Comments by the Ear Falls…

   Comments by the Ear Falls Trappers Council on Building a Wildlife Management Strategy for Ontario (EBR Registry number 012-8249

 The membership of the Ear Falls Trappers Council directed the executive to submit comments on this posting at the general meeting held on September 11, 2016.

  Guiding Principles

 •We agree with the need for a set of principles to guide development of a wildlife management strategy for Ontario.

 •A principle that requires management at the appropriate scale is necessary.  However, we are not sure that anyone really fully understands ecological processes, functions and structures. Therefore, you need to use the best available science related to these aspects of ecosystems. Let’s not forget that individual species biology also comes into play as we are still managing provincially significant species.  This aspect was forgotten in regards to moose as MNRF moved to broad scale caribou management.  Now moose are in decline and caribou management has played a significant role in this decline.

 oWhile social and economic factors are important in adjusting the scale of management so too is species biology/ecology, wildlife systems and landscape productivity.

 oWe remain concerned that wildlife management will be “scaled up” to satisfy the constant political desire for cost savings.  We do not want the scales of management to be unnecessarily large!

 oMNRF needs to provide well documented rationale, with any assumptions that are being made, as to how “appropriate scales of management” are determined.

 oWho determines what “good value” is for the effort and costs of management of wildlife? Whoever does this the results need to be made available to the public for review along with the methods used to determine “good value”.

 oIn addition, MNRF needs to commit to periodically review scales of management.

 •While we also agree with need to principle to integrate and coordinate wildlife management efforts I am concerned that MNRF will take this to the extreme.  For example, there are good reasons why trapping and hunting seasons are different in northern Ontario from southern Ontario. Making them all the same would not facilitate sound wildlife management.

 •Again, the principle to manage and mitigate risk is appropriate.  However, we would add the need to identify those risks and to ensure periodic assessment of whether or not those risks have been mitigated.

 •Facilitating adaptive management is also a sound principle to consider in the development of a wildlife management strategy for Ontario.  MNRF needs to make sure that there is the commitment to supporting science to fill information gaps and to following through on what that science tells you even if it isn’t politically expedient.  Remember, you are managing the wildlife resources on behalf of the people of Ontario and they are expecting sound management.

 •Recognizing the interests and contributions of hunters and trappers in wildlife management is a principle that must be included in the development of a provincial wildlife management strategy. Hunting and trapping has always been an important part of what built Canada.  Hunters and trappers could be used much for effectively as sources of information and partners in wildlife management than they have been in the past.

 •We are not sure why there needs to be a principle that recognizes Aboriginal rights and interests.  The Supreme Court of Canada and the constitution have repeatedly confirmed this.  Now if there was a principle to involve Aboriginal and Metis more fully in wildlife management, in particular harvest management,  would probably be appropriate.

  Establishing Ecologically Based Wildlife Landscape Zones (WLZ’s)

 •While we agree that we should examine the scale of management, we are concerned about the underlying motivations especially at this point in Ontario’s wildlife management history.  We are hoping that the strategy and the WLZ considerations are about better wildlife management and are not about the constant pressure from the government to reduce expenditures/budgets, or rationalizing and legitimizing a number of policies that were forced onto the public (eg. Cervid Ecological Framework),or  reducing regulatory complexity (which has been an internal MNRF focus for many years) or, rationalizing the results of the most recent restructuring event which has entrenched decision making at the regional level.  All of these things need to be reviewed in the context of improved wildlife management and modified if necessary.

 •MNRF makes it sound like finer scales of management, frequent decision making and variation in approaches are all bad.  This isn’t necessarily true and there may be situations where these are appropriate.  Thus finer scales of management should not be categorically rejected.  In these cases the rationale for finer scale management needs to be documented.  Similarly, frequent decision making may not always be bad.  A primary tenant of modern management is “ as the intensity of resource use increases so should the intensity of management”.

 •Lastly, variations in approaches to the management of the same species may be very necessary to maintain population levels while still allowing for an appropriate level of use. We must not get trapped in a “one size fits all” approach.

 •If we are getting the picture correctly then the following things need to be considered  in the development of WLZ’s:

 oEcoregions

 oWildlife systems

 oLandscape productivity

 oWildlife management units (WMU’s)/efficient administration

 •All of these considerations make sense to us. However, the public requires more information on how things like wildlife systems” and “landscape productivity” will influence the development of WLZ’s.  We are somewhat skeptical of how these things will influence WLZ’s since things like land productivity didn’t seem to play much of a role in the cervid ecological framework and areas that should have been managed for moose are now being managed for caribou.  Thus, further explanation is required.

 •Wildlife management units should definitely be a major consideration in the development of WLZ’s. What we didn’t like to see is the statement “e.g. desired wildlife outcomes can be determined at the level of a landscape or ecosystem, with some associated management decisions implemented at the WMU level.”. Firstly, who determines the desired wildlife outcomes (the public definitely needs to be involved in developing these!)?  Secondly, decisions should still be made at the WMU level where it is appropriate to do so.  Again, we are worried that MNRF will simply scale up decisions and management actions to save money and rationalize other policies that were forced upon the public without all the pros and cons being described.

 •Your “possible configuration” of WLZ’s looks somewhat reasonable with a few exceptions. Shouldn’t Z13, Z14 and Z15 be all one WLZ since they all appear to fall within ecoregion 3W?

  Mark Sobchuk

 Vice President

 Ear Falls Trappers Council

[Original Comment ID: 196659]