Thank you for allowing the…

Thank you for allowing the provincial trapping organization to respond to this ERO # 025-0781.

Item one: As for Fur Buyers being allowed to sell castoreum, we support this initiative.

Item two: As for Reducing reporting burden for licensed fur dealers, we support this initiative.

Item three: Regarding dispatching furbearers after dark, the Federation has no concerns with this. As there are already allowances by the conditions of the ATC to perform this task spelled out by the CFO's office. One thing that the Federation would ask for are provisions for trappers that are trapping black bears under the authority of their trapping license to dispatch black bears with a center fired firearm (rifle, shotgun or handgun) in the same manner as they would with a furbearer. Most trappers perform their twenty four hour checks after daylight hours and the MNR has recognized this, bringing forward dispatch after dark legislation. The only problem is it is unlawful to dispatch big game animals with rimfire firearms. The Federation would like the MNR to either add center fire considerations to this piece for dispatching black bears (long guns and handguns) or give the exemption of dispatching black bears after dark with a rim fire (long gun or handgun).

Item four: Regarding protecting infrastructure on Crown Land, this was discussed by the whole Board and was agreed upon that the contracting company should be instructed to look for the registered zone holder. If there is one, allow them to do the work. Doing this, it shouldn't be an onerous task. As it would be one phone call to the Federation for the local MNR office. The real concern is when people are paid by the tail or for the animal without guidelines, they would possibly travel up the chain of ponds and potentially kill every pond in the name of a payday, and not in the interest of conservation. Many trappers are experiencing this now along highways and railways. When it comes time to trap their mandatory seventy five percent beaver quota, they are unable because all of the ponds associated with that watercourse have been killed in defense of infrastructure. If this passes and the MNR allows non-zone holders, we would ask in the best interest of our membership and environment that the same rules are applied and enforced as with the roadways. The rule of not being allowed more than 33 feet from the center line has been followed for years and has worked. Another important piece would be to attach penalties for people that exceed the thirty three feet and instruct enforcement to lay charges. In some cases, it is hard for trappers to make the mandatory minimum 75% quota and by not safeguarding the zone holders in this manner it would put undue stress on the trappers mandated to manage for sustainability.

Thank you for your consideration to our comments. We look forward to our continued relationship moving forward to ensure conservation.