These proposed amendments to…

These proposed amendments to the Fish and Wildlife Conservation Act that would allow foxes, coyotes, and rabbits to be trapped and then held captive and used as bait to train hunting dogs in Train and Trial facilities is clearly unconscionable, cruel , inhumane, unethical and unacceptable. The proposed goal is not a compelling one; just so that the dogs become accustomed to tracking wildlife for hunting as a sport/recreational activity and for hunting competitions? That is not an outcome necessary enough to justify the obvious inhumane treatment of the captive animals - who have no quality of life or chance at escape. Captive foxes suffer in captivity ( https://montreal.ctvnews.ca/opinion-a-call-to-end-fur-farms-and-stop-cr… ). Why would it be any more acceptable to torment them for training dogs for sport than it is for fur farming?

It would not be considered acceptable for farmed animals to be routinely subjected to stress and cruelty before slaughter for food. Why then would that be acceptable to subject wildlife to? The foxes, coyotes and rabbits are not even being hunted to feed hungry humans - merely as 'recreation'. There are other things that dogs can be trained to do that would be far more useful and even noteworthy - ex. track and rescue ( https://canadiansearchdog.com/training/training-your-dog-to-search.html , https://osarva.ca/k9/ https://www.ovsarda.on.ca/ https://downsviewvethospital.com/news/search-and-rescue-dogs ).

With good reason, in 1997 the decision was made not to allow any more of these facilities to be created. It was a former Conservative government who started the phase out. There can be no new compelling reason strong enough to make it suddenly more ethical or acceptable now - 26 years later, to continue to trap and keep wildlife captive in enclosed pens only so that hunters can train dogs to hunt and to run 'competitions' for hunting dogs.There is no ethical or moral reason that can justify why these facilities should continue to operate, much less to continue to exist.

I strongly oppose the Ministry of Natural Resources and Forestry’s proposal to allow any new licenses to operate these penned dog hunting facilites, and to allow the transfer of existing licenses, for dog train and trial areas in Ontario. As a taxpayer and voter in Ontario I urge you this government to reject this proposal and refuse to give it force in law or policy.

Penned dog hunting facilities are very clearly by design and nature extremely cruel, inhumane and unacceptable treatment of the wild animals kept captive and then hunted where they have no 'sporting' chance whatsoever. The animals that will be exploited in this proposal are fellow creatures who play important integral parts in the ecosystem we are also a part of, and deserve to be treated with respect and care as conscious living beings who deserve to exist and not be exploited or tormented - they are not merely inanimate 'resources' to be callously used, abused and killed. Have we not come to realize that nature is not ours to exploit at will?

Hunting does not control coyote and fox populations ( ex. https://www.npr.org/2019/06/14/730056855/killing-coyotes-is-not-as-effe… , https://www.humanesociety.org/resources/why-killing-coyotes-doesnt-work , https://www.scientificamerican.com/article/why-killing-coyotes-doesn-rs…, ). ".Ministry of Natural Resources and Forestry research scientist Brent Patterson said he’s studied wolves and coyotes extensively over the last 15 years, including control methods. The short answer on bounties is they don’t work. It wasn’t for lack of trying; records show that Ontario spent the equivalent of $850,000 in today’s dollars on its coyote bounty back in 1918, he said....." So there is no compelling reason to train dogs to hunt them." ( https://farmersforum.com/coyotes-a-problem-but-a-bounty-isnt-the-answer… 'Coyotes a problem but a bounty isn’t the answer says researcher' June 01, 2018, Farmers Forum 'The largest circulation farm newspaper in Ontario, Canada' ), https://www.cbc.ca/news/canada/edmonton/bounties-on-wolves-and-coyotes-…

By Connor Lynch ).

The trapping involved will undoubtedly also catch other species of animals that are not coyotes, rabbits, or foxes - including potentially protected or endangered species, and domestic animals such as dogs. The argument that otherwise this activity would 'move underground' is without merit. If it were true, then that implies that the majority of those training hunting dogs or entering competitions for sport are otherwise willing to participate in illegal activities. That doesn't sound like 'sport'. Making it legal to do this does not make it acceptable.

This 'sport' can attract illegal and illicit activity, and there is the question of the methods used and treatment of the dogs being 'trained'; i.e. "...Dogs used to chase down canids are equipped with GPS and shock collars while their handlers track the dogs from their vehicles. ..".. ) https://www.facebook.com/TCCEinc/ ). And environmental, health and legal concerns;

Penning wildlife and forcing wildlife into contact with humans and domestic animals such as dogs can foster and spread disease and parasites to humans, dogs, coyotes, foxes, and other wildlife; for ex. see growing concern about Echinococcus multilocularis Infection - present and growing in Southern Ontario, according to the US CDC; ".typically fatal in humans and dogs when left untreated. Since 2012, alveolar echinococcosis has been diagnosed in 5 dogs, 3 lemurs, and 1 chipmunk in southern Ontario, Canada, a region previously considered free of these tapeworms."..."...In humans and dogs, AE is typically fatal when left untreated. The E. multilocularis tapeworm has a wide distribution in the Northern Hemisphere, including extensive endemic regions in North America, Europe, and Asia (1), and is usually maintained in a life cycle that involves 2 mammalian hosts. Wild canids (e.g., foxes and coyotes), dogs, and (less commonly) cats act as definitive hosts, which harbor adult parasites in the small intestine without apparent clinical disease....."......
https://wwwnc.cdc.gov/eid/article/25/2/18-0299_article . We have barely been able to fight off one pandemic - likely caused by the farming, penning and harvesting of wild animals and increased human contact with wildlife is a recipe for another disastrous but entirely foreseeable zoonoses https://www.who.int/news-room/fact-sheets/detail/zoonoses https://www.hsi.org/wp-content/uploads/2020/12/HSI-white-paper-on-fur-p… .

I do not believe that you will find a majority of current mainstream veterinarians or animal specialists or biologists who would agree that this proposal has any ethical merit whatsoever. One employed or speaking for a special interest hunting group - has an inherent conflict of interest.

Please do the right, the humane, the ethical and the scientifically informed thing and turn down the MNR's proposal, and phase out these trap and train facilities entirely, asap.

Sincerely,
An Ontario taxpayer, resident and voter.