I understand the need to…

I understand the need to modernize the current licensing system, however I believe that some of the proposed measures are flawed and will be counter productive to effective wildlife management in that they will be difficult or impossible to monitor and enforce. At the same time I believe there are opportunities for further improvement that should be taken advantage of now.
Mobile Technology: The increased reliance on mobile technology is convenient for the outdoors public but will create some unintended consequences. While simple to carry, hunters and anglers will have to made aware they are solely responsible for any loss or damage to their personal device should it become lost, wet, or dropped, during an inspection. I also anticipate there will be public concern for privacy of personal information when an investigating officer has to take control of the device (even for a short period) in order to make comprehensive notes following the “best evidence” rule (i.e., the officer may have to take the device to their patrol vehicle to review, and make investigative notes about, the individuals app to confirm aspects of licences, tags, and validations).
From an officer safety perspective having to view information from a mobile device screen limits situational awareness (i.e., where people are and what they are doing), and can also have serious negative effects on the officers night vision.
Game Tag Modernization – paper tags: The requirement for hunters to have a game tag is the cornerstone of MNRs selective harvest system for deer, moose, bear, elk, and wild turkey. Anything that diminishes the effectiveness, or the perception of integrity, of the tag system will have a negative effect on compliance to the rules used to manage the wildlife resource, and on that resource itself. The current use of print-at-home tags has seriously diminished public trust in the MNR as a competent resource manager. The continued use of this flawed system (i.e., the printing or copying of multiple tags), when there is opportunity to correct the flaw now, can only result in further erosion of trust in the MNR as a credible manager of a public resource.
As a retired Ontario conservation officer I am connected to a network of other retired officers, many of whom hunt. In June of this year, while preparing to respond this Registry proposal, I surveyed some of my peers by asking the following question: “Do you have first hand knowledge of anyone who has printed or made more than one copy of their licence tag?”. Of sixteen responses fourteen had direct knowledge of someone committing this unlawful act, while only two responded in the negative. Although I did not ask for numbers six of the respondents provided the number of people they had knowledge of, which ranged from only one person to as many as eight individuals. If this sample is representative of the broader hunting public currently not complying with the foundational rule of one tag per hunter per animal, then continuing to rely on the current paper based print-at-home approach is a failure to manage the public trust with integrity – blindly relying on hunters to “do the right thing” has obviously not worked. Perhaps those who wish to continue to use a physical tag should pay for that opportunity and be provided with an MNR issued, tamper resistant, tag.
Game Tag Modernization – digital tags: I believe that moving towards digital tags could be a significant improvement to managing this category of hunted wildlife in that the uploaded information from invalidating the tag could be used as a “kill registration” system, since it can give more accurate information than the current post-season hunter report (provided the system collects kill date and time as a minimum, and possibly GPS location).
Suggesting the use of “scrap paper” attached to the carcass, when the tagging hunter is no longer immediately available to display their tag, is a failure to modernize the system and to take advantage of the current opportunity. There are very few hunting situations where the tagging hunter will be with the carcass at all times between harvest and final butchering for preservation. Since the requirement to affix a tag is virtually inevitable a solution that supports the integrity of the system, and that allows easy compliance confirmation, must be proposed by MNR. One solution might be to develop a carcass tag form. It would be made available on the app (and therefor have the hunter and licence details pre-filled) and printed before the hunt. The carcass tag could also be a printed in the paper Hunting Regulations Summary, to be cut out and carried by those without access to a computer printer. Relying on hunters to carry a scrap of paper, that is not an MNR form, and to also remember the details that need to written on that scrap of paper, is extremely unlikely to succeed and does little to support confidence in MNR as a competent resource manager.
Game Tag Modernization – digital tags and night hunting: One of the unintended consequences of the digital game tag system will be the issue of perceived night hunting when a hunter blood trails a fatally wounded game animal after hunting hours, and then follows the rule to immediately invalidate the tag at the place and time of kill. Under the current FWCA definition “following after” constitutes hunting and following after a wounded animal at night is unlawful. Yet the majority of hunters will make an ethically proper attempt to retrieve the animal, even after legal hours, to avoid meat spoilage or scavenging by wildlife. A regulation change is necessary to allow for night tracking of lawfully wounded game, including with the use of a leashed dog.
In addition to a regulation change allowing for lawful tracking of wounded game after hours (and the period immediately after the end of season) the digital app might be used to support a night tracking system. The hunter would open the night tracking authorization on the app, and enable it before beginning the track and complete it once the track has ended. This authorization would be linked to the hunters tag, and would account for invalidating the tag after hunting hours. As a positive side benefit this approach would give MNR data about game tracking and recovery efforts.
Game Tag Modernization – digital tags and carcass transportation. Very often hunters will divide a carcass into portions after the hunt. As a result hunters are encountered by officers transporting untagged portions of game meat while conduction compliance checks. Very often the hunter in possession of the meat portion has very little information about the person who tagged the animal, making compliance confirmation difficult. This issue could be addressed through the app by creating a carcass transportation authorization (again with a paper version that can be cut from the hunting regulations summary).
Licensing System – modernizing compliance monitoring. The FWCA contains a variety of hunting and fishing advantages and opportunities that are based on residency and other criteria. The incentive to misrepresent residency, or other qualifying conditions, range from licence costs for anglers (Ontario resident vs Canadian resident vs non-Canadian resident fees), to accessing limited hunting opportunities such as antlerless deer tags and controlled deer hunt validations, resident moose licences without the need to be accommodated by an outfitter, and Northern Residence preference points to access moose tags. I understand there are even inactive hunters names that continue to be entered into draws by party members who have access to these otherwise dormant accounts. Given the advanced state of computer technology MNR should be taking advantage of other government data base information, and potentially AI, to identify the fraudulent activity of those taking advantage of the licensing system. The integrity of the licensing system cannot be left to chance encounters by a small number of Conservation Officers in the field when technology can easily be used to audit the data base for fraud.
In closing, I support the modernization of the licensing system and the development of new licence products. Modernization, however must be done with care and foresight to anticipate the consequences, and any changes must support effective management of wildlife resources and provide appropriate opportunity to monitor compliance to the regulations.