by David Seburn

An increase of only 0.1% in the annual mortality rate of 15+ year old Snapping Turtles would halve the number of adults in the local population in less than 20 years. Source: Management Plan for the Snapping Turtle (Chelydra serpentina) in Canada

An increase of only 0.1% in the annual mortality rate of 15+ year old Snapping Turtles would halve the number of adults in the local population in less than 20 years. Source: Management Plan for the Snapping Turtle (Chelydra serpentina) in Canada

Snapping Turtles face many threats including the loss of wetlands, traffic mortality, by-catch from commercial and recreational fishing, persecution, and toxic chemicals. If that were not enough, the province of Ontario also allows hunting of Snapping Turtles. Right now, the province is re-considering the hunt. Submissions requesting the hunt be ended are urgently needed.

In less than 5 minutes, you can submit your comments to the government and help protect Snappers. Below is the submission I helped prepare on behalf of the Ottawa Field-Naturalists’ Club. It provides more detail on why hunting long-lived species like Snapping Turtles is likely not sustainable. And below that are two sample letters you can submit for yourself. It is always better to personalize letters so it doesn’t sound like a form letter. Re-word a few sentences. Add a personal anecdote. Do even a little to make it your own. Or write your own letter.

How to submit your comments

  1. Make submissions via the Environmental Registry.
  2. Go to the Environmental Registry page.
  3. Click on the Submit Comments button.
  4. Fill out some contact info and then paste your submission into the comment box and hit save. It really is that simple.
  5. Comments are accepted until January 30, 2017.

OFNC’s submission

Comment on EBR Registry Number: 012-9170
Re: Harvest of Snapping Turtles

The current proposed changes to the Snapping Turtle hunt are to “Restrict snapping turtle harvest across Ontario in accordance with guidance provided by the draft Small Game and Furbearer Management Framework, in consideration of the biology of the species, and consistent with recommendations in the Proposed Management Plan for the Snapping Turtle (Chelydra serpentina) in Canada.”

The proposed changes would shorten the hunting period and reduce the possession limit to two Snapping Turtles. Unfortunately this does not adequately take into account the biology of the species, or the recommendations in the proposed management plan. The management plan clearly states “Considering the reproductive strategy of the Snapping Turtle (i.e., delayed sexual maturity, high embryo mortality, extended adult longevity; see section 3.4 – Limiting Factors), harvesting (legal or illegal) of adults and older juveniles is especially harmful for wild populations” (sec. 4.2, p.14).

Snapping Turtles in Ontario may take 20 years or more to reach maturity and any hunting and killing of the species must take into account such factors. Snapping Turtles have a suite of life history characteristics involving delayed maturity, high nest predation rates, but extended adult lifespan. This life history strategy is successful when adult mortality rates remain extremely low. Snapping Turtles already face significant threats in Ontario including traffic mortality, boating mortality, fishing by-catch, persecution, toxic contaminants, and habitat loss and fragmentation. Additional sources of mortality, such as from a legal hunt, are likely not sustainable in many areas of the province.

Scientific studies on turtles are very clear that removal of adults will cause a population to decline and recovery may not occur even after a few decades. A Snapping Turtle population in Algonquin Park has been studied by the lab of Professor Ron Brooks for more than 25 years. It experienced significant “hunting” from River Otters in the late 1980s. Following the reduction in the adult population, there was no increase in clutch size, numbers of hatchlings and juveniles, growth rates, or adult recruitment. There has been no population recovery in the last 25 years.

Under the proposed regulations of a daily limit of one Snapping Turtle and a possession limit of two, five people on a weekend hunting expedition at a cottage could take 10 Snapping Turtles from a single population. Removing 10 adults (particularly if they are adult females) could be catastrophic to many small or medium sized populations.

The “Draft Small Game and Furbearer Management Framework for Ontario” states that the first management objective is “sustainable populations.” Yet the evidence based on the life history of the Snapping Turtle, the statements about hunting in the proposed management plan, and the allowable hunting rates in the proposed guidelines all clearly indicate that the hunting and killing of Snapping Turtles is not sustainable. If wildlife management in Ontario is to be science based, then MNRF should not simply restrict the hunt, but end it completely.

Sample submissions

Feel free to copy one of the following sample letters as your submission to the Environmental Registry. You can also borrow some text from the OFNC letter. A personalized letter always counts for more, so please make it your own by re-wording some sentences or adding your own thoughts.


The legal hunting of the Snapping Turtle should be halted.

Snapping Turtles are listed as a species at risk both provincially and federally. They face numerous threats, including road kill, loss of habitat and persecution from many people. Large numbers of dead Snapping Turtles are seen on roads every year during the nesting season and most of these are adult females looking to lay their eggs. This threat alone likely is causing some populations to decline. Additional sources of mortality, such as from a legal hunt are likely not sustainable.

Please halt the legal hunt of this species at risk.


The government of Ontario should end the legal hunting of Snapping Turtles.

Snapping Turtles can take more than 20 years to reach maturity. Many of them die on our roads every June as females look for nesting sites. And the Snapping Turtle is now listed as a species at risk both provincially and federally. Why is the hunting of this species still allowed? Please end the hunting of this species to help ensure Snapping Turtles have a future in Ontario.

A comparison of the reproductive pattern of some commonly hunted wild mammals with that of Snapping Turtles.