EBR moose and coyote regulation: CUSP submission

EBR Registry Number: 012-6073
Comment ID 192372
Contact name: Lynn Palmer
Organization Citizens United for a Sustainable Planet (CUSP)

CUSP is a group of citizens that live in or near Thunder Bay who are committed to promoting healthy communities, a healthy environment, and social and ecological justice. CUSP strongly opposes this proposal, as we do not believe is likely to benefit moose and which may actually result in negative impacts.

CUSP does not oppose hunting. However we do support science. We do not see strong scientific evidence in this proposal that it will have the intended effect to improve the health of moose populations.

While the causes of moose decline are complex, and include the major influx of deer as well as the effects of climate change in recent years, in addition to human impacts of hunting and development, the proposal focuses solely on the impact of wolves and coyotes. The proposal disregards the fact that these species are key predators in a complex predator/prey relationship with moose, and now also deer. The proposal avoids indicating that, while wolves and coyotes may have negative impacts on moose, they are beneficial in controlling the vast numbers of deer now present in northern Ontario, likely due to human development and climate change.
The proposal is glaring in its lack of focus on the need to address climate change as a key element in the health of moose. We must therefore seriously tackle climate change to address moose decline as a key component of our approach to moose (and other wildlife) management. We must further address the levels of development from a variety of sources in moose habitat.

For these reasons, CUSP urges you to abandon this proposal, and to disregard the strong hunting lobby in Ontario that has made wolves and coyotes the scapegoats for moose decline in order that hunting interest groups can maintain or increase their current levels of moose hunting.

We further urge that, in addition to Ontario taking serious steps to address climate change and development in moose habitat, moose hunting regulations are revised appropriately in order to reduce the known negative human impacts to moose populations. This approach would follow the lead of such jurisdictions as Minnesota that, upon recognizing similar threats to moose, eliminated their moose hunt several years ago. Furthermore, we recommend that Aboriginal hunters in northern Ontario be encouraged to voluntarily reduce their levels of moose hunting, until such time as populations are stabilized. This is a direction that has been undertaken by some First Nations, in jurisdictions such as Manitoba, where moose are similarly in decline.