I have some serious concerns…

I have some serious concerns about the proposed changes to Ontario’s trapping regulations.

This proposal is far too lean on proper scientific evidence, environmental impact assessments and other data to support its claims that impacts will be minimal. Where are the peer reviewed studies? The public cannot assess the proposal and provide informed comment without such information. The proposal should not be approved until such documentation is available to the public. Please also extend the public comment period once this information is provided so the public has time to review and comment on it.

I oppose the proposal to relax reporting requirements for licensed fur dealers, eliminating mandatory annual reporting to the ministry. Fur dealer reports are essential for ensuring compliance with humane trapping standards and environmental protections. They provide important data on wildlife populations and the impacts on these populations of trapping. Mandatory annual reporting promotes transparency and public accountability. Please retain this important regulatory tool.

I am concerned that allowing fur dealers to sell raw castoreum will open a new controversial economic opportunity that could lead to excess exploitation of beavers. This is especially concerning given the proposed relaxation in reporting requirements.

I oppose the proposal to allow beaver trapping outside the open season on Crown land. Beavers are keystone species; they create wetlands, support biodiversity, regulate water systems and protect against forest fires. Policies should reflect the important benefits of beavers and protect habitats on both Crown and private lands from increased or indiscriminate trapping, especially during the closed season when beavers have young kits. There are highly effective non-lethal alternatives to protect infrastructure from beaver activity. For example: https://www.workingwithbeavers.ca/coexist_level.php

The proposal does not prioritize animal welfare. Trapping laws and regulations must do that, based on current peer-reviewed science. Trapping is inherently inhumane but if it is to occur, it must be made as humane as possible.

In this regard, I have serious concerns about the proposed expansion of methods allowed for killing trapped mammals after dark. What is the actual evidence that this will allow for more humane management of trapped animals vs. the risks to public safety, increased potential for animal suffering (e.g. inaccurate shooting after dark leading to injury and more suffering) and errors (e.g. killing a pet or an endangered species that could have been released but was incorrectly identified at night).

The small financial gains of the fur trade should not come at the expense of animal protection and welfare, public safety, or ecological health. Just not worth it.