I have the following…

I have the following comments to make on the proposed changes for the Moose draw. First of all I would like to commend the ministry and BGMAC committee for all their work on this proposal. I support the principle of the proposal with the following comments.
I support the proposed changes for 2020. Especially the inclusion of a bows only season for WMU's 46,47,49,50,53,54,56,58,59,60,61,62,and 63. However I disagree with the starting date of the first Saturday in October. In those southern WMU's a vast majority of the hunters hunt from established camps and in the past it was convenient to have the season start on a Monday. This allowed hunters to move into the camp on the weekend before the season started and not have to take extra days off work. I would like to see both the new bow seasons and the gun seasons move in the southern WMU's to a Monday opening. I suggest the last Monday in September for the bow season and the 3rd Monday in October for the gun season. This also eliminates the issue of the gun season for moose ending 2 days before the deer season starts ( as it does with the current start date every 4 years).
I support the proposed selective harvest approach and the preference point system. However I have the following concerns.

There is no mention of how the proposal would treat the apprentice hunters. At this time they are not able to enter draws. However they are able to purchase a moose licence with a calf tag. Under the proposed system if the apprentice's mentor does not have a tag they will not be able to hunt. This could restrict their their hunting opportunities. I feel that apprentice hunters should be able to enter the 2nd chance random draw for a calf tag. These will basically be surplus tags. This would also allow them to gain points for when they are able to enter the primary draw.
There is limited information on the fee structure in the proposal. I feel that the application fee should not be more than $15. Since there is a chance that many hunters / groups will not receive tags and therefore not able to hunt that year, the fee for applying in the draw should be minimal . As well calf tags should not be excessively priced ( more than $20) since there are many hunters who hunt as individuals or groups of two. Those people would find that the purchase of a tag every year or every two years would result in the cost of hunting on a yearly basis costing much more than it does the existing system. I would suggest that all tags that are allocated in the 2nd chance draw second and third choice ( the random draw) be of no charge.

I oppose the restriction of the party hunting rules. Although it is suggested that it may reduce fill rates there is nothing to validate that statement. With the proposed draw system, you are promoting hunters to hunt in groups through the draw process and then restricting them from party hunting. There can not be a restriction on party hunting size if you are promoting large groups through the draw. Also, reducing the distance for party hunting makes no sense. The emphasis for party hunting must be based on communication of the hunting party and not distance. A ban on the use of cell phones and radios with a range of more than 5 km would make more sense and would be easier to enforce.

The allocation process for issuing the tags is not stated in the proposal. There are at least two ways the tags can be allocated. The first option would be to sort all the applicants in each WMU by their preference number and then allocate the tags to based on the first choice , then second choice, and finally the 3rd choice ( if there are tags left). The second option would be to sort applicants by the tag choice ( bull, cow/calf, and calf only) and then allocate the tags to the highest preference numbers. There are pros and cons to both options,but I feel the most important thing is to make sure that it is clearly communicated to the applicants how the tags are allocated.