November 17, 2016…

November 17, 2016 Wildlife Section PUBLIC INPUT COORDINATOR Ministry of Natural Resources and Forestry Policy Division Species Conservation Policy Branch Wildlife Section 300 Water Street Peterborough Ontario K9J 3C7 Response to EBR Registry Number: 012-8249 “Building a Wildlife Management Strategy for Ontario: Discussion Paper” Dear Minister McGarry and Premier Wynne, On behalf of Humane Society International/Canada and our tens of thousands of members across Ontario, thank you for the opportunity to comment on the Building a Wildlife Management Strategy for Ontario: Discussion Paper. Our recommendations are as follows: 1.In the near term, restore public confidence by changing the funding structure of the MNRF to avoid undue influence of special interest groups and resulting weaknesses/bias in government policy. At a time when both provincial and national stakeholders are carefully analyzing the Ontario government’s spending practices, it is disturbing to learn that an Ontario government department is receiving the majority of its budget from an industry sector. Unfortunately, the recent MNRF discussion paper reflects the clear resulting bias towards industry that this funding structure creates, which tarnishes the image of the Ontario government and undermines public confidence in the MNRF’s ability to effectively conserve wild populations for all Canadians. While the fees gathered from hunting and fishing licenses are of course appropriate, and rightfully help offset the management and enforcement costs created by these activities, the designation of these fees in a “special purposes” account that currently comprises 70 percent of the operating expenditures of the Fish and Wildlife branch of the MNRF budget most definitely is not. The current funding structure has seemingly created a perception by industry lobby groups that the hunting sector should have more of a say than other citizens in dictating MNRF policy. This perspective has been made clear both in statements made by these stakeholders at recent MNRF sessions and in the clear bias in the MNRF draft strategy towards consumptive use of wildlife. We believe Ontarians would be surprised and dismayed to learn that the majority of funding for the MNRF does not come from taxpayers but rather from an industry sector with a vested interest in policy making. The situation would be analogous to the Ontario Ministry of Health and Long Term Care receiving taxes directly from the tobacco industry, putting those funds into a restricted account, openly acknowledging that the majority of its budget came from that account, and then setting policies that promote tobacco smoking. While the Ontario public may be unaware of the transformation in funding structure at the MNRF now, they will not be for long. We therefore urge the Ontario government to rectify the situation quickly to emulate the model of other regions, in which hunting/fishing license fees are collected into the general tax base and then the provincial government allocates budget for the MNRF according to program need. Such a funding model allows for a more inclusive participation in the approach and direction of the agency. 2.In the interim, take immediate steps to distance the MNRF and its management of natural resources—resources that belong to all Ontarians and all Canadian citizens—from industry lobby groups. While the current controversial funding structure remains in place, we urge the MNRF to take all precautions to ensure that its conservation and enforcement strategies are above reproach and show no bias towards industry. We note that in its draft strategy, references to the “contributions of hunters” are mentioned in no less than five places (pages 7, 8, 14, 20, and 24)—amazingly, in absence of any kind of recognition of the contributions of conservation groups, government agencies, corporations, foundations and the general public. To avoid the appearance of bias, these references should be struck from the document. We also note that, as one of its recommendations, the MNRF is suggesting a recruitment program to turn youth and new Canadians into hunters. The recruitment of clients to an industry sector is the responsibility of that industry, not a government department. Public spending for this purpose is offensive, unethical and a transparent concession to industry lobby groups. 3.Include—at the very least—minimum standards of animal welfare in hunting regulations. Responsible, recognized veterinary authorities state that for a kill to be humane, the following processes must occur: -The animal must be rendered unconscious with one stunning attempt, without causing fear distress or pain to the animal. -The animal must be monitored for consciousness directly following stunning, using a series of accepted methods of testing (such as corneal reflex) -The animal must be immediately bled out upon confirmation of unconsciousness Thus, any hunting regulations in Ontario should require these humane killing steps. Moreover, any weapon that cannot guarantee accuracy in hunting should be prohibited, as should stun/kill attempts in conditions that would prevent accuracy (such as poor visibility, high winds, etc). Permitted weapons should be regularly reviewed by veterinarians to ensure they are appropriate for delivery of instantaneous stunning/death. Adequate enforcement should be in place to ensure adherence to these standards, with appropriate penalties in place as deterrents to any deviation from regulation killing. Finally, we would recommend the government of Ontario require full utilization of targeted animals in all hunting in the province. Canadian citizens generally oppose trophy hunts in which wild animals are killed for sport and a single item (such as a bear skin, for example) is retained as a trophy while the remainder of the animal is discarded. Conclusions There are many more recommendations that could be made about future management of wildlife in Ontario. However, we maintain that under the current funding structure, such feedback will not be given due consideration and, until this funding model is fixed, no management plan can claim to serve the interests of the general population and wildlife conservation. Once the Ontario government has rectified the current funding issues, HSI/Canada would be pleased to more fully engage in an impartial review of wildlife management strategies in Ontario. [Original Comment ID: 196679]