ERO number 025-0781 “The…

ERO number 025-0781

“The proposed changes would enable sale of beaver castoreum by fur dealers, reduce reporting requirements for fur dealers, provide additional tools for trappers to humanely dispatch furbearing mammals, and provide trappers with additional opportunities to protect dwellings and critical infrastructure from beaver.  These proposals support humane trapping practices and provide additional opportunities for trappers to manage conflicts with wildlife.”

A) “enable sale of beaver castoreum by fur dealers” – It takes about 8 castors (the glands that the beaver uses to attract another) to equal a pound. The selling price of a beaver pelt needs to be approximately worth $200-$300 to make it worth the time and effort of the trapper to catch and skin (skinning takes about 2 hours to do), currently they get $165 for 4 pelts (approximately). Castoreum gets them a price of $65/pound for “good quality” – can’t be torn, must be dried between 15 & 21oC for seven days.
If the government is only going to allow the trappers to sell castoreum (used in perfumes and food flavouring -very ‘vanilla’ taste.) at the current cost of the beaver pelt, then it would not be worth the time and effort of the trapper.

B) “reduce reporting requirements for fur dealers” -

“Fur dealer reports are recognized as a key regulatory burden experienced by these small businesses.”

• “We are proposing changes that would remove the requirement for fur dealers to submit a report to the ministry, subject to certain requirements:
◦ Fur dealers would be required to keep records on file for five years and make those records available to the ministry upon request.
◦ The ministry would retain the ability to add conditions to a licence, as needed, to address specific compliance issues.”

In your own summation of this proposal saying that fur dealers reports are a “regulatory burden” is an open statement that tells us that anyone licensed or authorized by the government to make reports and hand them in yearly (i.e. Authorized Wildlife Rehabilitators, Falconers, Tourist Outfitters, etc) should also be exempt and to just be allowed to “keep them on file for five years and make them available to the ministry upon request”. Of course, the obligatory “subject to certain requirements” and “retain the ability to add conditions” and “to address specific compliance issues” would still be in effect with them too. You must follow up once you set this precedence or it becomes preferential treatment to one and not all.

C) “provide additional tools for trappers to humanely dispatch fur bearing mammals”

“Many trappers maintain full-time or part-time jobs and supplement their income with trapping (1). This often requires licensed trappers to check their traps as it becomes dark (2) and requires them to humanely dispatch legally trapped fur bearers after dark(3).”
1) “many trappers maintain full-time or part-time jobs and supplement their income with trapping” - In our society of today, many people are working two, three, even four jobs to make ends meet. In your statement you make this sound like a hardship for the hunters. Possibly, and likely is, but this is the route they chose to enable themselves to help make ends meet too.
2) “checking their traps as it becomes dark” – with the removal of their paperwork this becomes a moot point as when and where does the trapper ever report time he checked his trap line? And have they ever made that report? Very unlikely. Who knows how many times they have collectively not checked their lines due to inclement weather or even just their own fatigue!
3) “requires them to humanely dispatch legally trapped fur bearers after dark”. - this doesn’t make any sense at all as part of your argument to actually change things to make it easier or better for trappers! Any person trapping fur bearing animals for a living SHOULD be dispatching them HUMANELY as it is! You basically are only wanting to give them permission to kill with any type of gun they are licensed for or give them access to carry other weapons to do the job!

D) “provide trappers with additional opportunities to protect dwellings and critical infrastructure from beaver” - “We are proposing changes that would enable licensed trappers to trap beaver on Crown land during the closed season (may-August) in protection of property situations or to protect infrastructure.”
Beavers mate in January and February, gestation period is 105 days (give or take). That time period comes up in the start of when you’ve proposed to open up trapping. To give a YEAR ROUND trapping on beavers. Enabling trappers to kill off young and adult alike. The consequences of this will be the rapid decline and possible eradication of beavers in the wild.
When the fur trade first started, it is estimated that there were 6 million beavers living in what is now Canada. By the time the fashion had changed in the mid-1800s, the beaver was almost extinct. Today, thanks to many protections, thriving populations of beaver exist across Canada once again.

Open killing of any wildlife has historically proven that the demise of the animal is created by government intervention of policies already laid out for the initial protection of wildlife. It leads to trappers and hunters able to hunt beyond limits.
Removal of the annual reporting will give way to an opportunity to take what they want - but would they do so? As you well know, everyone is honest to a fault!

E) “These proposals support humane trapping practices and provide additional opportunities for trappers to manage conflicts with wildlife”
While in theory, what is laid out, may be construed as a supportive measure, but without the numbers required for Conservation Officers (which are sorely lacking in the MNR - 13% of 650 people who worked in this title in May 2021 were distributed to Fishing, Hunting, Trapping; In 2021, there were 184 C.O.s policing 1 million square kilometers that is Ontario and they were looking to hire 25 more! ) to police the trap lines, the way the animals are “humanely killed” or even how long the animal has been in one of the traps – are they live traps, foot hold traps? WHAT? These are NOT mentioned anywhere, so the “humane” practices are questionable in the very least.

To state that this will “provide additional opportunities for trappers to manage conflicts with wildlife” is nothing less than lip service. As this statement only clearly states that you will be allowing trappers to kill off young that rely on parents or kill off the parents and leave the young to suffer and die without their support because you are opening up a closed season.

Your changes are not supportive to the wildlife and only give the trappers the release of reports.