PUBLIC INPUT COORDINATOR
Ministry of Natural Resources and Forestry
Species Conservation Policy Branch
300 Water Street
Phone: (705) 755-1940
Fax: (705) 755-2901
RE: EBR 012-8104 Amendments to wolf and coyote hunting and trapping seasons under the Fish and Wildlife Conservation Act in response to amendments to Ontario Regulation 230/08 (Species At Risk in Ontario List) under the Endangered Species Act, 2007 for Algonquin Wolf.
Thank you for this opportunity to comment on the Ministry of Natural Resources and Forestry (MNRF) proposed amendments to the Fish and Wildlife Conservation Act in response to the legal listing of Algonquin wolves as Threatened under Ontario’s List of Species At Risk. We are encouraged that the MNRF has proposed additional closures for both wolf and coyote hunting and trapping, in line with research that shows there is overlap in the morphological attributes for these animals and their hybrids (Benson, Patterson and Wheeldon 2012; Sears et al. 2003), and therefore the species cannot be distinguished without a genetic assignment test (MNRF, and see Rutledge et al. 2010a). However, we emphasize that the three proposed closures are inadequate to recover the Threatened Algonquin wolf population and urge that more protective measures be taken immediately.
In order to implement the required protection outlined in the Endangered Species Act for threatened populations, and to effectively increase the probability of recovery for the Algonquin wolf population, wolf and coyote hunting and trapping must be immediately banned in all Wildlife Management Units (WMU) that contain any portion of the Algonquin wolf’s extent of occurrence (as described by the Committee on the Status of Species at Risk in Ontario (COSSARO 2016).
These WMUs are: 35-39, 41-61, 75 & 76A. We recommend that these closures should be additive to the existing protection in and adjacent to Algonquin Provincial Park. Given the vagility of these animals, these closures are conservative. Anything less than this is a blatant disregard for the recovery of this at-risk wolf population.
The proposal effectively creates a category of habitat unknown to the Endangered Species Act, 2007 (ESA) of “core occurrence area”, and only protects the Algonquin wolf in those areas. The ESA defines habitat very broadly and “habitat” under the ESA includes all of the WMUs identified by COSSARO. Protection of only a portion of the habitat of the Algonquin wolf will cause significant adverse effects on the Algonquin wolf’s survival and recovery. Specifically, the proposal would prevent the recovery of the species by limiting dispersal. Accordingly the requirements of subsection 57(2) of the ESA must be met. The Minister has failed to meet these requirements or provide reasons why the proposal will not jeopardize the survival and recovery of the species or cause any other significant adverse effect. The significant adverse effects that will be caused by the proposal include:
Algonquin wolves will not be able to disperse due to hunting and trapping outside of the “core occurrence areas”. Dispersal is a natural process that is important to survival and recovery.
Hunting and trapping outside the “core occurrence areas” will disrupt the social structure of Algonquin wolves residing within the “core occurrence areas” and jeopardize their survival and recovery as functional packs within the protected areas.
Connectivity between the “core occurrence areas” is too restricted.
There is a high risk of hunting and trapping of wolves outside the “core occurrence areas”.
Algonquin wolves, coyotes and their hybrids are exposed to poaching and vehicles during dispersal from protected areas, also putting their survival at risk.
‘Baiting’, ‘hounding’ and ‘calling’ are common methods used by hunters to kill wild canids. These activities essentially facilitate a ‘forced dispersal’ outside of the suggested “core occurrence areas”.
The “core occurrence areas” are too small to sustain viable wolf populations.
Climate change is impacting the environment in unpredictable ways; numerous predator and prey species are being forced to alter their ranges and adapt to habitat disruptions. Limiting the hunting and trapping ban to three small “core occurrence areas” will likely not allow Algonquin wolves to relocate as needed if weather patterns, sources of prey and habitat changes dictate the necessity.
The Ottawa River poses a significant geographic barrier to this threatened species. To preserve Algonquin wolves and allow for gene flow to populations in Québec, as well as protected areas north of their extent of occurrence (e.g. Lake Superior Provincial Park, Chapleau Crown Game Preserve), we recommend that wolf and coyote hunting and trapping is also closed in the following WMUs: 28, 29, 31-34 & 40.
We have chosen the WMU as the unit for closures, in lieu of townships, as the WMUs have more biologically relevant boundaries and enforcement at this level is simpler given the existing maps made available to the public. In all cases, the closures must be year-round, as dispersal times vary for individual wolves.
In support of the closures we have outlined, we document the positive benefits to the Algonquin wolf population and local economy following protection implemented in townships adjacent to Algonquin Provincial Park (APP), and scientific rationale outlining why the three proposed closures are insufficient to protect Algonquin wolves or lead to a population recovery of this unique species.
1. Wolf and coyote killing ban in Algonquin Provincial Park and adjacent townships.
In 2001, a moratorium was placed on killing wolves, coyotes and their hybrids in the townships adjacent to APP in recognition of the significant mortality occurring immediately outside of park boundaries, and concerns about the viability of the park wolf population as new genetic evidence concluded that these wolves were a unique species Canis lycaon (Wilson et al. 2000). This protection was made permanent in 2004. These two proposals earned widespread support from the public, and subsequent research concluded that the protection afforded to canids inside and adjacent to APP had several important positive effects on the park’s wolf population and social structuring:
a. The wolf density inside the park stabilized almost immediately following the ban in 2001 (Theberge and Theberge 2004, Rutledge et al. 2010b). Widespread culling of the park wolves in the 1960s was responsible for introgression of coyote genetic material (Canis latrans) into the park wolf population (Rutledge et al. 2011). Therefore, despite many years of culling, the park’s canid population was likely saturated, supported by evidence showing that packs of wolves, coyotes and hybrids were found to be spatially segregated within the park (Benson and Patterson 2013). This explains why the wolf population did not increase significantly following the hunting and trapping ban. While the stabilization of Algonquin wolves within Algonquin Provincial Park is a measure of success, it is not adequate to allow for dispersal, nor full species recovery.
b. The ban restored the natural, family-based pack social structure of the Algonquin wolves (Rutledge et al. 2010b). The authors stress that:
“Despite the high kinship within packs, incestuous matings were rare. Our results indicate that even in a relatively large protected area, human harvesting outside park boundaries can affect evolutionarily important social patterns within protected areas. This research demonstrates the need for conservation policy to consider effects of harvesting beyond influences on population size.”
Furthermore, research suggests that maintaining family-based relationships in social wildlife species is evolutionarily important in maximizing fitness (Silk, 2007), which is a crucial element of species-at-risk recovery and persistence. For wolves specifically, the authors describe the benefits of maintaining natural, family-based social structures:
“Wolves are highly intelligent animals that have evolved under a family-based social framework. Although the influence of this structure on fitness is not well understood, recent work suggests that maintaining the social organization of wolf packs is important for effective resource use (i.e. knowledge of prey
distribution and ability to detect, pursue and subdue prey) (Sand et al., 2006; Stahler et al., 2006), pup survival (Brainerd et al., 2008; Schmidt et al., 2008), and may be effective, at least in part, at precluding hybridization with coyotes (C. latrans) due to the lower turnover of individuals within packs and the tendency during hybridization events for genes to flow from the more common into the rarer species (Grant et al., 2005). Breeder loss is particularly influential and can result in abandonment of territories, dissolution of social groups, and smaller pack size (Brainerd et al., 2008). Mate loss can also result in unusual behavioural responses of the surviving breeder (Smith and Ferguson, 2005) or incestuous pairings if mate loss occurs close to breeding season (VonHoldt et al., 2008). Minimizing the anthropogenic impact on social structure in populations that form highly related groups is likely to improve overall fitness by allowing evolutionary processes to occur in response to natural selection, not human-mediated mortality (Darimont et al., 2009). In this way, conservation strategies can bolster the adaptive evolutionary potential of populations facing environmental fluctuations, including climate change. When compared to other conservation and management approaches such as translocations and habitat restoration, reducing levels of exploitation by expanding no-harvest zones to include areas outside park boundaries is a relatively simple, long-term solution to promote persistence of top predators that are integral to healthy ecosystems (Terborgh et al., 2001; Soule et al., 2003; Chapron et al., 2008).”
c. The protection zone is associated with a larger proportion of Algonquin wolves relative to other canids (Benson et al. 2012, Rutledge et al. 2010a) and some data suggest that Algonquin wolves may be able to exclude and/or displace eastern coyotes (Patterson pers. comm.).
d. The Park wolves are world-famous and contribute positively to the local economy, having attracted over 167,000 people from all over the world to the Public Wolf Howls that take place in August, 4 times per year. Wolf ecotourism contributes a significant amount of money to the local economy around Algonquin and Bonnechere Provincial Parks, offsetting the potential economic effects of reduced hunting and trapping.
2. Proposed closures around Killarney Provincial Park (KPP), Kawartha Highlands Signature Site (KHSS) and Queen Elizabeth II Wildlands (QEIIW) are insufficient to recover the Algonquin wolf population.
COSSARO described the extent of occurrence for Algonquin wolves using single record locations for confirmed individuals. Approximately one third of the records of individual locations found outside of existing protection in and adjacent to Algonquin Provincial Park fall outside of the proposed closure areas.
It is inaccurate, misleading and inappropriate to describe the three proposed closures as “core occurrence areas” or to use these areas as sufficient for survival and recovery of Algonquin Wolves, for the following reasons:
a. Search effort has been minimal and limited outside of provincial parks; there may be as-yet unidentified clusters of Algonquin wolves that have successfully established beyond the parks, for example where human access (via roads etc.) is low enough and moose density is high enough to allow persistence despite ongoing hunting and trapping at a coarser scale (see Benson et al. 2014). Continued hunting and trapping of wolves outside these areas could prevent dispersal and recovery of Algonquin wolves.
b. The most recent surveys have found sparsely distributed Algonquin wolves along the periphery of the extent of occurrence, suggesting that the currently described extent of occurrence is a conservative estimate. For example, the most recently identified Algonquin wolves have been recorded near Sault Ste. Marie and Minden.
c. The proposed closures encompass a small portion of the complete extent of occurrence. This would provide inadequate protection for a species with large territorial requirements. In addition, this would limit dispersal and could potentially lead to in-breeding ingression.
d. Algonquin wolves, coyotes and their hybrids are wide-ranging animals. The records used to create the extent of occurrence polygon are single locations that do not accurately depict the home range, territory or dispersal patterns of individual Algonquin wolves. The extent of occurrence is therefore a conservative estimate of the Algonquin wolf’s true range or habitat. The average minimum (straight-line) distance that an Algonquin wolf travels from its natal pack is 32km (Patterson pers. comm.). There have been two recorded Algonquin wolves (Patterson pers comm. & COSSARO 2016) in areas very far from Algonquin Provincial Park, the presumed source of the population (Benson et al. 2013), providing clear evidence that at least some Algonquin wolves travel hundreds of kilometers in search of mates, territory, and/or prey. In addition, the extensive travel of some wolves, often referred to as “dispersers”, may be essential for maintaining genetic diversity and thus integrity.
e. The proposed closures are too small and disconnected to protect individual Algonquin wolves throughout their life cycle. Dispersal is a process inherent to the animals’ survival and recovery through establishment in new areas; without this ability to disperse and recover, there will be a significant adverse effect on the species. Moreover, it is unlikely that viable wolf populations can be supported in such a small area (Theberge 1991). The proposed closures are largely disconnected from one another and from Algonquin Provincial Park, except for a narrow corridor connecting the Algonquin panhandle to the closures proposed north of Kawartha Highlands Signature Site. Provincially funded research showing satellite-tracked movements of confirmed Algonquin wolves has provided clear evidence that wolves living in the areas where the closures have been proposed are not restricted to the closed season boundaries.
It is important to recognize the possibility that outside of APP, Algonquin wolf clusters around KP, KHSS and QEIIW are not viable to begin with.
“Increased human-caused mortality of wolves and coyotes in harvested areas outside of APP may result in higher rates of mate turnover. Understanding whether the pre-reproductive mechanisms that have maintained the distinct population in APP are intrinsic or environmentally mediated, and whether they are also exhibited by the patchily distributed eastern wolves in unprotected landscapes would provide insight into whether these wolves represent viable extensions of the APP population. If these mechanisms are absent at lower densities, the occurrence of highly assigned eastern wolves outside of APP may be ephemeral and largely maintained by regular dispersal from the park.”
(Benson, Wheeldon and Patterson, 2012).
Given the high risk of Algonquin wolf mortality due to hunting and trapping outside of protected areas (Benson 2013), it is alarming that the government would knowingly jeopardize the survival of individuals that cross the proposed closure areas; these closures are biologically and ecologically meaningless to wolves and coyotes.
Regardless of the biologically flawed definition of “core occurrence areas”, it remains that the Endangered Species Act was created with the intent of recovering species facing high risk of extinction, and this proposal insinuates that all wolves, coyotes and wild canid hybrids occurring outside of these three proposed closures are not worth protecting. This is completely unacceptable given the rarity of the Algonquin wolf, population size, substantial evidence showing that hunting and trapping are the primary threats to the species, and ecological and inherent value of all species, sub-species and hybrids.
f. Algonquin wolf mortality across the extent of occurrence is unknown, but likely significant. The Algonquin wolf population is unlikely to expand without further protection (Benson 2013). Despite the fact that these wolves have been listed as a species at risk for over a decade, management regimes pertaining to wolves and coyotes in Ontario do not provide adequate data for the government to quantify Algonquin wolf mortality:
i. Ontario previously defined a “core wolf range” where small game licence holders can purchase up to two wolf/coyote game seals per year for use between September 15th and March 31st, and mandatory reporting averages approximately 60% (Stuart pers comm.). To begin, the government does not have sufficient numbers of conservation officers to enforce these restrictions. Secondly, the low reporting rate of data required by hunters holding wolf/coyotes seals (data which we emphasize is not necessarily accurate, as it is collected by special interest groups and is at best, anecdotal given that coyotes and wolves cannot be identified using visual cues, and the surveying consistency between hunters has not be analyzed) appears to be without consequence. Hunters who do not report their take should be denied a licence the following year, as trappers are denied access to traplines when they do not report their take. MNRF must hold each hunter licensed under the FWCA accountable to the regulations.
There are no trapping bag limits and trapping data is compiled provincially without finer scale analysis (Stuart pers comm.) which is required to determine the amount of trapping occurring within the Algonquin wolf’s extent of occurrence. Like hunters, trappers are unable to differentiate between Algonquin wolves, coyotes or their hybrids and are therefore unable to accurately report how many of each species they have killed. However, MNRF still required trappers to differentiate between “wolf” and “coyote” which is extremely inconsistent. That MNRF does not require genetic assignment testing of commercially sold pelts is alarming and leaves room for further exploitation of a species which is supposed to be protected by law.
ii. In southern Ontario, coyote/wolf hunting and trapping are permitted year-round without bag limits or mandatory reporting requirements. The extent of occurrence of Algonquin wolves includes areas under this management regime. Absolutely no information has been obtained by the government to quantify the probability of wolves dispersing south into habitat identified as historical range by the Committee on the Status of Species At Risk In Canada (COSEWIC) and currently available in the Adirondack region (COSEWIC 2015). This is antiquated, unethical and scientifically unsound management; coyotes and wolves in southern Ontario receive no protection, not even during periods of the year when they are nursing and raising their young. Thousands of animals are killed every year under the pretence of “population control” which research continues to show to be ineffective, unnecessary and which can exacerbate conflicts such as livestock depredation (Wielgus and Peebles 2014. Musiani, M. and P. Paquet 2004).
It is very concerning that for many years ongoing killing of at-risk Algonquin wolves, across their extent of occurrence, has barely been quantified or mitigated. Algonquin wolf populations would likely be unviable within the proposed closures, which are insufficient at protecting even individual wolves throughout their life cycle. To increase the probability that Algonquin wolves recover, all wolf and coyote killing in the above mentioned WMUs must be banned under the FWCA, in line with the intent of the protection provisions outlined in s. 9 of the Endangered Species Act.
While these three closures are marketed as an interim strategy as we await the Ontario government’s Recovery Strategy and Response Statement, we would like to take this opportunity to remind MNRF that a Management Plan has been overdue since 2008, as mandated by the Endangered Species Act and federal Species At Risk Act since the wolves’ listing as a species of Special Concern. Furthermore, these proposals ignore the vast majority of Algonquin wolf research that has been undertaken by experts. Ignoring the science at the behest of the profits made by hunters and trappers is an abysmal waste of the money that supports the wildlife research division, as well as the time, energy and skills that numerous biologists have dedicated to the study of Ontario’s wild canids.
The province of Ontario released then-progressive provincial wolf and black bear conservation strategies in 2005, recognizing that large carnivores are ecologically and inherently invaluable and irreplaceable. A provincial coyote conservation strategy is long overdue, and we urge the MNRF to prioritize the conservation of all canids alongside the implementation of meaningful regulatory changes that will stand a real chance at recovering at-risk Algonquin wolves.
#410 – 401 Richmond St. W., Toronto, ON M5V 3A8
Hannah Barron, Director of Wildlife Conservation Campaigns
Coyote Watch Canada
P.O. Box 507, 341 Creek Rd., St. David’s, ON L0S 1P0
Lesley Sampson, Founding Executive Director
Wolf Awareness Inc.
R.R. #3, Alisa Craig, ON N0M 1A0
Sadie Parr, Executive Director
Animal Alliance of Canada and Animal Alliance Environment Voters Party of Canada
#101 – 221 Broadview Ave., Toronto, ON M4M 2G3
Liz White, Director and Leader
Bear With Us Inc.
3113, Hwy 518 W., Sprucedale, ON P0A 1Y0
Mike McIntosh, President
31 Colonel Butler Dr., Markham, ON L3P 6B6
Barry Kent MacKay, Senior Program Advisor
Canadians for Furbearing Animals
124-2 Clarendon Ave., Toronto, ON M4V 1H9
Citizens United for a Sustainable Planet
1181 Sunrise Beach Dr., Shuniah, ON P7A 0Z5
Paul Berger, Meetings Chair
Humane Society International/Canada
4035 Saint-Ambroise St., Suite 320, Montreal, QC H4C 2E1
Rebecca Aldworth, Executive Director
179 W. Broadway, Vancouver, BC V5Y 1P4
Lesley Fox, Executive Director
cc. Hon. Kathleen Wynne
Premier of Ontario
Hon. Kathryn McGarry
Minister of Natural Resources and Forestry
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