NOTO’s Submission to the EBR Re: Spring Bear Hunt Proposal

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NOTO’s Submission to The EBR Posting
Re: The 5 Year Spring Bear Hunt Pilot Expansion and Extension

On behalf of the NOTO Board of Directors and membership we would like to express our support for the proposal to extend and expand the spring bear hunt pilot for 5 years. We are pleased that it includes the opportunity for non-residents to participate and that the hunt will be offered in the wildlife management units that currently offer a fall black bear hunt.
In the development of this submission, NOTO has solicited input from its membership as well as the entire resource-based tourism industry regarding the presented proposal. In addition to reviewing the individual comments supplied to us directly from tourism operators, NOTO formed a Bear Task Force. This task force was made up of 7 experienced bear hunt outfitters who met with us to discuss the items listed in the proposal as well as additional information that they wished to provide based on their knowledge of best practices in black bear hunting.
As you are aware, our organization on behalf of the nature and outdoor tourism industry believes that a properly conducted spring bear hunt will provide numerous benefits to residents, communities, other wildlife species and the overall economy in Ontario.
NOTO supports the use of bait sites as an integral part of conducting a bear hunt. Bait sites offer the hunter an opportunity to determine the sex of the bear, study the group dynamics of the bears in an area, as well as provide time to hunters for best shot placement. All of these provide a means to assist with the overall bear management objectives.
Baiting for bear, especially in the spring, provides a valuable food source at a time when bears are emerging from their dens looking for food sources high in protein that may not be present yet in the natural flora and fauna. Baiting can also provide alternative food sources that may help in protecting moose, elk, deer calves from bear predation at this critical time of recruitment for these species. 
With regard to some of the restrictions outlined in the proposal regarding bear baiting we have the following concerns and recommendations:
Bait Placement:
We are unaware of any concerns in the past regarding baiting sites being too close to public areas. In the Outfitting community baiting for black bear best practices have been developed over many many years. The industry takes its participation as wildlife management guardians very seriously. The longevity of their businesses depend on it. The significant investments made by the individual businesses ensures that they must retain relationships with their guests, their communities, their fellow outfitters and our Government.
We believe that placing restrictions on placement of bait sites within regulations is unnecessary and will place an undue burden on the MNRF to enforce. We are in support of developing a Best Practices Guide for Hunting Black Bear in Ontario to provide support to the outfitting community, our hunters (residents and guests to Ontario) as well as the general public as an educational offering. NOTO would be pleased to partner with MNRF and other stakeholder groups to develop this piece jointly and would like to discuss these opportunities outside of this proposal review process.
We would not be opposed to discussing possible placement of signage at bait sites for the public to identify whether a site is active or inactive if this would help.
Permitted Timing:
We are not in support of including any timing restrictions on the placement of bait. The weather in most parts of Ontario, particularly northern Ontario will dictate when baiting will be able to begin. Another factor that will determine when baiting practices will begin for the industry is the cost of baiting to the individual businesses. There are definitely costs to baiting for bear whether it is in the spring or the fall (e.g., food products used, staff time, transportation costs, etc.)
Outfitters have concerns that limiting the timing of using bait sites will not allow them to continue with their current practices of having several bait sites on their BMAs (depending on the size of the BMA of course) which allows them to conduct intelligence on the dynamics of the bears in their area.  If one site is being frequented by a sow with cubs then they can keep their hunters away from that site to protect those bear.  Limiting the timing of bait placements will surely eliminate this opportunity.
Another factor that needs to be considered is, over the last number of years, as the nuisance bear problems rose in our communities, a number of them reached out to our outfitting industry to ask them to maintain bait sites to keep bears away from their populated residential areas. Limiting the timing of baiting sites will not allow for this added support for our industry to continue.
Bear bait sites have also been used to offer diversified tourism products like bear viewing in some instances during those months that bear hunting is not available.  It would be a disappointment to lose these alternative tourism products for Ontario.
Bait Removal:
We agree that all bait and garbage (if any) should be removed and bait sites should be cleaned up however any permanent structures (e.g., barrels, bait boxes and stands should be permitted to be left on the sites once the hunt has ended. 
Tourist outfitters pay for their Bear Management Areas (BMAs) annually and in the past leaving these permanent structures has not been a problem.  If an outfitter also participates in the fall bear hunt, having to remove these structures twice a year is an onerous task.
For many outfitters having the ability to leave these permanent bear baiting materials on site between hunts is also a sign to other recreational users and other industries like forestry and mining creates an awareness that these areas are a tourism value to the individual businesses. These tourism values on the land base are of critical importance to those that offer these tourism products. Through the Resource Stewardship Agreement process that was developed in the mid 1990’s baiting sites were listed as key tourism values. We wish to keep this model for future use.
In some instances GPS coordinates of bear baiting sites have been provided by tourism outfitters to the MNRF when BMAs are renewed so that MNRF is aware of their locations. This level of communication between MNRF and outfitters can only be considered positive for all.
Method of Baiting:
We do not support restricting baiting to only hanging baits through regulation. Outfitters have over the years tested many different ways of baiting for black bear. We believe that limiting baiting practices to hanging baits only will not serve the industry or the hunters well. Generally a combination of suspended and ground baiting is used.  The use of hanging baits only may create more difficulties for hunters to gain an appropriate clear shot that would prevent wounding a bear rather than a humane dispatch of the animal.
This would be another item that we would recommend be part of a Best Practices Guide for Black Bear Hunting in Ontario.
Weight Restriction on Bait:
We are not in support of putting a weight restriction on the amount of bait used. For one, it would be nearly impossible for the MNRF to enforce a regulation of this nature.  We wonder why there would be a need to impose such a limit.
The amount of bait used will be determined by the cost that outfitters are willing to spend on baiting as well as their ability to physically get to their baits during peak times of operation. Weight limits on bait will prevent the industry from supporting our communities and the bears during those peak times of spring and in those times when berry crops and other natural food sources will not support the bear populations causing them to venture into communities in search for other food sources.
Additional Comments/Recommendations:
We would strongly recommend that the regulation prohibiting shooting, or attempting to shoot at a cub or a sow with cubs be extended to the fall hunt as well. The short period of time between the middle of June to the middle of August when the fall hunt begins doesn’t warrant a difference in this regulation from one hunt to the other.  This would support the objective of preventing the orphaning of cubs.
We would also like to see more protection for those that have invested money and time into an annual rental of Bear Management Areas. We would be interested in having a discussion regarding BMAs in the near future in hopes to gain more support for the tourism industry for their investment. There are some interesting activities that have been taking place on the land base within these BMAs that should be of interest to the MNRF and we would like the opportunity to discuss them with the appropriate people.
We would like to reiterate our interest in developing a Best Practices Guide for Black Bear Hunting in Ontario and look forward to an opportunity to explore this idea with MNRF.
Thank you once again for your support in bringing back a spring black bear hunt to Ontario in the form of this 5 year extension of the pilot. We are pleased that the Ministry has included our non-resident guests and has expanded the scope of the hunt across Ontario.
We look forward to continuing our discussions with your Ministry and if you seek any further clarification you only need to ask.
Respectfully submitted,Laurie MarcilExecutive DirectorNature & Outdoor Tourism Ontario

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