1. It distracts the public from the lack of concerted efforts to halt moose declines
“consider the potential additive effects of calf hunting cautiously when contemplating changes to moose hunting regulations.” – MNRF research biologist Brent Patterson, 2013
Moose are declining at an alarming rate in many jurisdictions such as Ontario, Manitoba, Minnesota and Montana. Many of those areas have prohibited moose harvesting while they investigate the reasons behind the declines. Ontario needs to build on its commitment to change hunting regulations, manage resource extraction and development to limit impacts on wolf-moose-caribou dynamics and plan for the long-term effects of climate change.
MNRF currently collects data on wolf/coyote sightings and hunting effort, which helps to clarify moose-predator dynamics. Part of the proposed regulation changes are to remove the mandatory game “seal” reporting requirements for coyote and wolf hunters in Central and Northern Ontario. This reduction in research effort clearly demonstrates the MNRF’s lack of commitment to determine the true cause of moose declines.
2. Wolf and coyote control is unethical and will not prevent moose declines
“Unfortunately, the notion of humane treatment is often the first casualty of turning a species into a pest” – renowned ecologists Fryxell, Caughley and Sinclair
The Ministry has no scientific evidence showing that encouraging hunters to kill wolves and coyotes will benefit moose. In fact, the Moose Project website summarizes scientific research that suggests the opposite.
“Only the removal of an entire pack can substantially reduce predation but this practice may not be ecologically or socially desirable. Changing hunting and trapping regulations to allow more wolves to be harvested is unlikely to remove an entire pack.” – MNRF Moose Project
Ministry biologists learned that in Ontario, “relative to what’s out there, wolves killed proportionately more old and vulnerable moose”. They also learned that eastern coyotes don’t pose a significant threat to moose:
“it seems unlikely that predation by coyotes and hybrids is cause for conservation concern in central Ontario.” - MNRF research biologist Brent Patterson & Dr. John Benson, 2013
Moreover, there is strong evidence from Central Ontario that hunting pressure increases moose deaths, instead of compensating for deaths from predation and natural causes. Ontario’s moose are managed under the compensatory framework. Clearly moose harvest policy must be changed to reflect this new knowledge.
The BC and Alberta governments are currently attempting to exterminate wolves in endangered caribou habitat, yet the caribou populations are not increasing. Once again, government encouragement of predator control as a band-aid solution to the larger problem of declining prey species fails at the expense of thousands of wolves.
3. By eliminating the wolf/coyote seal across much of Ontario, MNRF will lose funds needed to enforce regulations and conduct future research
“the 2013 budget restored some of the funding but the ministry had already made deep cuts, reducing the number of MNRF technicians to 21 from 48” – Toronto Sun, 2015
Wolf and coyote seals cost a mere $11.14 for Ontario residents and are currently limited to 2/hunter/year.
At a very small cost to individual hunters, the MNRF collects badly needed funds that help them carry out essential research and management enforcement.
This proposal perpetuates the under-funding of MNRF by removing the wolf/coyote seal once required across all of Central and Northern Ontario. Without adequate funding, MNRF researchers will be unable to identify the reasons behind moose declines.
4. The regulations result in an expansion of Ontario’s war on the coyote
“Know thine enemy” – Barry Potter, Ontario Ministry of Agriculture, Food and Rural Affairs livestock specialist
By encouraging hunters to kill as many coyotes as they want in Northern Ontario, this proposal worsens the already medieval management of the species. It is time these animals are managed with more compassion and respect for their ecological contribution to Ontario’s diverse landscapes.
Eastern coyotes are fascinating examples of evolution. Arriving in Ontario in the early 1900s, they bred with remnant eastern wolves and became incredibly well-adapted to a variety of habitats.
Following the systematic extermination of wolves in Southern Ontario during European settlement, rodent and deer populations became hyperabundant and have cost millions in crop devastation. Described as wily, wolf-like vermin, the eastern coyote’s ability to fill the role of top predator in areas dominated by people is actually a blessing. Coyotes are now the only predator capable of controlling deer in Ontario’s populated areas – deer culling would not be necessary in areas with a coyote population protected from harvesting.
However, coyotes are still slaughtered to prevent livestock depredation in most of the province. MNRF and the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA) support these actions, ignoring science that shows coyotes populations are next to impossible to control, that non-lethal predator management can successfully mitigate livestock losses and that attempts to control coyote populations likely exacerbate livestock losses.
Wolves and coyotes evolved alongside wild prey that are considerably harder to catch than livestock such as newborn calves and fearless, fenced-in sheep. By killing members of a coyote family, hunters splinter the tight pack structure that allows coyotes to take down larger prey like white-tailed deer. As such, fragmented coyote packs might be more of a threat to livestock than coyotes that are left alone by hunters.
Coyotes and wolves dispersing south are never safe from hunters in Southern Ontario under existing legislation. Whole pack families can be destroyed as they nurse and raise newborn pups each spring.
5. Proposed regulations endanger Ontario’s at-risk eastern wolves
“There are probably fewer than 500 Eastern Wolf in Canada … Special concern species do not receive species or habitat protection.” – MNRF
On December 8th 2015, The Committee on the Status of Species at Risk in Ontario (COSSARO) voted on the re-assessment of eastern wolves. COSSARO was expected to follow the lead of their sister committee in Canada and reclassify the animals as a unique species at a higher risk of extinction – up from “Special Concern” to “Threatened” or “Endangered”. Either of these levels would automatically and immediately protect Ontario’s eastern wolves.
Typically, COSSARO notifies MNRF about their decisions on December 31st, half-way through the commenting period for this proposal.
MNRF’s own research shows that there are eastern wolves in various parts of Central Ontario, well outside their stronghold (and only fully protected habitat) in and around Algonquin Provincial Park. The research also shows that compared to coyotes and hybrids, eastern wolves are the most likely to die outside of protected areas. Researchers have consistently claimed that the recovery of the species is virtually impossible if hunting and trapping seasons remain open in Central Ontario.
With this proposal, MNRF suggests new canine management boundaries to mitigate threats to this at-risk species. However, hunters will still be allowed to shoot up to 2 wolves/coyotes in eastern wolf range, and will no longer be required to report on their hunting activity.
Without genetic testing, no one can distinguish between coyotes, eastern wolves or their hybrids in Ontario. The government admits that they have no way of determining how many eastern wolves hunters or trappers are killing each year across the province. This is completely unacceptable.