To: Whom it May Concern,…

To: Whom it May Concern, MNRF Moose Policy Committee

Re: Comments regarding revision of Moose Draw& Tag Allocation

For the most part I will refer to the numbers for WMU 60 as it is where our hunt camp LUP is located.
In the immediate area surrounding us there are 6 hunt camps with an approximate total number of hunters equal to 5% of the Bull Tag Applicants for WMU 60 in the year 2018. Some of these camps/groups apply as a large group but most do not, and as such the ratio of group applicants vs individual applicants may not be consistent with the published number of 49.7% of applicants applied in groups for 2018.

In this case, and as I would expect elsewhere in the province, the percentage of applicants who hunt in a group is much higher then the numbers reflected in the 2018 draw applications. In the camps surrounding us geographically, this has happened for a number of reasons, but mostly because people felt there was no advantage to apply as a group, particularly when in an area without a guaranteed group size and the hunter to tag ratio is higher then the maximum group size of 15.

For arguments sake going forward in this problem and solution comment, I will make my examples using a straight 50/50 ratio of past group to individual applications.

Additionally in WMU 60 for year 2018 there were 1524 applicants for 52 Bull Tags. For simplicity in my examples I will use an approximation of 50 tags and 1500 applicants.

Problem 1: No Preference Given to Groups, Large or Small.

The proposal of no group applications will be a SERIOUS DETRIMENT TO REVENUE.
In our group of 16 for example, the current approximate revenue from licenses is $944 annually. Although we don’t know what the ‘modest fee’ will be for applying under the new proposal, I can tell you that in years that we do not have an adult tag our numbers are usually 6 hunters in the field instead of 16, however in past years we have already spent the entire license fee before the draw.

In talking with our group members and explaining that a calf tag could make you surrender your accumulated points under this new proposal, the overwhelming response was “I just won’t hunt that year” As a result I would expect the number of active hunters to be lower then the previous scenario of 6 because there wouldn’t be any perceived value of 1 calf tag for the group/camp. As a result and using a fictitious amount of $29 as an application fee, the effective revenue for our group would decline by 50% for application fee only.

Our Solution For Problem 1.

Maintain a group application system using the group to individual applicants ratio/percentage of total tags available.
I.E. From 2018 Quota and using a 50/50 ratio of groups to individual applications for
WMU 60, the 50 Bull Tags would be split into 25 for groups and 25 for individuals.
The individual applicants would use their accumulated points as proposed in the new system.
The Groups would be able to consolidate their points to have a running total year to year. Once a set number of points are achieved, a tag is allocated and if claimed to the person inside the group who has gone the longest without a tag, AND all members of the group surrender their points.
Limit tag transfers to one in a lifetime unless death occurs between claiming the tag and the start of the hunt.

USING WMU 60 THIS IS HOW IT WOULD LOOK (using 2018 Quota and applicant numbers)
1500 applicants for 50 BULL TAGS, 50% groups, 50% individuals
1500 divide by 50 tags =30
30 would be the required number of points to be awarded a Bull Tag
Under the new proposal as it is today, an individual would receive a tag once 30 points is accumulated.
The number of points required each year would vary slightly and would be based on the previous year’s applications to tag ratio. (1500 divide by 50 example above)

A group would receive a tag once the required number of points is accumulated.

THIS GROUP APPLICATION DOES NOT DISCRIMINATE AGAINST THE INDIVIDUAL as it is the same percentage and points system that is currently being proposed.
It simply allows Groups of any size to pool their points.
It also goes without saying that a group of 16 should have a higher frequency of obtaining a tag then an individual, even if solely based on the revenue difference of 16 fees vs 1 fee.

Problem 2 How Points are Rewarded and Accumulated
Under the new proposal an applicant is to receive 1 point for every year they go without obtaining a tag. They can obtain this point by just applying to the process and only paying the application fee.
This is completely unfair to an applicant who applies, pays the fee, is unsuccessful but ends up buying the full license so they can party hunt, and as such produces more revenue for the system.

Solution for Problem 2
Simply make the application fee equal to ½ the total license fee and have the points match the amount paid.
½ point is awarded if the applicant applies, and an additional ½ point is rewarded if the individual buys the other half of the license so they can party hunt on someone else’s tag.

Problem 3 Cutting Group Size to Max 10 Hunters
Why should it matter what size the group is if the tags are separate for groups and individuals?
The separate allocation for groups vs individuals would satisfy all concerns from individuals about ‘ghost hunters’.
The one transfer per lifetime will effectively remove the Ghost Applications over time.
In a camp like ours, and many others in Southern Ontario, there are routinely more then 10 hunters when an adult tag is in hand. This new restriction would be disqualifying 6 hunters in our group and have an adverse effect on revenue as there would be 6 people not paying the full license fee.

Solution for Problem 3
Make group maximum 16 as most traditional camps have 12-16 beds. Although a large group may have a higher harvest rate because they cover area more effectively, the new restriction on party hunting distance would still limit the group to a very specific area.
Limit tag transfers to one in a lifetime unless death occurs between claiming the tag and the start of the hunt.
If a large group has a history of 75% fill rate on adult tags in the past and only got a tag every three years, it would effectively reduce their rate of success to 25% based on a tag every 3 years.
Leaving the large group size preference will speed up the turnover from the back of the line to front as all hunters in the group would surrender their points.

Problem 4 Number of Years Between Front and Back of the Line
Although listed as problem 4, this is quite likely the most concerning issue of all.

How do you recruit new/first time hunters if the wait time is 30 years to get a tag?
(Using WMU numbers of 1500 bull applicants divided by 50 tags)
This will kill revenues as the current hunters die off or retire from hunting.

Problem 4 Solution
Leave the group application in place allowing accumulated point system. This provides an opportunity for a new hunter to be part of a group with a tag on a more frequent and reliable basis.
This also affords a group to recruit new members on an ongoing basis, which contributes to the sustainability of an active moose hunt in Ontario.

The group application WILL have a positive impact on long-term revenue.

Your Name goes here

Moose Hunter since __1997______(year), WMU #___19___