Comments on EBR Registry Numbers , and

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1 January 18, 2016 Minister Bill Mauro Ministry of Natural Resources and Forestry Information Centre 300 Water Street Peterborough ON K9J 8M5 Dear Minister Mauro, On behalf of a broad coalition of animal protection organizations from across Ontario; including: Animal Alliance of Canada, Animal Alliance Environment Voters Party of Canada, Born Free, Canadians for Bears, Coyote Watch Canada, Humane Society International/Canada, Wolf Awareness, and Zoocheck, please find below our collective comments on EBR Registry Numbers , and Comments on EBR Registry Numbers , and On December 17, 2015, Minister of Natural Resources and Forestry signaled his intent to relax protection for wolves who are hunted, open up the wolf and coyote hunting season in the Northern area from mid September to the end of March beginning in Hunters would be allowed to kill two wolves with no limit on the number of hunters, while the coyote kills would be unlimited. No seals would be required either for wolves or coyotes. According to the Minister, the proposed changes are intended to: address the concerns in recent years about the impacts of wolf predation on moose in northern Ontario, address concerns about the requirement to purchase a seal in northern Ontario, maintain controls necessary to ensure the sustainability of wolf and coyote populations in northern Ontario, not impact current protections for the Eastern wolf population in their core range in central Ontario. (EBR )

2 The Minister claims that: separating harvest limits for northern wolves and coyotes reflects current science showing that hunters can generally distinguish between northern wolves and coyotes in the wild. (EBR ) The apparent purpose of the Minister s decision is to grow moose populations at a time when he claims declines in moose numbers in many parts of northern Ontario but are doing relatively well in southern Ontario. (EBR ) Our recommendations: To truly protect or enhance moose populations, while at the same time, also showing responsibility for protecting and conserving other species in these ecosystems the MNRF should: 1. Prioritize non- lethal methods over lethal methods in protecting moose populations and mitigating predation; 2. Increase efforts to end moose poaching; 3. Make moose hunting reports mandatory; 4. Increase aerial surveys and land surveys to better understand moose populations and wolf and coyote populations; 5. Increase funding for studies and solutions to mitigate parasites, such as winter ticks; 6. Prohibit hunting in the areas of most concern. Background: Information lacking to make a considered decision: The Minister provides no science to demonstrate that moose populations will increase to projected numbers through the proposed actions. A vast body of literature shows that predator- prey relations are not simplistic, and killing native carnivores will not bolster ungulate numbers because of many confounding factors that inhibit ungulate increases, including habitat loss and climate change. We are given no indication or estimate of how many native carnivores will have to die in order to achieve the Ministry s arbitrary target moose population increase. Indeed, this is because there is no credible scientific evidence that justifies these measures. Wolf dependency on ungulate populations: The Minister provides no explanation as to how a decline in the moose population has not resulted in a decline in the wolf population if moose are so integral to the wolf survival. Information provided by MNRF staff cite the latest Ontario Out of Doors publication which states that in Ontario there are 8500 grey wolves and hybrids, 500 Eastern wolves and an undetermined number of coyotes. The article shows the number of wolves and coyotes killed under the small game permit from 2005 to The Backgrounder on Wolf Management in Ontario, page 16 seems to agree that wolf density and numbers are dependent on ungulate densities. It states, In summary, across 2

3 Ontario it is likely that regional wolf population densities reflect the abundance and composition of the primary prey species, ranging from <1wolf/100km2 where wolves are reliant on a single (and relatively scarce) ungulate species (either deer or caribou depending on locality) to densities approaching 3/100km2 where multiple ungulate species are present and deer are relatively abundant. Number of wolves killed on the increase over the last 10 years: The chart included in the article shows a growing number of wolves killed by hunters from 2005 to 2014 a number that is likely unsustainable. Hunting wolves results in disruption to pack structure and to pack members, especially pups of the year. If the wolf population is stable or growing as the MNRF claims, then it would follow that moose populations are also stable in those regions based on historical codependency. If moose populations are in decline, then it is also possible that the wolf population is also in decline. The MNRF needs to focus on other factors, such as, poaching, overhunting or parasites. No data on First Nations take of moose: The MNRF has no idea how many moose are taken by First Nations (including Metis) as confirmed in the following statement: MNRF respects Aboriginal and treaty rights to harvest moose and doesn t have the authority to require Aboriginal peoples to provide their harvest information. That said, we have developed specific agreements with some Aboriginal groups in recent years to share this type of information, and we are working to further promote cooperation and information sharing with Aboriginal groups and communities as part of the Moose Project. Problems assessing population size requiring precautionary approach to wolf conservation: There is no application of the precautionary principle with regard to wolves. As the Background report states, At this time, there is no evidence to suggest that either gray or eastern wolves are threatened or endangered on a regional or provincial basis in Ontario. Wolves and coyotes occur at relatively low densities compared to their main prey species (deer, moose, elk, caribou, beaver) and are generally secretive by nature. As a result, inventory methods are time- consuming, 3

4 expensive and subject to a high degree of error. The information currently available in Ontario is not sufficiently sensitive to predict changes in the populations of canids except at the largest of scales. Therefore, there is the risk that conservation measures may not be appropriate or timely to respond to changes in local wolf populations. (Backgrounder on Wolf Management in Ontario, 2005 page 1) How does the Ministry intend to live up to its commitment to protecting wolves in Canada as is cited in the Backgrounder? The report states In view of the apparent relative abundance of gray and eastern wolves in Ontario, compared to their world status, Ontario has an international responsibility to conserve this species carefully. Wolves can be considered a barometer of both biodiversity and a functioning ecosystem. (Backgrounder on Wolf Management in Ontario, 2005, pg 1) Population: The Backgrounder shows that the number of wolves in Ontario has declined from the estimated 10,000 to 15,000 in the 1960s and 1970s with the estimated population at 8,300 wolves today. The Backgrounder states, Given the difficulty in precisely estimating wolf abundance, it is unclear precisely how many wolves there are (or have been historically) in Ontario. During the mid- 1960s the number of wolves province- wide was estimated at between 10,000-15,000. During the 1970s deer numbers declined throughout their range in Ontario, and moose numbers similarly declined through much of the southern boreal forest, leading Kolenosky to conclude that wolf numbers had probably declined drastically as well. Assumptions discussed by Kolenosky lead to an estimate of ~4,500 wolves province wide in the early 1980s. However, based on a thorough review of the literature it seems unlikely that there were ever these few wolves in Ontario in recent (post colonization) times. (Backgrounder on Wolf Management in Ontario, 2005, pg 7) Failure of hunters to distinguish between wolves and coyotes: The Backgrounder talks about the difficulty in distinguishing wolves from coyotes, yet the coyote hunt in northern Ontario is significantly expanded. The report states, The full extent of harvest of wolves by hunters is also not known at this time. The most reliable harvest information is collected through mandatory reports from fur dealers and taxidermists indicating wolves received from hunters for sale or tanning from hunters. These reports indicate a small harvest of wolves and coyotes by hunters within wolf range (2000/ animals, 22 identified as wolves ; 2001/ animals, 11 of these identified as wolves, 2002/ animals, 23 of these identified as wolves ). Some of these coyotes may be eastern wolves, as it would be difficult for hunters to visually distinguish wolves from coyotes in the field particularly in central Ontario. (Backgrounder on Wolf Management in Ontario, 2005, pg. 21) The Minister provides no evidence to support the statement that hunters can generally distinguish between northern wolves and coyotes in the wild. In fact, many wolves have been killed because of mistaken identity. 1 This statement is particularly suspect given all the Ministry s discussions about the larger size of coyotes. So not only will there inevitably be mistakes by hunters, the methods for capturing those data are gone 1 4

5 with the removal of the requirement of the seals. In addition, the Minister has set no limits on the number of hunters who can hunt wolves. Even when the seals were required the MNRF had trouble collecting the data. The report states, Wolf harvest data are also obtained from questions on wolf harvest included in the voluntary annual postcard surveys of moose and deer hunters, the periodic postcard surveys of bear hunters (2003), and the provincial mail surveys of moose hunters (2001) and small game hunters (2001 and 2003). These data suggest that 1,000-1,600 additional wolves/coyotes may be harvested annually by large and small game hunters. However, the level of confidence of this data is low due to the difficulty in hunters visually distinguishing wolves from coyotes in the field, low survey response rates, and possible duplication of harvest data submitted by the same hunter through various surveys. (pg 22) Data collection through postcards etc. can only be described as sketchy at best. Protection for wolves and coyotes should be increased, not decreased as is being proposed. Mandatory reporting should mean mandatory no permits should be issued unless the hunter has completed the mandatory report. No information provided about the number of wolves and coyotes trapped by WMU and not considered in the overall kill rate of wolves and coyotes Harvest of wolves and coyotes by licensed trappers can be controlled through the application of harvest limits (quotas), should that prove necessary. Harvests of wolves by trappers averaged 337 animals (ranging from 285 to 1,248) annually during the period to , while an average of 994 coyotes (ranging from 397 to 3,272) were trapped during the same period. (pg 22) Removing natural predators known to have little to no effect on moose populations In the Ontario Ministry of Natural Resources and Forestry s own research document entitled, Factors that affect moose survival the MNRF acknowledges that targeting such predators as wolves, coyotes, and black bears will have little to no effect on moose populations: Further: Generally, the number of moose killed by wolves increases with moose density and the number of moose living within wolf territories. Larger wolf packs kill more moose than smaller packs. But the increase in moose killed over time is not proportional to the increase in pack size. So, larger wolf packs actually kill fewer moose per wolf than smaller packs. The number of moose killed per wolf pack will not significantly decrease as the pack size is reduced, so removing just a few wolves from each pack will not decrease overall predation on moose. Only the removal of an entire pack can 5

6 substantially reduce predation but this practice may not be ecologically or socially desirable. In fact, there is virtually no independent scientific evidence to support the idea that it is possible to protect ungulate populations by killing such predators as wolves or coyotes. Efforts in British Columbia and the Yukon to cull wolves proved to be complete disasters. 2 Again from the MNRF s own research document: Some provinces and states have undertaken wolf control efforts. After control measures were discontinued, wolf populations in Alaska, British Columbia, Quebec and Yukon soon recovered to pre- control levels. For example, in the Papineau- Labelle Wildlife Reserve in Quebec, wolf numbers recovered to previous levels less than a year after a 71% reduction in wolf numbers. Once wolf populations recover, moose populations typically return to pre- control levels. The MNRF has explicitly acknowledged to animal protection and conservation groups that reducing the numbers of wolves and coyotes will have essentially no effect or possibly and potentially a very limited benefit in some areas, and even in regions of concern the department has no stated targets or ways to measure the outcomes of this proposal. Prioritizing lethal vs. non- lethal methods of population control The MNRF appears to be prioritizing lethal methods of predator population, despite responsible, non- lethal methods including conservation closures- - being used in other jurisdictions, such as in Minnesota 3 and to a lesser extent in Manitoba. 4 There is not enough of an attempt being made to significantly reduce the number of moose hunted or to prohibit moose hunting in the areas of concern. There is also no attempt being made to significantly improve the enforcement of moose poaching or the hunting regulations that exist, despite even the hunting community calling for more enforcement, 5 and the fact that moose poaching remains a serious problem. 6 Hunters commonly believe there are insufficient conservation officers afield to enforce moose hunting regulations (Bottan1999). The Provincial auditor reported a decrease in the amount of time spent on general deterrent patrols by conservation officers and in the number of charges laid under the Game and Fish Act (Provincial Auditor 1998:3). The MMP proposed increased enforcement of legislation and regulations to control illegal hunting and to 2 news.com/news/lose- wolves- lose- the- wilderness 3 moose- hunting- season- canceled 4 hunt- temporarily- banned- in- five- manitoba- regions/ 5 6http://go.galegroup.com/ps/anonymous?id=GALE A &sid=googleScholar&v=2.1&it=r&linkaccess=f ulltext&issn= &p=aone&sw=w&authcount=1&isanonymousentry=true 6

7 suppress poaching (OMNR 1980a). Few moose enforcement data concerning hunter compliance have been analysed or published. 7 Increase efforts to end moose poaching This, despite moose poaching being a rampant problem, Conservation Officers found 793 illegally killed moose in the Ontario Ministry of Natural Resources Northeast Region during the period of Of these illegally killed moose, 365 were abandoned. 8 The MNRF should invest more time, money and resources into preventing moose poaching. The MNRF should increase patrols by conservation officers and increase time spent on deterring, enforcing and penalizing illegal moose hunting. Reporting moose hunting should be made mandatory While reporting of the hunting of wolves and bears is mandatory, there is no provincial mandatory reporting requirement for moose kills. In fact, voluntary reporting of moose kills is reported to be at a 52% response rate. Even the mandatory reporting of wolf and bear kills is at 68% and 72%, respectively, with no penalties or repercussions for not complying. 9 The MNRF should immediately move to a mandatory reporting system for moose hunting. The proposal appears to favour livestock farmers concerns In the MNRF s proposal, it appears to be prioritizing the concerns of livestock farmers: It will also allow additional hunting opportunities for coyotes which continue their expansion in northern Ontario and have been an increasing concern for livestock farmers. And again Livestock farmers in northern Ontario are expected to appreciate changes to coyote hunting regulations. It is irresponsible of the MNRF to give any weight to the separate concerns of livestock farmers in a proposal to protect or increase moose populations and these concerns should carry no weight, as they have no relation to the discussion of the Moose Project. In addition, the Ministry does not provide any data on northern farm animal predation and costs. It provides no information on whether there are hot spots of predation and whether those could be addressed through non- lethal measures. And, the entire north is opened up to unlimited coyote killing beyond the areas where agricultural activities that would attract coyotes occur A &sid=googleScholar&v=2.1&it=r&li nkaccess=fulltext&issn= &p=aone&sw=w&authcount=1&isanonymousentry=true 9 mandatory- harvest- reporting/ 7

8 These regulations are not neutral The MNRF predicts that from an environmental and societal perspective, the regulatory impact of the cull will be neutral, despite the lethal consequences for wolves and coyotes: The anticipated environmental consequences of the proposal are neutral the anticipated overall social consequences of the proposal are also neutral. Some stakeholders have expressed concerns about the impacts of wolf predation on moose. These groups are likely to support the proposals, whereas some other stakeholders and members of the public may be opposed to any changes in wolf hunting regulations. A proposal that results in the deaths of hundreds to thousands of animals simply cannot claim to be neutral. Indeed, the proposal is seen as a political move to gain voter support in rural and northern communities and to placate the hunting lobby. 10 Given the MNRF s stated view that these regulatory changes will have little to no effect on the moose population, there is no justification for these measures bay/wolf- coyote- hunting- follow