June 14, 2006
Tom Ethier
Manager of Legislation and Regulations
Ministry of Environment
4th Floor, 2975 Jutland Road
PO Box 9363 Stn. Prov Govt
Victoria, British Columbia
V8W 9M2
Facsimile: 250-387-9568
Re: Draft 5 of the Allocation Policies and Procedures.
The BC Wildlife Federation (BCWF) will make one more attempt to illustrate the issues and concerns that our organization, representing the residents of this province, have with these policies and procedures. Our position has altered very little from our initial submission two years ago, yet through this lengthy review very little has been incorporated from our very reasonable requests and we have to wonder why, as it now appears that the non-residents are the ones with priority.
The present papers represent huge gains for the commercial side and very few positive measurables for residents. The commercial side has all the certainty and guarantees they were asking for while the resident is still in a state of flux.
Resident Hunter Priority Policy:
• Point (1): This statement is contradicted in the Harvest Allocation Procedure where it states the minimum share for residents will be 40%. A majority would be 55% or 60%. How does 40% represent the majority?
• Point (4) should be changed to read: considering resident opportunity first when removing unnecessary barriers to achievement of harvest prior to reducing allocation
• Minimum percentages should also be added here.
This definition has been expended from the old policy but these points need to be strongly supported in the other policies and procedures. Resident priority means priority access to the opportunity.
If these points were supported throughout the other policies and procedures, this policy would represent a small gain for the residents.
Administrative Guidelines Procedure:
• Administrative Guidelines were intended for small quotas and the BCWF cannot support this Procedure as is.
• To allow for a 30% additional harvest in a given year will quite simply mean that there will be very little, or in some cases, no resident harvest in that particular guide territory. How does this address resident priority or opportunity?
• For the guide outfitters Administrative Guidelines represent certainty and a guarantee to help achieve their harvest. Where is the equivalent on the resident side? We do not know our numbers and there are defiantly no guarantees in place.
• Guide Outfitters will use Administrative Guidelines to target years of good recruitment at the expense of resident hunters.
• Administrative Guidelines will also be used when a territory is about to be sold or has been recently purchased.
• How will conservation concerns be factored into the use of Administrative Guidelines?
A concern about under-harvest was mentioned at the last meeting, and therefore the need for Administrative Guidelines, yet many outfitters purposely do not fully utililize their quota. If under-harvest becomes an issue than the Under-Harvest of Allocated Share Policy should address their concern.
A second comment about substantial increases in LEH authorizations occur for residents was also made. In fact this happens very rarely and most often does not result in an increase in the harvest level.
This policy is a very significant gain for the Guide Outfitters.
Allocation of Previously Unopened Hunts Policy:
• A starting point of 75/25 does not reflect resident priority for a completely new hunt.
• 2% must be in place for all antlerless hunts and youth only seasons should exclude non-residents.
• How do antlerless hunts fit within the ‘quality’ criteria for guide outfitters?
This policy is a gain for the Guide Outfitters.
Harvest Allocation Policy:
• (a) How does 40% represent point (1) in the Resident Hunter Priority Policy?
• (b) At the end of this sentence, the statement “and only when barriers have been addressed” should be added.
If amended this policy is a gain for residents.
Harvest Allocation Procedure:
This procedure is the focal point of the whole review and therefore has the most impact on allocated percentages. As written it will not be supported by the BCWF.
• What were the criteria used to establish 75/25 as the starting point?
• The BCWF cannot support a starting point of 75/25 as this does not adequately reflect resident priority and represents significant gains in allocation for non-residents in most regions when compared to the status quo. For example, in region 4, 10 out 16 hunts are gains for non-residents and in region 3 it is all four hunts. Where the calculated percentages do represent gains for residents when compared to the status quo it is only because the status quo numbers were significantly favourable for non-residents in the first place.
• A starting point of 75/25 sets out minimum and maximum percentages for non-residents that do not reflect resident priority. Many jurisdictions have a set allocation percentage for non-residents and it does not vary.
• Point (4a): This point again conflicts with point (1) in the Resident Hunter Priority Policy. 40% is not a majority.
• Point (4d): The BCWF does not support this point. It was not intended that 20% could be used as a stand-alone minimum. This was to be used only if a maximum of 40% for non-residents was incorporated for Sheep, Goats and Grizzly Bears and if 30% - 10% was used for all other species.
• Was resident relative importance re-run considering 1/3 for sheep in region 7b, the impact of shared moose hunts, the fact that many hunters do not apply for moose after the year they receive an authorization because they know they are on reduced odds and actual status quo numbers for moose in region 4?
• Was an additional category added for residents due to existing restrictive regulations and significant regulation changes that occurred prior to five years ago?
• Splitting region 6 into north and south only benefits the guide outfitters.
• A comment was made that because of the starting point of 75/25, only three hunts fell below 15% for non-residents and this was good rational to raise the minimum percentage to 15% for non-residents. The BCWF will not support 15% as a minimum percentage but will support 10%.
• The BCWF advocated a maximum percentage of 40% for sheep, goats and Grizzly Bear and a maximum percentage of 30% for all other species except antlerless. Even with a 75/25 starting point, only four hunts (2 goat, 1 sheep and 1 grizzly) exceed 40%. In addition only 1 caribou hunt exceeds 30% so why are the BCWF’s reasonable maximum percentages not incorporated?
This procedure is a huge gain for the guide Outfitters.
Under-Harvest of Allocated Share Policy:
• Reviews and revisions of all restrictive regulations must be done jointly with the Resident Hunters Committee.
• How will intentional under-utilization by guide outfitters be addressed?
• What will facilitate reviews actually occurring?
This policy could be an equal gain for both residents and Guide Outfitters.
Commercial Hunting Interests Policy:
• (1) This point should include at the end the statement “except when permits to accompany have been issued.
• (4) This point should be removed.
This policy is a gain for the Guide Outfitters.
Definitions:
• Previously Unopened Hunt: Amend to “means a hunt for a category ‘A’ species that has never occurred before or has not been opened within the last 10 years in any part of a given region”.
Implementation Plan:
• 3. The wording should be stronger to ensure the new policy is fully implemented by in five years (2012) including the Kootenay region.
Quota Procedure:
• There is relatively no change from the old policy
This procedure is equal for residents and Guide Outfitters.
General Comments:
The BCWF cannot see how the majority of these existing policies and procedures reflect any significant gains for the residents of our province. In fact, many of the pre-existing problems and hurdles from the old policy have not been addressed from a resident perspective. Most importantly, there is no guarantee that regulations will be reviewed and amended. We still have to rely on the goodwill of the regions to even discuss and then perhaps entertain changing regulations. In addition, GOABC has stated they will resist regulation changes. What kind of a guarantee is this compared to what the guide outfitters have? The proposed new allocation percentages will in fact reduce resident opportunity and the BCWF cannot support this concept.
From the start of this project two years ago there seems to have been little regard or respect for resident issues and concerns and the BCWF therefore, cannot support these policies and procedures.
The BCWF would very much appreciate a response to this submission by June 24th so our organization can plan for the future. We would also like to suggest that a meeting with our committee before the end of June would be a valuable exercise and we sincerely hope it can be arranged
Yours in Conservation
Les Husband
On behalf of the BC Wildlife Federation Allocation Committee
CC Chris Trumpy, Deputy Minister 250-387-6003
Nancy Wilkin, Assistant Deputy Minister 250-387-9568
Al Martin 250-387-9568
