A fulsome review of moose…

A fulsome review of moose management and hunting is a long time coming and I commend the Minister and MNRF staff for conducting widespread consultation on the topic. Moose hunters are creatures of habit and this is a wholesale change to the very structure of moose hunting. Some moose hunters have already consistently demonstrated their inability to understand the regulations, so clear and frequent communication will be key.

In my career as a wildlife biologist involved in moose management in Ontario, I have witnessed a slow but steady shift in the moose hunting community opinion/attitude to a system that provides additional protection to calves, as well as cows (despite an oft-misused analogy to cattle). The proposed changes to calf hunting will negatively impact a lot of hunters but there is likely more overall support within the moose hunting community than ever before.

I fully agree with implementing calf harvest controls but my support is entirely contingent on the promise of increased adult hunting opportunities in the future. There’s a history of district and regional biologists being unnecessarily cautious with the provision of hunting opportunities and it is highly likely that hunters will not be provided with the additional adult hunting opportunities that are being promised. This lack of consistency between managers must be addressed through harvest management guidelines.

Hunt camps will be disproportionately impacted by this change, and as such I expect public opinion to be polarized. Some of these hunt camps that have invested thousands of dollars and shared generations of hunting memories will be unable to shift their hunting activity to other units, creating a disproportionate impact compared to other groups that the government has no right to ignore. How will the calf tag quota be determined in the absence of established guidelines or policy direction? Will it be set at a percentage of total allowable harvest? Will ‘percent calves’ be similar between residents and the tourist industry? I recommend setting the ‘percent calves’ at no more than 20% of TAH, ideally less. This will help strike a balance between maintaining overall hunting opportunities with increasing adult hunting opportunities, and contribute to population sustainability.

I support creating separate tag quotas for bow and gun in northern units but due to the impact on existing gun tag quotas, should start off relatively low. I also support the creation of bows-only seasons in southern units with separate quotas, and shifting the season.

The proposed new selective harvest approach is long overdue. The creation of separate licensing products is a positive and necessary step. However, this change will have an unpredictable impact on the Special Purpose Account. I recommend a pricing structure that is revenue neutral or close to it.
Preference point system: moose hunters were loud and clear – they want change. Whether this new structure is the right decision or not, changing the system has been called for extensively. I support this change in principle (despite the current system actually being much fairer than most hunters perceive) but this proposed preference point system will present a barrier for the recruitment of new moose hunters. The MNRF can scarcely afford unimpeded hemorrhaging of moose hunters, particularly if there will be a projected loss of revenue as a result of moving to an application fee process in 2021. Likewise, for older hunters that have gone a long time without getting a tag, the first few years of this new system will generate a tag in their name but it could also mean they likely won’t ever get another tag in their name in their lifetime. However, I recognize that the details have not been finalized and I look forward to seeing the full details of implementation.

I support the elimination of the Northern Resident draw, a system that sowed unnecessary division between northern and southern residents over provincial resources. The proposed provision of an extra point to northern residents simply reinforces this imbalance between hunters and I strongly oppose this aspect of the proposal. There is no similar accommodation for southern Ontario hunters (elk in Bancroft/North Hastings, antlerless deer). Why is preferential treatment for one segment of the community limited to moose hunting? This wholesale review of moose is a prime opportunity to eliminate this nonsense, not reinforce it.

A two-stage allocation is promising and should address the longstanding issue of unutilized hunting opportunities and allow the province to divest itself from the frustrating surplus tag system.

I am pleased to see the MNRF considering the implementation of a deadline by which tags must be purchased - it’s possibly the most appealing aspect of this proposal. The MNRF should consider a similar deadline for the elk draw. It’s a progressive change, and I’m not ashamed to admit that it’s something that I’ve pushed professionally in the past.

Tag transfers should be limited to extreme circumstances, and I wouldn’t complain about requiring a doctor’s note or some other proof. I assume that a hunter would be able to transfer the tag to any other licensed moose hunter (rather than just a member of a group application)? Since the pool of potential transferees is being expanded, it’s necessary to limit the conditions under which a tag can be transferred so as not to encourage transfers.

In principle, I support efforts to reduce tag fill rates. But I question the proposed changes to party size – how will the limit of 10 hunters be enforced? Has any modelling been done to determine the point at which TFR is actually reduced or are we just guessing at a starting point?

I agree with eliminating special access to moose hunting opportunities in Ontario. I’m pleased to see that the proposal includes aspects that weren’t recommended by BGMAC due to the concerns that I raised earlier about geographical bias in composition.

Finally, we have decades of evidence to support the claim that MNRF communications is dismal at best despite having an entire Branch dedicated to it. These fundamental changes will be a communications nightmare. I recommend developing a clear communications plan that also includes groups like the OFAH.

Thank you for the opportunity to provide input.