I oppose the proposal to…

I oppose the proposal to issue new licences and allow transfer of existing licences for dog train and trial areas.

As stated in the proposal, these areas "were intended to be phased-out over time". That is what should have happened. Many years have passed, and still they exist. No one can claim that the licence holders didn't have many years of warning that this has to end some day; the phase-out was, in effect, written right into law. The intention to phase-out these areas was deliberate. These areas should not exist, but you propose to allow them to persist by transfer and to allow more of them.

No change in society since 1997 has made it somehow acceptable now, when it wasn't then, to continue indefinitely into the future the use of trapped wild animals as bait to train hunting dogs. It was and still is cruelty to wild animals to use them for this purpose.

You say that train and trial areas are used to train hunting dogs and "provide a dedicated space for training where dogs and wildlife are contained and safe...". That should be corrected, because wildlife in these areas are certainly not safe. Being terrorized by dogs is not safe.

You appear to assume that the training of hunting dogs to hunt is a necessary activity. Is that because you assume that hunting with hunting dogs is necessary? But it is not necessary. No one "needs" hunting dogs to hunt. The wish of some people to use hunting dogs to hunt is not a need, and does not justify the cruelty that happens when they are used.

The use of hunting dogs is an archaic, cruel and unnecessary practice that has never made the world a better place. What social progress does the government see in more use of hunting dogs? There is none. Your proposal is a backward step for Ontario. It would encourage more people to train hunting dogs to hunt, and to use hunting dogs in hunting, both of which mean more cruelty to wild animals.

Wild animals that are hunted while in captivity suffer stress repeatedly. It is prison with repeated terror, death being the only escape. What crime did these wild animals commit to deserve this? Why does this belong in Ontario?

You say that "the ministry has received requests for changes to allow dog train and trial areas to continue to persist". How many requests were there? Why does a cruel activity that was to be phased-out and is engaged in by a tiny part of the population, warrant this response from the ministry to change the law for their benefit? If the government received the same number of requests to bring back cock fighting, would we then see a proposal, with "standards of care", "restrictions", etc, to bring it back? Is any cruel activity ok so long as someone somewhere wants to do it, and there are "conditions"?

The Provincial Animal Welfare Services Act says in section 15 that no person shall cause an animal to be in distress, and no owner or custodian of an animal shall permit the animal to be in distress, and no person shall knowingly or recklessly cause an animal to be exposed to an undue risk of distress. All of these conditions are broken for a wild animal pursued by dogs in a dog train and trial area. The law specifies an exception for an activity permitted under the FWCA "in relation to wildlife in the wild", but "in the wild" does not cover captive animals. Which exception in the PAWS Act allows the distress caused to captive animals by what the FWCA allows in a dog train and trial area?

Why is there no mention in your proposal of the distress caused to the captive wild animals, and of the legal basis for allowing it? It appears that you do not want the public to know about or think about this distress. The most important effect of this proposal is more cruelty to wild animals. Yet your "Regulatory impact analysis" is silent on that. It is written as if there is an economic opportunity and no negative consequences. You say the proposal "removes barriers and creates an opportunity for new persons to participate in the existing regulatory framework". You say the proposal would "offer benefits to persons who use dogs to hunt or track wildife". Using hunting dogs to hunt is a social ill dating from past centuries that has no justification. But you wish to encourage it. You see "opportunity".

The whole proposal is written as if morality does not matter. Why does a province which passes an act disallowing animal distress, a law which appears to be motivated by moral concerns, have no moral concern about the distress of a captive wild animal used as bait for hunting dogs?