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Bill 108: The Demise of Ontario’s Endangered Species Act

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On June 6th, and without much fanfare, Ontario’s endangered species were stripped of the foundational protection afforded to them by the Endangered Species Act. Hidden in a “housing bill” alongside a number of other changes to legislation – the Environmental Assessment Act, the Environmental Protection Act, the Conservation Authorities Act, and the Ontario Heritage Act – which will do nothing to solve Ontario’s housing crisis, were 20-pages of legal amendments removing almost every single requirement designed to protect and recover species at risk.

The Progressive Conservative’s Bill 108 gives industry a pass to slay at-risk species, pave over their homes, extract natural resources in critical habitat, and cause unbridled destruction of sensitive ecosystems.

The timing of these changes are almost unbelievable – an about-to-be-published UN report concludes that the human-caused mass extinction is putting a million different species on the brink. Meanwhile, Ontario’s own species at risk, now numbering 243, have been swept into the arms of an all-powerful Minister of Environment.


Wasted opportunity for improvement

27 The demise of the Endangered Species Act was carefully and quietly introduced as a “10-year review”, an opportunity to consult about what was working, and what was not working, for Ontario and its imperiled species.

We’re under no illusion that prior to the 10-year review that the Act was being implemented in such a way as to effectively protect and recover species at risk. Certainly there was a lot of room for improvement in the Act’s implementation.

A perfect example is the “permit-by-rule” system. The previous Liberal government had a history of abusing this mechanism in the Act to exempt a slew of user groups from the prohibitions of killing threatened and endangered species or destroying their habitat. Thanks to permit-by-rule, forestry companies are allowed to destroy threatened caribou habitat, hunters and trappers are allowed to kill threatened Algonquin wolves, and endangered American eels are being cut up in hydroelectric dams—and these are just a few examples of exemptions that predated the new government.

None of the activities exempted this way were being monitored. Simply put, we had no way to measure how bad ongoing destruction was.

What we did have was an important backstop to benchmark a species progress (or regress): science– the essential tool wielded by expert and objective scientists who study Ontario’s biodiversity and the individual and often magnificent components of it.

Science in and of itself has no value unless it’s being used. Until last week, science was a foundation of the ESA.


A species’ journey through the Act

15 The species assessment committee called COSSARO (“Committee on the Status of Species At Risk in Ontario”) is a group of scientific experts that objectively determine whether a species is at risk or not in our province. If a species in trouble, depending on the severity of threats and the species’ rarity, COSSARO places it in one of the risk categories – special concern, threatened, endangered, or worse yet, extirpated (extinct in Ontario).

Before the Act was gutted this month, species assessments led to automatic legal listing of species on the Act’s Species At Risk in Ontario list (SARO list) a quick 3 months after assessment. If a wildlife or plant species made it to the SARO list as either endangered and threatened, it gained automatic protections under the Act. This makes sense; threatened and endangered species need immediate protection to stand a chance at bouncing back over the longer term while they wait for their recovery to be mapped out.

To direct recovery, a science-based Recovery Strategy was then due within a year of a species being listed as endangered (within two years for those listed as threatened). Then came the Government Response Statement within another 9 months, which is where politicians decided which activities suggested in the Recovery Strategy would actually be undertaken within a socioeconomic context.

For those species listed as special concern, the science-based Management Plan is due within 3 years, where important evidence-based suggestions are suggested. Special concern species don’t get any protection unless the government decides it’s necessary and willing to enact them.

Once government-directed actions are underway, a Progress Report would be due 5 years later to determine how well the species is doing. The cycle is complete when the species gets re-assessed by COSSARO every 10 or so years.

This cycle boded so well for species at risk it was dubbed “the gold standard”. What a marvel of integrated science and decision-making was promised when it was rolled out in 2008! Built-in flexibility meant that socioeconomics of recovery were considered as long as species’ recoveries were the priority. Provided a scientific expert concluded to the Minister that an activity or exemption wouldn’t jeopardize the recovery of species, harmful activities that could kill species and destroy their habitat were still allowed to happen in a controlled way. The Act was written so that it could carefully regulate ongoing destruction that was deemed necessary for the human community through the use of permits and authorization tools that either minimized adverse impacts, or provided some other overall benefit to a dwindling species on the ground nearby to where any habitat destruction was taking place.

It was in 2013 that the reigning Liberal government introduced a fistful of permit-by-rule exemptions that allowed destruction of certain species or in certain areas, enormous and embarrassing delays in the development of Recovery Strategies and Government Response Statements, which in turn delayed Progress Reports, and made it harder for scientists to use reliable updated data to re-assess a species.

Meanwhile, the Environmental Commissioner figured out that none of the exempted activities were being monitored, and that the Ministry didn’t track any compliance monitoring or enforcement for any other permit or authorization given to industry or landowners to conduct activities that harm species at risk or their homes.

These were important sticks stuck in the wheel of the Act, a wheel which was designed to move us forward toward a future where hundreds of species weren’t about to disappear from Ontario, perhaps forever.


The future of Ontario’s endangered species is now under more threat than ever before

38Fast-forward to 2018, when the Progressive Conservatives took over and the Act’s 10-year anniversary triggered them into announcing a “review”.  A review of a poorly functioning Act is in theory well-deserved. But then the PCs rolled out a discussion Paper, a single paltry consultation with biodiversity proponents (industry proponents each got their own consultation), an unclear summary of expected amendments, followed by 20 pages of legal language that spelled out the doom of the Endangered Species Act. This was all written under the guise of improving the Act, removing red tape, and importantly “ensuring positive outcomes for species at risk”.

What really happened was this. Timelines to assess, list, monitor, plan, and report were lengthened dramatically. COSSARO will now be open to special interests, diluting the scientific expertise and objectivity that are essential to accurate species assessments. COSSARO is also now required to match the assessment status of species that are doing OK elsewhere, but only if it means the species status will be downgraded. Extinction in Ontario isn’t an issue if the species still exists somewhere else, according to Premier Doug Ford. On the other hand, he doesn’t want us to panic when a species is going extinct next door. This compartmentalization of recovery planning is irrational. Wild animals don’t know where borders are, and certainly our federal government does an abominable job at forcing the provinces and territories to take action for imperiled species even though it’s written right into the federal Species At Risk Act.

What could be worse than diluting science and forcing their hand in assessments? Answer: under the new and not-so-improved Act, the Minister no longer has to consult a scientist before deciding to allow or exempt activities or proponents from killing species at risk or destroying their homes. In fact, businesses will now be able to pay to do this, and that money will be used by some “crown agency” which will have to make tough decisions about which species might benefit from the blood money, and which ones will be ignored and left to disappear.


Our rights to participate in decision-making processes have been undermined

35The scariest part for me (and this is coming from a biologist whose work to recover Algonquin wolves is being deliberately undermined by special interests and politicians who hate, fear and misrepresent the wolf) is that to rip up the Endangered Species Act so badly, the government also had to tear into our Environmental Bill of Rights to remove the sections saying that the public had to be notified and consulted when these arbitrary, political and anti-biodiversity decisions are being made by the Minister.

If this isn’t a cover up, I don’t know what is.

How can politicians claim that this is going to be good for species at risk, that it’s going to make a better Ontario? How can so many provincial representatives ignore the concerned scientists, the outraged municipal governments and the environmental community? Last time we checked, consultation meant listening to everyone, and taking all information into consideration. Checking off the wishlists of developer buddies and natural resource extraction CEOs is not what the Environmental Bill of Rights meant by consultation.


This is in no way “For The People”.

10Let’s not kid ourselves. We know what is going to happen when a Minister is handed all the power to control species at risk, and it’s hardly ever going be to be a “positive outcome” for wildlife or rare plants. The new Endangered Species Act is a gift to housing developers in the south, hunters and trappers across the province, and natural resource extraction companies in the north. Logging companies will gain permanent exemption rights to destroy caribou habitat, mining is going to wipe out species habitat in the Ring of Fire, dams will continue to chop up endangered American eels, and Algonquin wolves will continue to be shot and strangled in neck snares for sport and profit. Wetlands, green corridors, vernal pools and vestigial forest in southern Ontario will be paved over and covered in houses that most Ontario residents will never be able to afford.

We are indeed in a housing crisis, but it is not limited to the houses of humans. More than the Endangered Species Act, Bill 108 – the housing bill – changed over a dozen other acts that will negatively impact every species that needs a secure home in this province, whether it’s a low-income person, an endangered salamander or a woodland caribou calf.

This government has it out for our species at risk. These species are the canary in the coal mine of so-called progress and the open-for-business mentality that Ford and company have been promoting for the last year. It seems too few governments are willing to recognize and address that species at risk recovery is inconvenient and will require science and tenacity to guarantee. There’s no denying that legislation geared to protecting and recovering them necessitates us to do business a little differently. After all, it’s just one species – our own – that is largely responsible for putting a million others at the precipice of extinction.

It’s hard to believe that any government can ignore the stark findings from UN reports about losing species, losing biodiversity, and losing intricate ecosystems that deliver invaluable, unimaginable, and often unmeasured services that we as the human race rely on for our very survival. The UN report reminds us why we should care about species at risk: without them, we face ecological collapse. How can a government “for the people” put our species at risk too?

At this point, asking head-scratching questions like this is a waste of time. Now we stand together. Now we fight for our human families, for our wildlife community, for the web of life that connect us all and gives us shelter. If we don’t fight now, it’ll all be gone. Please take action now! Extinction is forever.



Save our Endangered Species

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We need your help to stand up to the Progressive Conservative government who have just proposed sweeping changes to the Endangered Species Act (ESA), and to our Environmental Bill of Rights (they intend to cut the public out of further consultations on species at risk!).

The Algonquin wolf is being targeted again, even though they lost so much of the automatic protection the ESA should have given them under the ESA back in 2016.  They can’t afford to lose anymore safeguards from hunting and trapping!

Please send your official comments today.  By adding just one line or comment in your own words to our template letter, your voice can have an even bigger impact with the decision-makers!

The deadline for submissions is May 18th.

I am not protected


Will you go one step further and share our action alert with your friends, family and social networks? This consultation is the most important we’ve ever asked for your help with, and since our last round of comments which opposed further weakening of the ESA have largely been ignored, we need to get LOUDER!

Here’s how the proposed changes will impact Algonquin wolves:

1. The Minister will be allowed to remove or reduce protections for any threatened or endangered species, and doesn’t have to notify or consult the public, or ask species experts for their professional opinion;

2. The Minister can demand that COSSARO, the independent scientific body that conducts assessments of species at risk, re-assess any species. Moreover, the scientists will have less time to report, and COSSARO members may no longer be independent since the eligibility requirements are about to change;

3. Timelines for the government to create an action plan once a species’ science-based Recovery Strategy is finalized will be weakened. They also want to loosen monitoring of the recovery plan, meaning they don’t have to report on progress they don’t plan to make.

For Algonquin wolves this could even mean removing their protection from provincial parks that still allow hunting and/or trapping (most of them do!), even around Algonquin Park where the science clearly indicates how beneficial the no-kill zone is.

In a landscape populated by coyotes that have a better chance of survival, Algonquin wolves won’t stand a chance at recovery if their entire range is opened up to hunting and trapping again. If COSSARO re-assesses them as endangered in their next round of review, it won’t make a difference in legal protections if the proposed amendments go through.

Extinction is forever,  please speak for Algonquin wolves and the other 230+ species facing extinction in our beautiful province

Media Release: Earthroots echoes Environmental Commissioner’s call to recover at risk wolves

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Ontario needs to protect threatened Algonquin wolves from hunting and trapping

TORONTO (October 24th, 2017) – Today Ontario’s Environmental Commissioner Dianne Saxe released her annual report, “Good Choices, Bad Choices”, a critical assessment of the Ontario government’s environmental practices and recent decisions. The report outlines multiple areas where the province is failing to take effective action on pressing environmental issues.

In particular, Commissioner Saxe emphasizes that the Algonquin wolf, a unique species that was listed as Threatened last year, needs more protection. Threatened species receive immediate province-wide protection under the Endangered Species Act but the protection of Algonquin wolves was stripped down to 4 provincial parks and buffers around them on the opening day of hunting and trapping season in 2016. Outside of these areas, where eastern coyotes are heavily hunted and trapped, Algonquin wolves receive no protection because it is difficult to visually distinguish them from each other (a genetic test is required to correctly identify them).

“It is critical that our government upholds the objectives of the Endangered Species Act, and prohibits non-aboriginal hunting and trapping of Algonquin wolves across their range,” said Hannah Barron, Earthroots Director of Wildlife Conservation Campaigns. “We need our government to take immediate measures to protect these wolves – there may be as few as 250 mature Algonquin wolves left in the world, mostly in Ontario. Scientific research funded by the Ontario government shows that without additional protection, this small yet ecologically invaluable population of top predators will not recover.”

The Algonquin wolf is the only Threatened species that can be legally sport hunted and trapped, even in some protected areas. Commissioner Saxe builds on this point in her report, stating that, “Thousands of Ontarians expressed concerns about the inadequacy of the government’s new measures to protect Algonquin wolves. If the MNRF is incapable of protecting a small number of threatened Algonquin wolves in only one part of the province, it creates doubt about the ministry’s commitment to sustainably managing any species of wildlife – let alone an imperilled one.”


For more information, contact: Amber Ellis, Executive Director, / 416-565-0795

Key Excerpts: Good Choices, Bad Choices

“Hunting and trapping is a central threat to the long-term survival of the Algonquin wolf, which is a threatened species at risk. Ontario’s Endangered Species Act prohibits threatened species from being killed or harmed, but the Ministry of Natural Resources and Forestry has chosen to exempt the Algonquin wolf from this important protection across much of its range. The ministry has opted to only protect Algonquin wolves from hunting and trapping in and around a few isolated provincial parks. Scientists have concluded that the Algonquin wolf stands little chance of recovery unless the ministry bans hunting and trapping of wolves and coyotes throughout its range.” (ECO 2017, Good Choices, Bad Choices, page 253)

“The three new areas with closed hunting and trapping seasons will not suffice. These areas cover only a small fraction of the region where Algonquin wolves have been found. Moreover, the newly closed areas primarily consist of provincial parks – where the Algonquin wolf already received substantial protection – doing little to change the status quo. The closures also do not provide adequate connectivity between these areas.” (ECO 2017, Good Choices, Bad Choices, page 265)

“Controversy has surrounded how the Ontario government has managed eastern (or Algonquin) wolves for decades. Scientists believe that there may be less than 250 adult Algonquin wolves left in the world. The top threat to the long-term survival of the threatened Algonquin wolves is hunting and trapping. Unlike the pressures facing many other species, the Ontario government has the ability to easily eliminate the biggest threat to Algonquin wolves by simply amending a regulation.” (ECO 2017, Good Choices, Bad Choices, page 266)

“The Ministry of Natural Resources and Forestry is not only turning a blind eye to the best available science, it is also disregarding the significant public interest in protecting this ecologically and culturally significant animal.” (ECO 2017, Good Choices, Bad Choices, page 266)

“Algonquin wolves must receive the full protection of the law if this threatened species is to have any chance of recovery. Algonquin wolves need to be protected from Peterborough to North Bay, and from Pembroke to Sault Ste. Marie. The ECO recommends that the Ministry of Natural Resources and Forestry prohibit hunting and trapping of wolves and coyotes throughout the Algonquin wolves’ entire “extent of occurrence” (i.e., where they live).” (ECO 2017, Good Choices, Bad Choices, page 267)

Help Keep Wildlife Wild

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Feeding Wildlife – Never A Good Idea


There’s a reason the phrase “a fed bear is a dead bear” has become part of our lexicon. More than just bears, all wildlife can become food-conditioned when presented with a tasty reward. Whether it’s camp food dumped in a fire pit while you’re packing up to leave, garbage bags on the side of the road long before pick-up, or trail mix being handed out a window in order to get a close-up photo of a wild animal, feeding almost always ends badly for the wildlife.

Most wildlife is wary of people. This strategy helps to keep them safe. It also makes us more excited when we get the rare chance to see and observe a wild animal going about its normal activities. There’s never been a time that I’ve driven through Algonquin Park’s highway 60 corridor and not spotted at least a few cars on the side of the road watching a moose eating in a marsh, or a turtle making its slow, annual trek to a nest site to lay its clutch of eggs.

The most rewarding observations for us are the ones where we get more than a split second to watch them. Despite spending many hours tracking wolves for research, I’ve only actually seen an Algonquin wolf once – as I was driving, it darted across the road and disappeared after a quick glance in my direction that seemed to stop time.

I still remember that feeling that I was left with. I think of it every time I talk to someone about wildlife they’ve encountered. Most of the time, people are telling me about wildlife they spotted unexpectedly. Sometimes, though, I listen to stories of people watching people watching wildlife. These days, the thrill of wildlife-watching seems to be dampened if not shared on social media, and so people become increasingly bold, approaching a moose or a bear or a fox more and more closely to get just the right selfie.

Bold. That’s a word I hear much more often in reference to wildlife, rather than people. That, or aggressive. If I asked the person feeding wildlife that someone else has labelled bold, I would hear words like friendly, tame, cute or magnificent. The interpretation is our own, skewed by our own feelings of security or excitement. One person is happy for a wolf to come close enough to take food right from their hand. The next person feels threatened when the wolf goes to do the same thing to them expecting a similar food reward, when all the person wanted was a photo from their car window. Biologically, that animal has learned that people provide food, and that food is easier to come by than hunting for itself. Why not wait around for the next person to safely feed it rather than go back to the woods and look for a moose?

An animal is food-conditioned when it expects all people will feed it. It might try harder for food, prompting the person to understand what it’s supposed to be doing. Eventually someone will call the police or the park warden. Or maybe the wolf is struck and killed while it’s waiting on the road for oncoming traffic to stop and hand out some food. These situations escalate to a point where both people and wildlife are put in dangerous situations.

At this point you might be thinking, “What kind of person shares their lunch with a bear or a wolf?” What we all need to remember is that feeding wildlife comes in all shapes and forms. We may not even know who is eating the leftovers from our campsite or bird feeder. Our impact on wildlife usually goes unnoticed until something goes badly wrong.

For anyone who would never knowingly put wildlife in danger, but believes we can reverse the environmental damage humans do by feeding wildlife to help make their lives a little easier, please think carefully the next time you feel compelled to leave food out. Wild animals that are not ill or badly injured are perfectly able to forage for themselves – this is what keeps them safe in a world where human encroachment on the environment continues at an alarming rate. If an animal is in poor condition, you should call the relevant authorities, rehabilitators, animal control, or contact us to ensure the animal gets the help it needs. Everyone needs to understand that they are not helping wild animals by feeding them. Let’s keep wildlife wild for their sake and for ours!




How many wolf species are there in North America?

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Last summer, right before the Ontario government decided to reduce province-wide protection for threatened Algonquin wolves to a few provincial park buffers,  a research paper made major headlines across the USA announcing evidence that eastern wolves (AKA Algonquin wolves) and red wolves were simply hybrids of grey wolves and coyotes, rather than unique wolf species.


In response to that research, a group of genetic experts from across North America published a review of last year’s genome data study this month.   Following a critique of the original study design, including unrepresentative groups of coyotes and eastern wolves and inappropriate hypothesis tests, they concluded that the genomic data still support the case that red and eastern wolves evolved a very long time ago. While they are now two distinct populations of similar wolves with different names, both are species-at risk, and both are able to mate with coyotes and grey wolves. It is this current hybridization that occurs in parts of their range that makes genetic research on wild canines confusing at best. However, the researchers show that the individuals from the red/eastern wolf lineage are distinct from the more common grey wolf and coyote species.


Genetic research progresses as tools are developed to look at and compare more and longer sections of DNA, and it was therefore no surprise when last year’s research was published in major newspapers in the USA after being the first to use the full genome of wolves and coyotes to discuss the evolution of these animals. As far as wildlife genetics goes, the wolf species debate has been a hot topic – wolves are in the news frequently being charismatic, controversial, some facing extinction while others face government killing programs.


Unfortunately, we tend to get caught up in the species-number debate: how many wolf species are there? Are red wolves and eastern wolves really different from the grey wolf? When did the eastern wolf become the eastern wolf? These questions have detracted from the most important, and indeed perhaps the only agreed upon conclusions from both side of the scientific discussion: that top carnivores are ecologically valuable, that the ‘species’ definition in endangered species legislation is too inflexible (after all, even humans genomes aren’t “pure” – we have neanderthal DNA) and that wildlife policies should strive to conserve the genetic diversity of populations, especially in the face of climate change. We hope that this ongoing discussion redirects decision-makers back to the conservation of biodiversity at all scales – both species, and genetic.

Are we acting on wolves or are they acting on us too?

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When I was completing my Masters thesis, I had the opportunity to work with Dr. Stephanie Rutherford in reviewing the history of wolf management in North America. With the information collected, Rutherford asked an interesting question: What role do wolves have in shaping policy as active participants rather than just passive subjects?

The response draws from Donna Haraway’s book When Species Meet which suggests that people and animals influence each other through interactions, and that animals can resist or cooperate with us. Acknowledging animals’ agency contributes to the establishment of what is called a biopolitical view of policy, where the goal is to promote the mutual flourishing of humans and animals rather than asserting human dominance. Management for, rather than of, species – ourselves included.

Historically, wildlife policies have excluded animal agency from consideration, instead understanding animals as materials for capital gain. Wolf management has long been equated with bounties, poisons and other tools of systematic eradication, treating living wolves as economic risks and dead wolves as a source of currency. Tools such as bounties provide economic aid to rural communities and reassert human control over nature. While there is little evidence that wolf control is financially beneficial, bounties and killing contests continue in many parts of Canada even today at a great cost to government and wildlife.

It became clear that a new relationship between humans and wolves was emerging in Ontario in 1963 with the first Algonquin Park Public Wolf Howl – an unexpected hit that continues to draw people in by the thousands each August. Less than 10 years after the public howls began, bounties were banned in Ontario.

Tourism, research and even urbanization have resulted in the public’s attitude of wolves moving away from fear and intolerance, and toward appreciation. Perhaps because of the park’s popularity as a tourist destination or the unique genetics of its wolf inhabitants, Algonquin has become something of an exception within Canada. This exceptionalism is perhaps best exemplified by the province’s 2001 decision to ban wolf and coyote killing adjacent to the park boundaries to preserve the wolves’ genetic identity even before they were recognized as a Threatened species.

This exceptionalism is perhaps because we have been interacting with them via hugely popular park programs, rather than strictly acting upon them. Through these types of positive interactions, our policies may well continue to be changed by the wolves themselves, persuading us to see them as more than just capital.

Across Canada we appear hesitant to relinquish our dominance over ecosystems, instead preserving our ‘control’ by killing predators. The ongoing governmental wolf eradication programs in British Columbia and Alberta suggest that wolves are still widely considered an economic or ecological threat to be controlled. Instead, let us learn from the Algonquin experience and consider a new biopolitical approach that aims to establish policies beneficial to humans and wolves alike.

Adam Marques, MSc

Guest contributor

Launching the Ontario Wolf Survey

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ontario-wolf-survey As 2016 drew to a close, we launched a new non-invasive research program called the Ontario Wolf Survey.  Designed to target areas identified within the Algonquin/eastern wolf’s suspected range, we collect urine, scat and hair samples for DNA profiling to identify whether local canids are either Algonquin wolves or the more numerous eastern coyotes.

By identifying more Algonquin wolves living in protected and unprotected areas of the province, our data will contribute to the information collected by provincial staff from the Ministry of Natural Resources and Forestry, as well as the Eastern Wolf Survey. At Earthroots, we realize that good policy comes from good science, and that carnivore conservation can be accomplished once we have a better idea of where rare wolves live, and how they are surviving in a landscape where they only receive partial protection.

Thanks to many generous donations to our crowdfund campaign, we completed the first round of our Ontario Wolf Survey in an area where the government has found only 1 Algonquin wolf so far. We identified and followed wolf/coyote tracks on back roads, trails, hydrolines and deep within crown forests and collected 7 frozen urine samples that  were left by canids marking their territory. These samples will be delivered to Trent University’s Natural Resources DNA Profiling and Forensics Centre for species and gender identification, and will directly contribute to provincial and academic research on the Algonquin wolf and eastern coyotes.

wolforcoyoteWe will be returning to the same area over the coming months to survey and set up a  trail camera to capture images of the elusive animals we track. We are planning  surveys further afield to fill in the geographic gaps that other researchers are unable to  get to – please consider contributing directly to our work by visiting our Ontario Wolf  Survey campaign page - donations provide you with tax receipts!

To learn more about the methods we use to collect samples for DNA analysis, and to find out how these date are used by biologists, you can read the results published in this month’s issue of the scientific journal Diversity and Distributions, featuring Dr. Linda Rutledge’s Eastern Wolf Survey.

Sign up as a Wolf Defender to receive updates about the Ontario Wolf Survey!

Looking back at 2016

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As this year comes to a close, let’s take a moment to celebrate our wolf conservation victories and look to the future!

As 2016 started, we sent thousands of comments to the Ontario government opposing their plan to liberalize wolf hunting across much of the province.  We demanded that wolves be conserved because they are both inherently and ecologically valuable, and the government listened.  Ontario’s first-ever wolf killing restrictions remain in place thanks to your support.

Come summer time, eastern wolves were renamed Algonquin wolves and listed as a Threatened species in Ontario.  In response to that up-listing (they were previously Special Concern), Ontario proposed an “interim strategy” because Algonquin wolves and eastern coyotes can’t be told apart by sight, and coyotes are heavily hunted and trapped.

Again, thousands of you rallied behind us and told the government that these rare wolves (and the coyote they resemble) must be protected throughout their range.  While the government refused to add more land to the 3 new closure areas around provincial parks where the wolves have been found, it’s important to remember that the only reason the government bothered to close any land to wolf and coyote killing at all is because they know we are watching them, and that we won’t stop until these amazing animals are better protected.

The single most important thing Earthroots can do for wolves right now is contribute to surveying research in Ontario.  If we can locate more lone Algonquin wolves or whole family packs in the unprotected landscape, we have a very good chance of extending protection to both wolves and coyotes in those areas. That’s why this year we are beginning the Ontario Wolf Survey.

Before I joined Earthroots, I had the distinct pleasure of managing Dr. Linda Rutledge’s Eastern Wolf Survey, a research project designed to refine the distribution of these rare wolves by collecting non-invasive samples in our province’s provincial parks.

It was that research that led to the protection granted to wolves and coyotes this summer.  Dr. Rutledge taught me how to research wolves non-invasively – instead of capturing, anaesthetising and collaring them with GPS beacons, a practice that is very invasive and disruptive to the wolves and their health, we collect urine, scat and hair in wolf habitat and identify the species, gender and relationships of those animals using tiny fragments of DNA.  We find the wolves, but the wolves themselves hardly notice, and continue their wild lives without interruption.  This is science at its very best.

Please give generously in support of our Ontario Wolf Survey and help put Algonquin wolves on the map so we can fight for their protection!  Each and every donation will help us reach our goal.

Do you live or travel to wolf habitat in south-central Ontario and want to get involved in the surveying? Scat surveys aren’t as gross as they sound, we promise, and we need help with trail cams too! Get in touch and we’ll plan a way for you to get involved in this landmark survey.

On behalf of the wolves and the wilderness we all enjoy, I want to wish each and every one of you a healthy and happy New Year – keep howling!

Hannah Barron

Director, Wildlife Conservation Campaigns


Media Release: Awenda Provincial Park Canis Family Shot Dead and Abandoned

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December 14, 2016

Niagara Falls – Last week, two wild canids were found shot to death and dumped in the snow just outside Awenda Provincial Park, where hunting is illegal.

The animals were identified as a female adult and female pup of the year. Upon finding the two animals the hiker notified the Ontario Provincial Police, who are now investigating the incident with the Ministry of Natural Resources and Forestry. Last week, the same hiker found three canids shot to death approximately 1km inside the park boundary. When he returned to the site several hours later, the hiker found the bodies were removed by person(s) unknown.

The hiker noted that the way the coyotes or wolves were killed is referred to as ‘rot shot’ – gunfire directed at the side of an animal, used to deliver an excruciating and slow death.

“The number of animals, their ages, and the small scale of the region in which they were found indicates they were probably a family pack,” says Lesley Sampson, Founding Executive Director of Canada Watch Canada. “Coyotes and wolves are highly social, family-oriented keystone species that manage Ontario’s diverse ecosystems. The fragmenting of a coyote or wolf family can have a drastic and detrimental impact on the stability of the family structure, while disrupting the prey/predator relationships throughout their home range.”

Hunting is currently legal in 128 provincial parks, undermining the ecological integrity of these areas.

DNA tests have not yet been performed but are required to determine if the animals are to be identified as eastern coyotes or Algonquin wolves, a threatened species in Ontario.

“Such disregard and malice directed towards coyotes is not uncommon,” remarks Hannah Barron, Director Wildlife Conservation Campaigns, Earthroots. “Top predators such as coyotes and wolves are both ecologically and inherently valuable. Provincial parks should act as refuges for these animals, particularly as coyotes and wolves can be hunted or trapped year-round without bag limits or reporting across Southern Ontario.”

Coyote Watch Canada and Earthroots encourage the public to come forward and report any information they may have about these or other poaching incidents. This information can be shared anonymously with the Ministry of Natural Resources Tip Line at 1-877-TIPS MNR (847-7667) or the Ontario Provincial Police Crime Stoppers at call1-800-222-TIPS (8477).




EBR 012-8105 Comment

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Species at Risk and Biodiversity Protection Section
Ministry of Natural Resources and Forestry
Policy Division
Species Conservation Policy Branch
300 Water Street
Peterborough, Ontario
K9J 8M5
Phone: (705) 755-1940
Fax: (705) 755-2901
RE: EBR 012-8105 Amendment of Ontario Regulation 242/08 (General Regulation – Endangered Species Act, 2007) in response to changes to the Species at Risk in Ontario List.
Thank you for this opportunity to comment on the proposed changes to the General Regulation – Endangered Species Act, 2007. We wish to express our disappointment in the Ministry of Natural Resources and Forestry (MNRF) for proposing the amendments specifically as they pertain to the Algonquin wolf. The proposal states:

“It is proposed that exemption from section 9 (species protection provision) of the ESA apply to Algonquin Wolf if the following conditions are met: • The person is hunting or trapping (including protection of property activities) in accordance with the Fish and Wildlife Conservation Act and its regulations; and • The person is outside of the identified core Algonquin Wolf occurrence areas”

The proposed amendment is inadequate for the recovery of Algonquin wolves and would effectively strip this at-risk wolf species of the most meaningful and biologically relevant protection afforded by the Endangered Species Act, namely section 9.

Below, we outline the flaws within the rationale used to justify this amendment, addressing each criteria included within the proposal, which states:

“An analysis of the regulatory provisions contained within O.Reg 242/08 was conducted for each of the newly listed species, using a range of factors including: the size of the species population in Ontario; the rarity of the species; whether the location of species and their habitats occur in the same location as the regulated activities; and whether certain types of activities are likely to adversely affect the species. Through this analysis, it is being proposed that certain provisions of the regulation would not apply to particular species added to the SARO List in 2015 and 2016, or reclassified in 2015 or 2016 as endangered or threatened. This analysis has resulted in the following proposed amendments to O.Reg 242/08:”

The criteria used are inadequate to evaluate whether there is a significant adverse effect on the species. 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 Wildlife Management Units (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, genetic diversity 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.
  • The “core occurrence areas” are too small to sustain viable wolf populations.
  • There is a high risk of hunting and trapping of Algonquin wolves outside of 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”.
  • 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 areas will likely not allow Algonquin wolves to relocate as needed if weather patterns, sources of prey and habitat changes dictate the necessity.


1. Size of the species population in Ontario.

The Algonquin wolf was recently up-listed from a species of Special Concern to the higher risk status of Threatened Species this past June. The size of the species population in Ontario taken alone is not evidence that the proposal will not cause a significant adverse effect on the species or that the proposal will not jeopardize survival and recovery. The population size is uncertain, but researchers estimate that there may be as few as 154 mature individuals in Ontario (COSEWIC 2015). Wolves live in family-based packs and are cooperative breeders, averaging between 4 and 7 pups/pack/year. Pup mortality within Algonquin Provincial Park can be high and variable, despite protection from hunting and trapping (Benson et al. 2013). The authors emphasize that low pup survival may decrease dispersing Algonquin wolves that could potentially establish outside of Algonquin Provincial Park and also outside of the proposed protected areas. It should be the goal of the Ministry to increase the survival rates of Algonquin wolves, particularly maturing and mature individuals that disperse to find mates and a territory in which to raise another litter of pups, as they contribute to the recovery and expansion of the population. Allowing hunting and trapping is contrary to this goal.

2. Rarity of the species

The rarity of the species is a factor pointing to the potential for the proposal to have a significant adverse effect and to jeopardize survival and recovery. Globally, the species exists in only Ontario and Quebec. Approximately 65% of the mature population inhabits Ontario (COSEWIC 2015, COSSARO 2016). Quebec does not recognize or protect Algonquin/eastern wolves.

“In Québec, wolves are considered a furbearer and are protected under An Act Respecting the Conservation and Development of Wildlife but not under Loi sur les espèces menacées ou vulnérables [Act respecting Threatened or Vulnerable Species in Québec]. The Eastern Wolf is not officially recognized because the province does not recognize wolf subspecies (MFFP 2011); the Act only acknowledges taxonomic nomenclature as outlined by the Smithsonian Museum of Natural History and the Integrated Taxonomic Information System ( (MFFP 2012a). Currently, wolf hunting and trapping is prohibited in all federal and national (provincial) parks but permitted elsewhere, including wildlife reserves (St. Louis pers. comm.). In most areas, the harvest season is late October – late March, and there is no bag limit.” (COSEWIC 2015).

Currently, there is no active scientific committee assessing the at-risk status of species in Québec, and protection measures are not predicted in the near future. It is therefore Ontario’s responsibility to begin recovering this globally threatened species.

3. Whether the location of the species and their habitats occur in the same location as the regulated activities.

There is considerable overlap between hunting and trapping activities and the species. This factor is also an inadequate criterion to be using to evaluate the potential impacts of hunting and trapping on the species. The species has been confirmed in WMUs 35, 36, 42, 47, 49, 50 and 56 (COSEWIC 2015, COSSARO 2016) where wolf/coyote hunting occurs under the seal but mandatory reporting averages less then 60% annually (Stuart pers. comm.). Accordingly the Ministry lacks adequate data on the potential impacts of hunting and trapping on the species outside the “core occurrence areas” to properly assess the risk of significant adverse effects on the species. Note that the proposed closure around Killarney Provincial Park accounts for less than half of the WMU 42 area. Hunting and trapping would be permitted by the proposal in the remaining area of WMU, as well as the other units mentioned.

Due to the low harvest reporting rate, the number of wolves/coyotes killed by hunters in each WMU must be extrapolated and is therefore not accurate. Not only are total numbers of wolves/coyotes killed therefore inaccurate, but the specific number of Algonquin wolves killed is unknown. This is alarming because Algonquin wolves have the lowest survival relative to all
other canids outside of protected areas (Benson et al. 2014) and hunting and trapping are the primary threats to Algonquin wolves (COSEWIC 2015, COSSARO 2016).

Trappers are not restricted with bag limits in WMUs 35, 36, 42, 47, 49, 50, and because traplines can extend through multiple Units (Stuart pers. comm.), reported trapping data are not compiled at a spatially fine enough scale to identify the WMU-specific maximum number of Algonquin wolves being trapped.

The species has been confirmed in WMUs 43B, 59, 60 75, 81B (COSEWIC 2015, COSSARO 2016) where wolf/coyote hunting and trapping is unlimited, year-round and untracked. There is no data available to estimate the number of Algonquin wolves killed in these Units. There is no evidence that Algonquin wolves are not being killed in these Units.

Of the Algonquin wolf records outside of existing protection in and adjacent to Algonquin Provincial Park used to describe the wolf’s extent of occurrence in Ontario (COSSARO 2016), one third are located where hunting and trapping would be permitted according to this amendment. Moreover, GPS satellite tracked Algonquin wolves provide a more accurate description of habitat use and locations of individuals across their lifetime. Algonquin wolves are extremely vagile animals, capable of traveling many kilometers in a single day. Those Algonquin wolves, whose single record location was found within an area that is proposed for wolf/coyote hunting and trapping closures, are not restricted to the proposed closure area; hunters and trappers can still kill Algonquin wolves that receive some protection within the enclosures. Therefore, these areas are not sufficient at fully protecting even one individual Algonquin wolf throughout its lifetime, let alone a viable population that will recover the effective population size and general population.

Search efforts have largely been limited to areas around provincial parks, and only the most recent surveys found those Algonquin wolves furthest away from Algonquin Provincial Park, their presumed population source (see discussion about source-sink dynamics in Benson 2013). It is therefore appropriate to apply the precautionary principle and assume that at least one Algonquin wolf is currently using, has used, or will use habitat in each of the WMUs that contain a portion of the extent of occurrence described by COSSARO. These WMUs are: 35-39, 41-61, 75 & 76A. Moreover, given that Algonquin wolves are positively associated with protection from hunting and trapping (see Benson et al. 2012, Benson 2013, Benson et al. 2014, Rutledge et al. 2010a and Rutledge at al. 2010b), it is possible that Algonquin wolves inhabit large, protected areas in Lake Superior Provincial Park and the Chapleau Crown Game Reserve. It is therefore necessary to ban wolf/coyote hunting and trapping in WMUs 28, 29, 31-34 & 40, areas that act as corridors between the extent of occurrence in Ontario and Québec and these large protected areas to the north, in addition to closing the wolf/coyote season in WMUs 35-30, 41-61, 75 and 76A until the range of the Algonquin wolf is defined by experts and extensive surveys are completed.

4. Whether certain types of activities are likely to adversely affect the species.

Hunting and trapping outside of the proposed “core occurrence areas” is likely to adversely affect the species. Referencing the type of activity, without examining reliable data on the potential impacts of that activity, is not an adequate approach to assessing the potential for significant adverse effects. The primary threats to the species are hunting and trapping (COSEWIC 2015, COSSARO 2016); these threats are obviously lethal and destroy individual Algonquin wolves. Of radio-tracked Algonquin wolves that dispersed from Algonquin Provincial Park, 80% were killed by hunters and trappers within one year (Benson 2013). Algonquin wolves must sexually mature, find a mate, and a territory before they can reproduce and contribute to population-wide recovery. Hunting and trapping likely prevents most dispersing Algonquin wolves from the source population in Algonquin Provincial Park from reproducing, and therefore helping to recover the population.


The amendment as proposed will likely have a significant adverse effect on the recovery of the Algonquin wolf population in Ontario. Significant adverse effects on a threatened or endangered population preclude such proposals, and should have precluded the exemptions proposed here. Hunters and trappers should not be exempt from section 9 of the Endangered Species Act in the areas outside of the closures proposed in EBR posting 012-8014, or in any part of Ontario. Instead, they should be prevented from killing wolves, coyotes and their hybrids throughout the extent of occurrence and in key corridor areas by closing wolf and coyote hunting and trapping seasons year-round under the Fish and Wildlife Conservation Act (see our comments submitted on EBR 012-8104).

Hunters, trappers and landowners who accidentally or choose to kill wolves and coyotes in Ontario, must be required to submit a tissue sample for genetic assignment to ensure the animal is not an Algonquin wolf. Hunters and trappers wishing to profit from wildlife, especially species-at-risk, which the government holds in trust for all Ontario residents, should be held accountable if they are willing to run the risk of violating s. 9 of the ESA. This sampling would provide the additional benefit of tracking Algonquin wolf occurrences and providing opportunity to adaptively modify hunting and trapping closures for wolf and coyote beyond those WMUs suggested above.

Lastly, we encourage the Ministry of Natural Resources and Forestry to commit to assisting landowners in preventing wildlife conflicts by working with the Ontario Ministry of Agriculture, Foods and Rural Affairs and the Ontario Federation of Agriculture, to develop and support a ‘Wildlife Friendly Farming Certification’ Program. Such programs recognize the implementation of non-lethal tools that minimize livestock predation by wolves and coyotes. Farmers and ranchers receive recognition and certification for executing best practices while celebrating the presence of carnivores. Rewarding monetary compensation to livestock and crop producers regardless of whether good husbandry practices are present, offers little incentive to deploy better strategies and foster appreciation for the ecologically important role wolves and coyotes bring to the landscape.

Prevention and education are the cornerstones of successfully farming and ranching while coexisting with carnivores. Landowners soliciting hunters and trappers that directly benefit from the destruction of top predators fail to identify or address poor husbandry practices. Killing individual wolves/coyotes disrupts their social, family-oriented packs, thus creating opportunities for more canids to move into the area. This strategy does not reduce the population of wild canids on the landscape; it simply perpetuates a cycle of persecution. Inherently invaluable and deserving of protection as part of our public trust, the threatened Algonquin wolf, along with coyotes and their hybrids, must be protected with ecological scrutiny and political integrity.
#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
Born Free
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
Ainslie Willock
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
The Fur-Bearers
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

Benson. 2013. Hybridization dynamics between wolves and coyotes in central Ontario. PhD Thesis.
Benson, Mills, Loveless, and Patterson. 2013. Genetic and environmental influences on pup mortality risk for wolves and coyotes within a Canis hybrid zone. Biological Conservation 166, 133–141.
Benson, Patterson, Mahoney. 2014. A protected area influence genotype-specific survival and the structure of a Canis hybrid zone. Ecology 95, 254-264.
Benson, Wheeldon, Patterson. 2012. Spatial genetic and morphologic structure of wolves and coyotes in relation to environmental heterogeneity in a Canis hybrid zone. Molecular Ecology 21, 5934-5954.
COSSARO. 2016. Ontario Species at Risk Evaluation Report for Algonquin Wolf (Canis sp.), an evolutionarily significant and distinct hybrid with Canis lycaon, C. latrans, and C. lupus. Available at: ancestry
COSEWIC. 2015. COSEWIC assessment and status report on the Eastern Wolf Canis sp. cf. lycaon in Canada. Committee on the Status of Endangered Wildlife in Canada. Ottawa. xii + 67 pp. (
Rutledge, Garroway, Loveless, Patterson. 2010a. Genetic differentiation of eastern wolves in Algonquin Park despite bridging gene flow between coyotes and grey wolves. Heredity 105, 520-531.
Rutledge, Patterson, Mills, Loveless, Murray, White. 2010b. Protection from harvesting restores the natural social structure of eastern wolf packs. Biological Conservation 143, 332-339.
Stuart, C. Director, Species Conservation Policy Branch, Ministry of Natural Resources and Forestry. Email correspondence dated: Mar 17 2016