Comments on Environmental…

Comments on Environmental Registry Posting 025-0781

Expand business opportunities for licensed fur dealers.
• I agree with the proposed changs to regulations that would enable licensed fur dealers to lawfully sell raw castoreum and thereby provide economic benefits to small business fur dealers in Ontario.

Reduce reporting burden for licensed fur dealers.
• I agree with the proposed changes that would remove the requirement for licensed fur dealers to submit reports to the ministry each year subject to the requirements indicated in the proposal.
• So, to a large extent, we are looking at self-compliance by licensed fur dealers to follow what is required by regulations. In this case to keep accurate records for a period of 5 years. We have seen with the forest industry that self-compliance doesn’t work all that well unless there are regular compliance audits conducted by MNR. I would like to see a commitment by MNR to undertake compliance checks to ensure that fur dealers are complying with the regulations.

Burden reduction for trappers dispatching lawfully trapped furbearers after dark.
• I agree and support the proposed changes to the regulations that would enable trappers to humanely dispatch lawfully trapped furbearers after dark using a rifle or federally authorized pistol firearm.
• I would like the changes to reflect the use of more calibers than just 22 rim-fire. The reason for this request is because the RCMP allows more handgun calibers to be carried by trappers than just rim-fire calibers. For example, 9mm.

Enable actions for protecting infrastructure on Crown land by trappers.
• I completely agree with the proposal to amend the legislation to enable licensed trappers to trap beaver on Crown land during the closed season in order to protect property and infrastructure. I think that MNR staff struggled with the volume of nuisance beaver issues in the spring and early summer. This resulted in delays to issue the required authorizations to trap during the closed season and this, in turn, resulted in damage and sometimes loss of infrastructure. The proposed legislative changes should help to alleviate this situation.
• I understand that MNR will be developing management guidance to support trappers in proactively addressing threats to property and/or infrastructure. This is a good idea. The following are a few thoughts on what this guidance should consider.
o I feel that the head trappers (01 trappers) should be given the first opportunity to trap nuisance beaver. This provides the opportunity for additional revenue. In addition, since head trappers are responsible for the management of their traplines this allows them to maintain an understanding of what is happening with beaver populations on their traplines.
o There needs to be guidance about how far above and below a specific nuisance beaver location that trappers can remove beaver. This is especially a concern if you have licensed trappers who are not the head trappers or helpers on a trapline undertaking nuisance beaver removal. Without clear guidance it is possible that they could trap up and down a watercourse, thus wiping out the beaver in large areas. This would compromise the sustainable management of beaver on the trapline and compromise the ability of the trappers on that line to achieve their beaver quotas.
o There needs to be guidance on trapping nuisance beaver by trappers from outside the province, specifically Quebec. Ontario trappers need to be given first right of refusal to trap nuisance beaver.
o I feel that nuisance beaver that are removed from a trapline should be considered part of the beaver quota for that trapline. The land can only produce so many beaver and a beaver removed as part of nuisance beaver removal program is no different than a beaver harvested during the open season. If the trapper on a trapline is then required to harvest their 75% quota, which is a requirement by regulation, there is the possibility that overharvesting of the beaver population could occur. Again, the long-term sustainability of the beaver population is a concern.
o I feel that there needs to be a reporting framework to aid in documenting nuisance beaver removal activities. This would help to document the value of nuisance beaver removal activities in protecting private property and infrastructure. The reporting framework would need to be simple. Reports would only need to be submitted once a year.