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Request for a full environmental assessment of the deer management program in Ontario.

September 29, 2004

Leona Dombrowsky, Minister of Environment
12th Floor, 135 St. Clair Avenue West
Toronto, Ontario M4V 1P5

Dear Ms Dombrowsky,

We are requesting that the entire deer management program of the Ontario Ministry of Natural Resources (OMNR) be reviewed by a full environmental assessment as outlined in the Environmental Assessment Act.

According to the Ontario Ministry of Natural Resources, deer is a native species historically found in the most southern regions of Ontario. However, deer can now be found as far north as the Hudson Bay watershed.

The expansion of deer well beyond their historical range can be directly attributed to clearcut logging, which has dramatically altered the province's native forests to ones more favourably to deer.

However, deer density is a direct result of government manipulation of the population, and the reliance on sport hunting as a wildlife management tool, specifically as a form of culling.

The Ontario Ministry of Natural Resources has announced it will permanently expand hunting opportunities in selected areas across the province where deer numbers are considered too dense. These areas cover at least half of southcentral Ontario. The Ministry has also announced it will allow hunters to kill a maximum of seven deer, again in selected areas across the province. These announcements indicate a large deer reduction program, but we contend that such wildlife management practices, i.e. culling, only perpetuates the problem and does not consider broader ecological impacts.

Deer are now recognized as a crop. The OMNR views deer as a manageable, harvestable natural resource that needs good farming practices as much as any valuable livestock or other resources. In its current application, producing harvestable surpluses as crops has created many negative consequences for other stakeholders and the deer population.

The Ontario Ministry of Natural Resources references many of these problems as a rationale to expand hunting opportunities. However, we contend that the very practice of managing deer populations through sport hunting, and hence culling, only perpetuates the problem.

We have explored five areas of concern in this application.

1. Car collisions with deer
2. Culling as an effective wildlife management tool,
3. Biological impacts on hereditary traits and the ecology.
4. Enforcement
5. Social impact on rural non-hunting residents

1. Car Collisions with Deer

Car collisions with deer peak in the autumn during hunting seasons. But this correlation is often dismissed by wildlife agencies as being linked to other factors such as the mating season and the harvesting of farmer's fields. To refine this correlation, we obtained data from the Co-operators Car Insurance Company of all car collisions involving wildlife across Ontario from 2002. This data is the most comprehensive data available. A copy of these records is provided on disk.

This data is more comprehensive than police records because the police are not always called to a collision with deer. The data provided by the Co-operators is for all claims whether the police were involved or not. As you will see, the data consists simply of date and location, by postal codes, for each accident. While not specified, collisions with wildlife are assumed to be deer in the southcentral region. Only wildlife large enough as deer can cause damage to a vehicle. In northern regions, collisions can occur with deer, moose or bear.

We then identified three sample areas in southern Ontario where gun deer hunts are scattered over a five week period - one week on, one week off. These areas are called Wildlife Management Units (WMUs). We then identified which postal codes overlapped these WMUs and began categorizing each collision with each WMU by week. In our analysis, we also included immediately adjoining postal codes since hunting on the perimeter of an area could impact on adjacent areas.

Our analysis also included two days prior to the opening day hunt when hunters traditionally use dogs to run deer out of private property and into public spaces where hunting is permissible, and one day after the hunt.

There is a noticeable decrease of car collisions by the third week of the hunting season. This could reflect lower deer density as a result of hunting pressure.

Two of the sample areas are controlled hunts. This means the OMNR controls the number of hunters allowed to participate in each week of the hunt. One sample area is an open season. This means there are no controls on the number of hunters allowed to hunt on any given day of the scheduled hunting season. Details of our analysis are attached. A synopsis is below.

Wildlife Management Units - 82A, 82B, 83A and 84

Open Season
Week 1 (hunting) - 18 collisions
Week 2 (no hunting) - 17 collisions
Week3 (hunting in WMU 82B only) - 38 collisions in total area, 23 collisions in area of WMU 82B
Week 4 (no hunting) - 17 collisions
Week 5 (hunting) - 13 collisions

Wildlife Management Units - 92A, 92B, 92C and 92D

Controlled Hunt
Week 1 (hunting) - 21 collisions
Week 2 (no hunting) - 10 collisions
Week 3 (hunting) - 24 collisions
Week 4 (no hunting) - 0 collisions
Week 5 (hunting) - 13 collisions

Wildlife Management Units - 90A and 90B

Controlled Hunt
Week 1 (hunting) - 17 collisions
Week 2 through to Week 4 (no hunting) - 17 collisions over a three week period
Week 4 (hunting) - zero collisions.

Since deer hunting occurs across all areas of southcentral Ontario, it is impossible to have a control area with no deer hunting. However, included is a graph provided by the OMNR which shows the relationship between car collisions and deer in Prince Edward County near Belleville, Ontario. Prince Edward County is an island. Deer hunting wasn't permitted until 1988. Therefore, there was no deer hunting in 1987 in Prince Edward County. The graph shows that prior to a hunting season, collisions with deer peaked during their winter migration from their staging grounds to their winter habitat. As hunting is introduced, collisions become more numerous in mid-November - the traditional hunting season.

Ministry of Transportation report: hunting causes car collisions
(pdf report)

2. Culling as an effective wildlife management tool.

The graph also shows that since hunting has been introduced in Prince Edward County the number of car collisions has increased. This is true throughout many regions of the province even though hunting continues and hunting opportunities are expanded.

Please find additional statistics from Ontario Provincial Police records.

This is because wildlife will accelerate their birth rate as population densities diminish, always striving to reach their natural/environmental carrying capacity. We have attached deer counts from Rondeau and Pinery Provincial Parks where culling of deer began in 1998. The numbers show that as Ontario Parks strives to cull the park's deer population, the deer double and then quadruple their birth rate once the population reaches a critical threshold. Please find these statistics attached. A synopsis is below.

Reproductive Rates

1998 - 10%
1999 - 10%
2000 - 39%
2001 - 39%
2002 - 33%
2003 - 50%

1998 - 10%
1999 - 10%
2000 - 25%
2001 - 25%
2002 - 33%
2003 - 50%

The increase in deer numbers at each park could be attributed to migration rather than birthrate, however deer are not long distance migrate travellers. According to the Ministry, deer tend to remain within a 20 kilometre home area.

3. Biological impacts on hereditary traits and the ecology.

While maintaining overall low deer densities through hunting may be the primary objective of OMNR, little consideration is given to the biological and ecological impacts of such a strategy. For example, this coming deer hunting season will aim to remove approximately 100,000 deer from the ecology within a one week period, with a few staggered hunts throughout the province.

Not only does OMNR not have an accurate grasp on the overall number of deer, they care little of the impacts on deer predators such as wolves and coyotes. Please find attached an email from the Kemptville District Office of the Ministry of Natural Resources that states the area office does not know how many deer are within their Wildlife Management Unit.

The OMNR also manipulates male/female ratios that interrupt the natural
balance among the deer population, and can influence historical mating
behaviour within a herd. According to government regulations there is no limit on the number of bucks that may be killed during the deer hunting season while the number of does killed is regulated by the sale of antlerless deer tags. Killing off the males increases the habitat's carrying capacity for breeding females and serves to accelerate population growth.

To date, very few studies have taken a critical view at the undesirable evolutionary consequences of trophy hunting. Trophy hunting is a primary consideration in scheduling deer hunts during the mating season.

Sport hunting is one of the most pervasive and potentially intrusive human activities that affect game mammal populations globally, and selective harvests, including trophy hunting, can have important implications for sustainable wildlife management if they target heritable traits.

A recent paper published in the scientific journal Nature, shows that in an evolutionary response to sport hunting of bighorn trophy rams, body weight and horn size have declined significantly over time, and these hereditary genetic traits are disappearing from the gene pool.

Please find this paper attached.

4. Enforcement

The OMNR has increased hunting opportunities without increasing the number of enforcement officers. While no new Wildlife Management Units are being created (the whole province is currently divided into units, and each unit has designated enforcement officers) hunting activity within each unit will increase substantially. Conservation officers already have large areas to patrol during hunting seasons. For example, only eight conservation offices are entrusted to enforce the Fish and Wildlife Conservation Act throughout southwestern Ontario, and they tend to focus on hunting and firearm violations. Hunting activities that violate or intrude on private property or personal safety are not addressed by any enforcement agency. Trepassing, for instance, is considered a low priority by the Ontario Provincial Police, and not considered a primary responsibility by conservation officers, even though trespassing by hunters touting firearms or flushing resident wildlife from private property using dogs or firing rifles into the air is highly intrusive and offends one's sense of personal safety. Greater hunter density requires more enforcement.

5. Social impact on rural non-hunting residents

Greater hunter density will translate into greater conflicts with non-hunting rural residents. Already across the province hunting occurs 10 months out of the year when all hunting seasons are combined, such as rabbit, wild turkey, squirrel, coyote etc.

Many rural residents do not appreciate excessive hunting in and around their homes. Controlled hunts were introduced to alleviate many of the concerns expressed by non-hunting rural residences, but it is not enough. Please find an email from OMNR that explains the purpose of controlled hunts.

The gun deer season involves high powered rifles with bullets that can travel up to two kilometres. In areas with a dense rural population, shotguns are required instead. But whether rifles or shotguns, many rural residences have become uncomfortable with hunting in and around their homes, and the lose of resident wildlife such as deer. Viewing resident wildlife is an important quality of rural living for many people but the Ministry of Natural Resources ignores their concerns.

Please find attached letters from rural residents from across the province that have agreed to submit their stories. Many of these people have had confrontations with their neighbour hunters, and have submitted their stories with the understanding that they will be kept confidential and not shared with other stakeholders. It is only with this assurance that we will be able to encourage others to write in their concerns to your office.

Thank you
Peaceful Parks Coalition


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