To Whom It May Concern /…

To Whom It May Concern / Ministry of Natural Resources:

I am writing to strongly oppose the proposals under ERO notice 025-0781 (“Proposals to reduce regulatory and administrative burden, and enable increased economic opportunities for licensed trappers and fur dealers”) for the following reasons:

1. Ethical inconsistency with modern values
We live in a time when society increasingly rejects cruelty to animals and values conservation, compassion, and coexistence. Expanding trapping rights, loosening restrictions, and monetizing by-products like castoreum runs counter to both public sentiment and evolving ethical standards. The government should be leading on humane, nonlethal wildlife solutions — not facilitating more exploitation.

2. “Humane trapping” is a flawed justification
The proposal repeatedly invokes “humane” methods and dispatching trapped animals after dark. But the idea of “humane” trapping is deeply misleading. Even under best practices, traps cause suffering, stress, injury, and prolonged death. The notion that loosening restrictions makes it more humane is disingenuous. This kind of regulatory change tends to downplay the real suffering involved.

3. Slippery slope toward more exploitation
Allowing sales of castoreum, relaxing reporting requirements, and letting trappers act with fewer checks opens the door to abuse. If oversight is reduced, enforcement becomes much harder. This invites bad actors to flout rules, operate illegally, or kill more animals than quotas allow. The weakened reporting regime (records “on file” rather than proactive oversight) is especially concerning.

4. Ecological risks and unintended consequences
The proposal claims environmental impacts will be “minimal” because these changes target animals “that would otherwise be harvested under quota.” But that’s an assumption with no solid guarantees. Many trapping decisions are made opportunistically, not strictly by quota logic. Expanding legal leeway (e.g. trapping on Crown land during closed seasons) could upset local ecological balances, affect populations, and indirectly harm non-target species. Once you give broader access, you lose control.

5. Public resources vs private gain
The proposal lets trappers intervene on Crown land (public land) to protect “critical infrastructure” or private property. That essentially privatizes decisions about wildlife interventions on publicly held lands. It’s not appropriate to let private economic interests dictate actions on public resources without stringent oversight, transparency, and accountability. And it risks setting precedents for further privatization of wildlife control.

6. Inadequate justification for deregulation
While the government frames this as “burden reduction” for small businesses, the costs to animals, ecosystems, and ethical standards are far greater. The economic gains for a narrow interest group do not justify weakening protections or oversight over wildlife and trapping practices. The regulatory regime exists for reason — to balance between use and protection, and to ensure that trapping occurs in a sustainable, checked, and humane fashion.

7. Questionable claims about “minimal environmental consequences”
The proposal rests on a claim that changes will have minimal environmental impact, but offers no rigorous evidence or independent review. That is a weak foundation for sweeping change. Before rolling back safeguards, there should be transparent, peer-reviewed studies, environmental assessments, and adaptive management plans — not merely assertions.

8. Moral duty to future generations
As stewards of the land, we should be strengthening protections for wildlife and wilderness, not retreating from them. The government should promote alternatives to lethal control (e.g. habitat restoration, coexistence strategies, nonlethal deterrents). Appeasing narrow economic interests at the cost of animal welfare and ecological integrity is short-sighted.

Suggested stronger alternatives / demands:

Instead of deregulation, invest in humane, nonlethal wildlife management (relocation, barriers, deterrents).

Maintain or strengthen reporting and oversight, not eliminate it.

Prohibit sale of by-products like castoreum from wild animals; if any by-product use is allowed, it must have rigorous standards and enforceability.

Ensure any interventions on Crown land are tightly controlled, transparent, and justified only in truly exceptional cases — not as a general expansion.

Commission independent scientific reviews or environmental assessments before making changes.

Please reject or significantly rework this proposal so it does not erode protections for animals and ecosystems for the sake of “streamlining” or narrow commercial gain.

Thank you for considering this perspective.