Comments on the Moose…

Comments on the Moose Management Review in the ERO
I attended a workshop in central Ontario and listened to a number of conversations between MNRF staff and hunters and between hunters. I had an extraordinary discussion with a hunter who clearly understood the intricacies of the moose system, the hunt and the factors that influence the health of the herd and didn’t blame the present health of the herd on “others” or “other factors” but clearly understood the role of harvest in the present state of the herd. I’ve reviewed all of the material on the Environmental Registry and have reviewed forest management plans for moose habitat in the past.

1. Implementing calf tags

I agree with the implementation of calf tags. This will make full harvest control a possibility. The last link will be non-regulated harvest however that may take some time yet.

2. Archery seasons for S Ontario/

I support an archery season for the S Ontario units. I may even become an archer in the S. Ontario unit I hunt as tags are hard to get for gun and every cow or calf I have killed in the past 11 years could have been easily harvested with a crossbow. NOTE: my switch to archery if I choose to do so is not a new hunting opportunity, just a converted one.

3. Separate archery quotas.

What I do not support is a separate archery quota taken from the gun allocation.

What I would support is the present fair draw of tags that occurs in units like WMU 41 where gun and archery hunters have equal chance of drawing a tag through one draw where the applicant indicates whether they wish to have the tag issued as an archery tag or a gun tag.

My concern with implementing archery seasons in S Ontario is that it well might attract many more moose archers to these units from distant units like WMU 21 or 12B etc that require 15-20 hr drives. Units like WMU 47 might see an influx of 1-2,000 archers to a unit that might provide 100 adult tags split between gun and archery in a calf controlled environment. These smaller units may see 100% increases in total hunters with 70% being archers, moreso if existing unit gun hunters begin switching to archery as well.

These are not “new hunting opportunities” they are just relocated or converted hunting opportunities that may well cause social issues amongst the strong local hunt clubs within these moose units.

4. Cow/calf tags

I support the notion that a hunter with a cow tag should be allowed to harvest a calf and leave the cow as a prime breeder. Hunters may not want to orphan calves so this gives them an option other than searching for a dry cow.

5. Modest tag application fee

The present license costs $50.29 and generates in excess of $4.2 million dollars in license fees (82,000+ applicants +non applicants). Simple math suggest that $2.1 million will be collected if the application fee is $25. In order to generate the remaining income each adult tag would cost approximately $250 requiring a group of 7 or more to split the cost to break even with the present system. This may be mitigated by the number and price of calf tags and encourages the issuance of more adult tags to mitigate adult tag prices (not entirely a good thing).

6. Selective harvest system is for cow protection

Nowhere have I ever seen where the selective harvest system was about saving cows. Low density populations require the protection of bulls to ensure adequate levels of fertilization according to the literature. Last time I checked we have lots of low density moose populations in northeastern Ontario. Bulls are differentially vulnerable particularly in early fall which coincides with the unregulated hunt and are the primary focus of archers, again an earlier hunt.

Misleading hunters into believing moose herds can be managed with low bull densities in the same fashion as deer provides a misunderstanding of the significant differences between the two species.

7. Tag Transfers

The proposed system allows for a hunter who is unable to hunt for acute medical reasons to refuse a tag and retain his or her points. In point of fact there are no details on the criteria for allowing a transfer in this proposal.

Hunters should be allowed to refuse a tag at any time or for any reason up until the day before the hunt and retain his or her points but not be able to transfer the tag. If they determine they will be unable to hunt early enough they can avail themselves of the first refusal all hunters will be able to use. This makes the tag available for reissue for the second draw.

In this way it removes the need to determine the validity of the request for transfer (medical certificate for acute medical reason vs “diabetes”, death in family, vacation denied etc.) This invariable leads to confrontation with frontline staff, exceptions granted to those who call MPPs etc. All in all the results are bad messaging, poor customer service.

The new system is not a group system and as such there is no designated alternate. Transferring the tag to a party member with low points will be the latest moose hunt game.

8. Forest Management Plans –from proposal text

“Ensure access is being addressed in moose emphasis area prescriptions to address concerns about potential for high levels of moose harvest mortality in recent cuts.”

Moose emphasis areas must be identified early and often in plans. They must be made mandatory in all plans, make liberal use of prescribed fire for site preparation and road decommissioning rather than access being “addressed” in order to be effective.

“Re-evaluate science on the impacts of spraying glyphosate (forest treatment) on moose, and/or conduct research designed to evaluate glyphosate impacts on moose.”

More use of and evaluation of fire as a means of site preparation with an emphasis on moose habitat. Strategies for moose early stage forage provision within spray areas may be an alternative (ie post harvest leave blocks ). A number of great opportunities exist in northeast Ontario to limit hunter motorized access to the 2018 fire sites, prevent silvicultural activities to recover the “unproductive” lands or to salvage timber(making roads) and to evaluate the value to moose over the next 10 years.

“Ensure forest management prescriptions continue to support WMU-scale moose population objectives that were consulted on and approved in 2016 as part of the Moose Project.”

Typical forest management plans promise early successional forest for moose and other users of this forest type however often the forest industry does not deliver on these objectives due to “market conditions”.

The industry is not held to their non performance on their wildlife objectives to improve the forest condition by forest industry biased auditors who focus on site preparation(spray effectiveness), forest regeneration via spray and plant, road networks and water crossings. Often low value stands such as birch and pulp hardwood stands are not harvested due to “market conditions”, a factor that MNRF allows to outweigh the plan’s forest improvement objectives for wildlife.

“However, there is no reporting on how these prescriptions are applied or how moose populations respond.”

Again a statement in the proposal from observers. There seems to be no evaluation of moose emphasis areas that have been established nor whether they are being established on all forest units that have viable moose populations.
FMP’s are an impenetrable maze of text and tables that seem meant to discourage non industry participation. Separate reporting of the wildlife objectives achievement is required in audits. These results must be provided to wildlife advocates such as moose hunters in any easy to read format.

9. Enforcement

I would hate to have to enforce the paperwork requirements that will face CO’s when they run into a group. Having all hunters listed on the license will be a nightmare. Too many in a group, penciled in daily hunting partners etc etc.

The more onerous the tasks put on hunters the less likely hunters are to do it or do it well. The only thing moose hunters have learned to do is adapt to the systems to benefit themselves. In the field this aspect of the enforcement task may well be laughed at by officers and deemed field unenforceable. This does little for credibility of the system.