Although the government's,…

ERO number

025-0781

Comment ID

158100

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

Although the government's, ludicrous, claims these changes will promote, humane, trapping, and, help manage, wildlife, conflicts, they carry, serious, risks that cannot be ignored! Obviously, expanding trapping, and, allowing, more, methods, for killing, increases the risk of suffering for, both, target, and, non-target, species! Even under the guise of supposedly, humane, traps, animals will experience pain, stress, and, prolonged, injury! The, proposed, changes weaken protections for, fur-bearing, mammals, and, set a, dangerous, precedent that, economic, gains outweigh, animal, protection!

These changes, also, threaten Ontario’s ecosystems! Beavers are, a, keystone, species whose dams create wetlands that support biodiversity, regulate water, flow, and, improve, water, quality. Permitting their removal, on, Crown, land, during the, closed, season (e.g. May-August) would destroy habitats, reduce biodiversity, and, disrupt, natural, water, systems, with, long-term, ecological, consequences! At the, same, time, reducing, reporting, requirements, for, fur, dealers, would erode transparency, and, make it harder to ensure that, trapping, practices comply with humane, and, environmental, standards!

Equally troubling is the absence of evidence to support these proposals! While the "ERO" posting claims that the “environmental, consequences of the, proposed, regulatory, changes are anticipated to be minimal,” it offers NO documentation to substantiate this! NO, environmental, impact, assessments, scientific, studies, or, ecosystem, data have been made available for, public, review. Without this information, stakeholders cannot, properly, evaluate the risks to wetlands, waterways, biodiversity, or, animal, welfare.

This lack of transparency follows a, troubling, pattern. Just, last, year, the government of Ontario proposed changes to, trapping, regulations related to the design of, restraining, snares (also, known as “relaxing, cable, restraints”) without providing evidence to support them! Although the government referenced “research, findings,” they were NOT shared, publicly, or, provided to "The Fur-Bearers", upon request. "The Fur-Bearers" has, since, appealed the government’s refusal to release the information to the "Information and Privacy Commissioner of Ontario", and, that appeal remains under review.

"AEL Advocacy" has, also, called out, similar, transparency, gaps, such as the government’s failure to provide, supporting, documents related to a, recent, "Environmental Compliance Approval" for a, meat, processing, facility in Brampton.

Even Ontario’s "Auditor General" has raised concerns. In its, most, recent, "Performance Audit on the Environmental Bill of Rights", 1993, the office noted that “18%, of the, proposal, notices [they] reviewed, left out, important, information for the public to, fully, understand the proposals, including about their, environmental, implications! This ongoing, pattern undermines transparency in, environmental, decision-making, and, prevents Ontarians from, meaningfully, exercising their, environmental, rights! Without access to complete, and, reliable, information, the public cannot, properly, assess the, potential, impacts, of these proposals, on animals, and, ecosystems!