This is going to be a long read and likely pretty dry so if you don’t have the time right now to give it some serious attention, please read it later when you do. Grab a cup of coffee, sit down and check out what the Ministry of Environment says is reflective of resident B.C. hunter’s interests. Some of the proposed policies and procedures created or “tweaked”, and their 5 year implementation plans, don’t sound to be in my best interest as a local hunter and after discussing the changes with some friends and colleagues, we are raising the following issues.
First a little background as to why these changes are coming.
Mr. Tom Ethier (Assistant Director, Fish & Wildlife Branch) formed a B.C. Wildlife Harvest Allocation Review “Task Group” to create a new harvest allocation policy, procedure, and implementation plan. This group included Wilf Pfleiderer (BC Wildlife Federation), Dale Drown (Guide Outfitters Association of BC), and Dave Hatler (BC Trappers Association).
Nancy Wilkin (the Assistant Deputy Minister of the Environmental Stewardship Division), is prepared to implement the resulting policies and procedures in time for the 2007 hunting season. In my opinion these changes are being rushed into place in hopes the Holiday Season will provide enough of a distraction that we won’t notice or we’ll be too busy to get involved.
Mr. Tom Ethier says the M.O.E. needed these changes to create a consistent and transparent approach for making allocation decisions across the Province, and that they are reflective of resident B.C. hunters’ interests. Well … you decide.
With regards to the Ministry’s procedure for Harvest Allocation;
Step 1 Apply Initial Allocation.
The Director should assign an initial allocation of 75% of the allowable harvest to resident hunters and 25% to guide outfitters for each category A species in each region.
An initial allocation split of 75%/25% is way to high in favor of the guide outfitters. It has a net result of awarding approximately 28,500 Residents the same allocation as 6400 Non-Residents. This hardly constitutes Resident Priority. To even achieve parity a 93%/7% split would be required.
Step 2 – A; Determine Relative Importance to Resident Hunters
This entire procedure is predicated on all Category A species being on LEH. This does not give a true picture of resident demand. First of all, not all species are on LEH in all areas. Second, many residents have given up on the LEH system and do not participate in the system. (A Category A species is any species that Guides are on Quota in any area in a Region)
From the Ministry’s policy on Resident Hunter Priority, item 2 reads;
providing residents with a minimum share of 98% for antlerless category A species and 50% for all other category A species.
Ok in the first part but 50% to me isn’t a clear majority of the AAH (Annual Allowable Harvest), which is what the resident hunter is supposed to be guaranteed. At the very least 60% should always be awarded to the resident hunter. For your info, our AAH is what is left AFTER the “legal rights of First Nations have been recognized and addressed”, and it is split between the resident and commercial hunter.
From the Ministry’s Commercial Hunting Interests policy statement;
Point 2 regarding the Ministry addressing the commercial interests of the Guide Outfitters reads;
providing predictable, fair shares of the allocations of category A species in tenured areas;
There is no provision that resident hunters should have a predictable harvest share, why should non-resident (Guided) hunters have this provision?
Point 3 – C reads;
“The creation and maintenance of a regulatory framework that maximizes non-resident hunting success, enjoyment, and participation.”
Now, as we have the exact same thing in the Resident Hunter Priority policy, I would like assurances that resident hunters interests will prevail in any cases of conflict between resident hunters and non-resident hunters where both sides are claiming an issue.
From the Ministry’s policy on Allocation of Previously Unopened Hunts, item 1 reads;
That the allowable harvest of previously unopened hunts on category A species be allocated 75% to resident hunters and 25% to guide outfitters for the duration of the first allocation period. (an allocation period = 5 years).
As the resident hunter is always supposed to enjoy a clear majority of the AAH, I feel an 80/20 split would be more reflective of that. The guides automatically get ¼ of the harvest?? Why? The non-resident hunter is not loosing anything here as they have never had access to this population so 20% is still 20% more than what they had!
With regards to the Ministry’s policy on Under-Harvest of Allocated Share, the policy states;
If either hunter group under-harvests a category A species regionally for three consecutive years, the Regional Manager will provide a report to the Director that reviews the regulations and/or license conditions relating to the particular species.
Although this is a positive for Resident Hunters, there are two problems with what the Ministry is presently proposing. First MOE is talking about this process being triggered at a 40% under-harvest and second there is no mandatory provision that the Regional Manager makes the recommended changes. An under-harvest of 25% or more over a three-year period should trigger the process and the results must be implemented.
With regards to the Ministry’s process by which Administrative Guidelines are to be applied to Guide Outfitter quotas;
This is a very difficult section to explain so I have gotten a lot of help here to try and get across the issue. Administrative Guidelines are a way that Commercial Sector is allowed to exceed “Quota” for a single year. There is no rational for applying Administrative Guidelines to whole number quotas. Applying Administrative Guidelines to small quotas may be justified however it is totally unnecessary with large quotas. Furthermore, Administrative Guidelines will be used to exceed “quotas” on years of relative abundance. As there is no similar provision for resident hunters, this will inevitably result in resident hunters not being able to consistently achieve their proportion of the AAH.
These policies and other provisions will result in the slow transfer of allocation from Residents to the commercial sector. As the resource is public and under constant demand, I can not see the owners, British Columbia Residents, being willing to engage in this wholesale transfer to private interests.
Residents provide by far the largest portion (8.8 of the 9.43 million) dollars in gross government revenues from wildlife harvest. This combined with the possibility of 85 – 100 thousand voters upset with this change in government policy makes me wonder at just how much lobbing power the commercial hunting sector has.
Now if you disagree with where the Ministry is heading with these new policies and procedures, make some phone calls if you can. Your M.L.A should feel some heat, get him checking into this. Generate some noise. The Honorable Barry Penner (Minister of Environment) has the power to stop this with a phone call, try and get his attention. You can send letters but this time of year they will almost certainly arrive to late. This is going into effect January 1,2007. I am more than happy to pass along the documents that I have been looking at and have quoted here, most are in the Adobe PDF format. Send me a Private Message with your E-Mail address.
First a little background as to why these changes are coming.
Mr. Tom Ethier (Assistant Director, Fish & Wildlife Branch) formed a B.C. Wildlife Harvest Allocation Review “Task Group” to create a new harvest allocation policy, procedure, and implementation plan. This group included Wilf Pfleiderer (BC Wildlife Federation), Dale Drown (Guide Outfitters Association of BC), and Dave Hatler (BC Trappers Association).
Nancy Wilkin (the Assistant Deputy Minister of the Environmental Stewardship Division), is prepared to implement the resulting policies and procedures in time for the 2007 hunting season. In my opinion these changes are being rushed into place in hopes the Holiday Season will provide enough of a distraction that we won’t notice or we’ll be too busy to get involved.
Mr. Tom Ethier says the M.O.E. needed these changes to create a consistent and transparent approach for making allocation decisions across the Province, and that they are reflective of resident B.C. hunters’ interests. Well … you decide.
With regards to the Ministry’s procedure for Harvest Allocation;
Step 1 Apply Initial Allocation.
The Director should assign an initial allocation of 75% of the allowable harvest to resident hunters and 25% to guide outfitters for each category A species in each region.
An initial allocation split of 75%/25% is way to high in favor of the guide outfitters. It has a net result of awarding approximately 28,500 Residents the same allocation as 6400 Non-Residents. This hardly constitutes Resident Priority. To even achieve parity a 93%/7% split would be required.
Step 2 – A; Determine Relative Importance to Resident Hunters
This entire procedure is predicated on all Category A species being on LEH. This does not give a true picture of resident demand. First of all, not all species are on LEH in all areas. Second, many residents have given up on the LEH system and do not participate in the system. (A Category A species is any species that Guides are on Quota in any area in a Region)
From the Ministry’s policy on Resident Hunter Priority, item 2 reads;
providing residents with a minimum share of 98% for antlerless category A species and 50% for all other category A species.
Ok in the first part but 50% to me isn’t a clear majority of the AAH (Annual Allowable Harvest), which is what the resident hunter is supposed to be guaranteed. At the very least 60% should always be awarded to the resident hunter. For your info, our AAH is what is left AFTER the “legal rights of First Nations have been recognized and addressed”, and it is split between the resident and commercial hunter.
From the Ministry’s Commercial Hunting Interests policy statement;
Point 2 regarding the Ministry addressing the commercial interests of the Guide Outfitters reads;
providing predictable, fair shares of the allocations of category A species in tenured areas;
There is no provision that resident hunters should have a predictable harvest share, why should non-resident (Guided) hunters have this provision?
Point 3 – C reads;
“The creation and maintenance of a regulatory framework that maximizes non-resident hunting success, enjoyment, and participation.”
Now, as we have the exact same thing in the Resident Hunter Priority policy, I would like assurances that resident hunters interests will prevail in any cases of conflict between resident hunters and non-resident hunters where both sides are claiming an issue.
From the Ministry’s policy on Allocation of Previously Unopened Hunts, item 1 reads;
That the allowable harvest of previously unopened hunts on category A species be allocated 75% to resident hunters and 25% to guide outfitters for the duration of the first allocation period. (an allocation period = 5 years).
As the resident hunter is always supposed to enjoy a clear majority of the AAH, I feel an 80/20 split would be more reflective of that. The guides automatically get ¼ of the harvest?? Why? The non-resident hunter is not loosing anything here as they have never had access to this population so 20% is still 20% more than what they had!
With regards to the Ministry’s policy on Under-Harvest of Allocated Share, the policy states;
If either hunter group under-harvests a category A species regionally for three consecutive years, the Regional Manager will provide a report to the Director that reviews the regulations and/or license conditions relating to the particular species.
Although this is a positive for Resident Hunters, there are two problems with what the Ministry is presently proposing. First MOE is talking about this process being triggered at a 40% under-harvest and second there is no mandatory provision that the Regional Manager makes the recommended changes. An under-harvest of 25% or more over a three-year period should trigger the process and the results must be implemented.
With regards to the Ministry’s process by which Administrative Guidelines are to be applied to Guide Outfitter quotas;
This is a very difficult section to explain so I have gotten a lot of help here to try and get across the issue. Administrative Guidelines are a way that Commercial Sector is allowed to exceed “Quota” for a single year. There is no rational for applying Administrative Guidelines to whole number quotas. Applying Administrative Guidelines to small quotas may be justified however it is totally unnecessary with large quotas. Furthermore, Administrative Guidelines will be used to exceed “quotas” on years of relative abundance. As there is no similar provision for resident hunters, this will inevitably result in resident hunters not being able to consistently achieve their proportion of the AAH.
These policies and other provisions will result in the slow transfer of allocation from Residents to the commercial sector. As the resource is public and under constant demand, I can not see the owners, British Columbia Residents, being willing to engage in this wholesale transfer to private interests.
Residents provide by far the largest portion (8.8 of the 9.43 million) dollars in gross government revenues from wildlife harvest. This combined with the possibility of 85 – 100 thousand voters upset with this change in government policy makes me wonder at just how much lobbing power the commercial hunting sector has.
Now if you disagree with where the Ministry is heading with these new policies and procedures, make some phone calls if you can. Your M.L.A should feel some heat, get him checking into this. Generate some noise. The Honorable Barry Penner (Minister of Environment) has the power to stop this with a phone call, try and get his attention. You can send letters but this time of year they will almost certainly arrive to late. This is going into effect January 1,2007. I am more than happy to pass along the documents that I have been looking at and have quoted here, most are in the Adobe PDF format. Send me a Private Message with your E-Mail address.
