Re: Moose Management Review…

Re: Moose Management Review ERO 019-0405

I am a moose hunter and I have purchased moose licences, participated in, and supported the moose hunt in Ontario for most years since 1983. Disclaimer: I have to admit that my bias is for the current moose tag allocation that is in place in Ontario as I have received my share of adult moose tags over the years. I have concerns with ERO 019-0405 which I will address later.

I have reviewed the following documents:

1) Proposed changes to Moose management as part of the Moose Management Review, ERO 019-0405; and

2) Moose Management Review: Recommendations to the Minister of Natural Resources and Forestry on Moose Management.

By far, the biggest concern with the proposed changes to the moose allocation draw is the proposed introduction of a tag draw that will be based on a point system! In its report, the Big Game Management and Advisory Committee (BGMAC) makes reference to the unfairness of the current group application and moose tag allocation system, particularly the use of "ghost applicants" that is allegedly employed by some moose hunting groups in Ontario. I understand the concerns of the BGMAC in this regard. However, if memory serves me correct, was it not both the MNRF and the OFAH that encouraged moose hunters to apply in large groups so that moose hunting opportunities would be maximized to the hunting community and tags would be spread out more evenly to a larger number of hunt groups. As a matter of fact, the Ontario Hunting Regulations, until very recently, used to dedicate a few paragraphs to the subject of "how to maximize your chances in the moose tag allocation draw", or words to that effect. Just as there are currently vocal moose hunters in Ontario that are not satisfied with the current allocation draw, I predict that there will be those of us that have been recent recipients of moose tags that are going to be equally dissatisfied with the proposed point based system, especially if the system builds in systemic bias by applying points that are indexed back to 1983!
If indeed the problem with current tag allocation system is grossly unfair, then simply amend the rules "to tighten things up" and to reduce the chances of abuse. Why do we have to re-invent the wheel, especially since the BGMAC has already admitted in its report that the proposed new point based system is biased in favour of hunters who have gone for long periods of time without receiving a tag. Further, the hunter surveys received by the BGMAC indicate that most hunters are somewhat satisfied with the status quo of the current tag allocation system. I will admit that on the surface correcting past flaws in a system is a noble cause because it is the right thing to do, but maybe there is a little more to the story than simply saying that its not fair and I will address that subject a little further down the line! In the meantime, may I humbly suggest the following for your consideration?

Modifications to the Group Application System

1) No single applicants in the draw, group applications only;
2) Group sizes between 4-10 hunters;
3) Eliminate guaranteed group sizes;
4) All members of the group must be noted on the application;
5) All members of the group must be present during the hunt;
6) Mandatory check stations and reports.
7) Any violation of the above then receive a financial penalty and automatic 5 year hunting suspension.

I now have some questions concerning the responses from the moose hunter surveys as well as verbal feedback from the listening sessions. Given that there are approximately 80,000 moose hunters in Ontario and given that only 600 (+/-) hunters attended the listening sessions to vocalize their concerns, this would suggest to me that most of the other moose hunters not heard from are at least somewhat satisfied with the current tag allocation system, otherwise they may have made their concerns known! Either that or more listening sessions are needed over a greater geographical area.

I have a few questions for those applicants that have been unsuccessful for a prolonged period of time:

1) Did the unsuccessful applicants reveal that they were willing to consider employing the services of a registered outfitter that may have been able to provide a moose tag as part of a package hunt?

2) Did the unsuccessful applicants reveal that they were willing to attempt or attempted to join up with other like minded hunters in order to increase their group size and in turn increase their chances of receiving a moose tag?

3) Did the unsuccessful applicants reveal whether or not they were willing to to apply in a more remote WMU with less application demand which in turn could possibly increase their chances of success in drawing a tag?

In short, just how flexible were these unsuccessful applicants in their approach to the moose tag application process? May I humbly submit that in 2019, you cannot expect to hunt with your own tag from the back door of your house, nor should you limit your application to the hunt camp because that's where I always go, nor should you limit your application to the same old WMU because that is where you have always applied and coincidentally it is the same old WMU that has a very limited number of tags and a very high applicant demand. I have pontificated enough!
Lets face it, this is 2019, we all know that there are very limited resources available and if an individual wants to experience any kind of success drawing a moose tag, then moose hunting has to become a priority in ones life if it is not already and that might also mean one has to be flexible in their approach to tag application, the area to hunt, etc.

Before I continue, I want to state what is commonly known, yet bears repeating in regards to moose hunting and the moose hunters in Ontario. There are a considerable number of moose hunters in Ontario that each year purchase moose licences, enter tag allocation draws, travel vast distances at great expense just for the opportunity to hunt moose and let us not forget the economic benefits they bring forth to the local Ontario communities and the coffers of the Government of Ontario. Moose hunters don't just take, they also give back!

Tag Allocation via Point Based System

The proposed point system that is contained in ERO 019-0405 has at least three components that cause me concern:

1)Point Crawling;
What mechanism will be in place to regulate or stop this from occurring? My biggest concern is that just when an applicant has met the required point standard, the MNRF does a "review" and then proceeds to raise the point standard to a higher level and thus the applicant must wait patiently year after year to increase their points with no guarantee that the MNRF will not put forth another review and possibly another calculation to adjust the tag quota yet again!

2)High Point Applicants monopolizing the draw;
Just as the Large groups/guaranteed size groups in today's system are accused of abuse, I perceive of at least one situation where a large group that is populated with high point applicants can take "advantage" of the intent of the system. For example, Applicant A has high points, receives a tag in the allocation draw, but he knows of several other applicants that also have similarly high points. They form an understanding that, if drawn, the other applicants(s) would defer their tag(s) to the future and become a member of his group. The next year comes and the steps are repeated and again year after year until all the high point applicants of the group are exhausted. Conceivably they could monopolize up to ten years worth of tags, given that the new proposal suggest capping the group size at ten hunters. In my opinion this would be worst that "ghost applicants", at least under the current system, there is some fairness that comes with a random draw!

3)Second Allocation;
Consider the following..... Hunter "A" defers a tag in WMU 123 and keeps his points. Subsequent to that, there is a second allocation draw in an adjacent WMU, Hunter "A" reapplies to the second allocation draw which I believe he is allowed to do and receives a tag in the second allocation but yet does not lose his accumulated points? Is this a correct interpretation?

If the MNRF adapts the contents ERO 019-0405 as it exists today, then I firmly believe that there will also be imbalances/abuse within this system as well. In effect we will have a new "unfair" system that replaced the old "unfair" system. The only thing that will change as far as the success of an application goes will be the faces and the names and we will be back to this point again in another three to five years to yet again reinvent the wheel.

Other Concerns RE: Moose Management

In it's report, the BGMAC suggests that under the current system, moose hunters are too successful, that there are too many moose being harvested! How can this be? Are quotas not based on data and information gathering that is later formulated into scientific models/harvest quotas? If there is indeed too many moose being harvested, then it would seem to me that there was incorrect data gathered or the model and its assumptions are not valid! Are other factors other than scientific data and licensed hunters being considered when calculating quotas? I do not want to fault the science, but as a lay person something here is not adding up! I will concede that the moose harvest may need to be reduced in some areas, but how can you achieve a lower moose harvest by changing the rules that affect the licensed hunters alone. Clearly there are other factors at play here that are just as important to the stability and future growth of the moose herd. In my estimation, other factors that ought to be in the forefront of moose management are:

1) unlicensed hunters;
2) illicit activity e.g., poaching
3) natural predation e.g., bears/wolves
4) disease and infestation;
5) forestry operations e.g., cutting and spraying activities
6) conflict with the modern world e.g., car/train collisions

What I would have liked to have seen ER O019-0405 was a statement or recommendation(s) on how to proceed or deal with the above noted activities. We can no longer look at the licensed hunting community alone. As a lay person, even I can see that the moose herd dynamics are far too complex for that. I believe the focus of the BGMAC has been too narrow in its approach in this regard and that we have to push political and economic factors to the side, let's make this moose study more encompassing. I find it somewhat ironic that the licensed hunting community that has traditionally paid its fair share of the freight when it comes to moose management are once again called upon to do their part and make their share of the sacrifices and when it comes to the other moose herd dynamics, all we seem to hear are crickets.....

In conclusion, if this exercise is about the Moose, then let us make it for the Moose, no half measures. If toes need to be stepped on, then so be it. Political and economic considerations should not enter into this discussion. It is about what is good for the Moose.

I have taken the liberty to list below what I believe are some important components that may make a workable plan for moose recovery,

1) It is imperative that the Native communities in this province be encouraged to embrace a harvest program that honors their treaty rights and also respects the concepts resource conservation and management. The moose belong to all of the people of Ontario!;

2)Severely restrict or eliminate the calf harvest for a period of five (5) years, then study;

3)Intensify a predator management program by increasing bag limits on bears/wolves for five (5) years and then study in conjunction with (2) above;

4) Restrict forestry operations. Restrict the size and scope of clear cut operations, also leave more and bigger natural buffer areas in and around cuts. Discourage the use of herbicides/pesticides and promote natural forest regeneration.

5) Shorten the moose season to two (2) weeks, no exceptions;

6)Where the herd size is not at its intended goal or is unstable, institute a bows only season and eliminate the rifle season;

7)No tag transfers.If a hunter with a moose tag is unable to attend a hunt, in the proposed system, applicants points would be reimbursed or applicant would be reestablished into Pool#1 in the current system pending medical validation.

8)Increase enforcement penalties where it can be reasonably proven that infractions in the law was intentional (make the penalty a deterrent).;

9)In areas where it can be scientifically confirmed/proven that there is excessive pressure on the moose herd, then eliminate mechanized transport to gain access to a hunting area. e.g.,no airplanes, no motor boats, no land based motorized vehicles allowed. Primitive transport only. e.g., canoes/kayaks/hike

10) Introduce a mandatory Moose hunter education program at no cost to the MNRF. No moose course, then no licence.
The focus of the program should include, but not be limited to the following:
a) hunter safety;
b) firearms proficiency;
c) moose hunting regulations; and
d) moose biology, emphasis on gender identification;

I want to thank you for patiently taking the time to read my submission and perhaps you may wish to give some consideration to the points that I have attempted to make here today.