Public Input Coordinator…

Public Input Coordinator
MNRF Fish and Wildlife Policy Branch – Wildlife Section

300 Water Street
5th Floor, North Tower
Peterborough, ON
K9J 3C7
Canada

May 18 2023

RE: 019-3685 -- Proposal to allow the issuance of licences for new dog train and trial areas and the transfer of licences

Dear Public Input Coordinator,

I am writing on behalf of Wolf Awareness, a conservation charity dedicated to promoting and conducting wolf research and engaging the public in improving policy around wolf conservation. Wolf Awareness strongly imposes the proposal to re-open the previously phased-out trial and train licensing process.

In the 1990s, social opinion had already shifted so strongly in opposition to the wanton destruction and cruel treatment of animals, including wildlife, that the previous Conservative government made the decision to phase out the licensing and operation of trial and train centres where dogs are trained to harm, harass and kill coyotes, rabbits and foxes. Given this decision and its social context, as well as the ongoing public intolerance of wildlife mistreatment in such places, it is both egregious and frankly shocking that the Ontario government would propose a reversal of the phase-out and appear to be proud of this proposal in the House of Commons discussions of Bill 91.

Both the dogs and the wildlife raised or released into these enclosures are at risk of serious harm both in trial and train centres as well as during hunting with dogs more generally. There is no ecological reason to hunt coyotes or foxes, as it provides no benefit to the ecosystem or to hunters, people do not eat these canids, and moreover hunting coyotes and wolves could shift and/or exacerbate livestock losses and decrease the positive benefits of canids to farmers (rodent control, for example). There is therefore no defensible reason to promote hunting of wild canids with or without dogs. There does not seem to be any ecological reason to hunt lagomorphs, with hounds or otherwise, either. Rearing, keeping and teaching dogs to kill rabbits as well as their natural predators is redundant and unnecessarily costly.

Farmers and other rural landowners frequently complain about trespassing by hunting dogs (e.g. at the Eastern wolf recovery planning meetings), and these trial and train areas will not solve this issue, but may possibly increase these negative interactions by promoting this type of hunting widely. The Ontario Government has made no improvements to preventing trespassing by hunters, including hound hunters. Despite changes to technology (e.g. GPS trackers on hounds) trespassing seems still to be common. It is not safe or even possible for landowners to attempt to remove a pack of hounds from their land, and dealing with hunters in these circumstances often ends in conflict and feelings of insecurity on the part of the landowners, which is inappropriate. Hound hunting on public land is also the most likely form of hunting to preclude other recreation on that land; it is alarming and possibly dangerous to encounter hounds on the trail of wildlife, especially for people walking dogs or travelling with small children. Clearly this proposal benefits a small select demographic of Ontarians, while negatively impacting the vast majority of Ontarians.

Wolf Awareness is particularly concerned about negative impacts of this proposal on the threatened Eastern wolf. Genetic testing is required to accurately differentiate eastern coyotes and eastern wolves, which would be used in unknown numbers in these trial and train areas. Harming and harassing this species at risk merely for sport is disgusting, ecologically unsound and violates the purpose of the Endangered Species Act. There is no information in this proposal to suggest that eastern wolves would not be harmed in trial and train areas where coyotes are used as the target for hounds.

The proposal failed to outline how Ontario has dealt with wildlife welfare issues in the past at these centres, as well. Due to the nature of these facilities, where wildlife is trapped and either placed in the enclosure and/or bred for future training targets, and dogs are trained to harm and harass the wildlife directly, it is impossible for the government to make assurances that any stringent animal welfare standards are upheld. The interaction of hounds chasing and destroying or injuring wildlife is inherently inhumane. That this inhumane treatment is happening under only the supervision of people who believe this treatment and the killing of wild canids and rabbits is morally justified, and that the enclosures are by legal definition closed, private, fenced areas guarantees that it will be impossible for the Ontario Government to uphold animal welfare there. While some hunters justify their hatred for carnivores and dedication to killing them by their opinion that wild carnivores cause damage in their natural depredation of herbivores, these same hunters do not appear to consider the wanton damage that hounds have on wildlife, especially wildlife such as canids that are not eaten by the hunters but merely killed for sport. This double standard is perplexing and gives the broader hunting community a poor reputation in the eyes of the Ontario public.

There are many ways for hunters to participate in hunting activities, and to earn a living doing so. The impacts of phasing out the handful of centres that still operate, compared to allowing dozens more in our province, is insignificant within the greater hunting industry. It will cost hunters far more money overall to keep hounds, a practice which is entirely unnecessary for successful hunting, and will not benefit the hunters or the ecosystems where they hunt at all. Allowing more trial and train areas is not an appropriate way to appease the hunting demographic in our province. If the Ontario Government wants to support hunters by increasing social tolerance of hunting, it must better regulate the activity (i.e. creating closed seasons for coyotes in Southern Ontario), enforce mandatory reporting and use that data in policy-making, and concentrate on the ecological, animal welfare and property protection outcomes of hunting on public and private land. Many other jurisdictions in North America know this already, and have banned this harmful practice outright. Ontario was following suit for many decades, making this abrupt shift all the more alarming.

Wolf Awareness requests that this proposal be immediately abandoned, that trial and train centres be phased out more quickly and that hunting with hounds be prohibited across the province to better protect wildlife, reduce injuries to hunting dogs, and balance the myriad perspectives on hunting in Ontario.

Sincerely,

Hannah Barron
Conservation Director
Wolf Awareness