlife populations or maintain biodiversity.

  Conclusion:

  Ontario has continued to allow increased growth and sprawl, increased use of environmentally compromising technology and increased consumption that has led to the current ecological and wildlife crises based on the flawed concept of “sustainable development”.

 However, we have advantages in Ontario.  We have a relatively smaller human population with a larger land base and virtually no endemic species of “wildlife”.  We have history and examples from other regions of the world that show us the effects of environmental degradation that we may face in the future if we don’t implement wildlife and environmental protective policies.

 Short of such a shift in thinking within the MNRF, the management strategy to guide us into the 21st Century will have been developed on concepts derived from the 19th century to be an exercise that may keep people employed at the taxpayers’ expense, but will achieve nothing more than the metaphorical equivalent of re-arranging deck chairs on the Titanic.

 In fact there are declining populations of some “game” and “furbearing” species and places where you can kill them.  Concurrently, there is an increasing appreciation for animals as perceptive beings with inherent self-interests, just like us.  With the explosive increase in electronic communications and shared images there is increasing awareness of the needless cruelty inherent to hunting, trapping and fishing plus far more extensive and emotionally satisfying ways to become involved with nature.

 MNRF needs to awaken to the modern world.

[Original Comment ID: 196677]