I represent a group of 9…

I represent a group of 9 hunters that hunt and maintain a camp in WMU29. Our camp has been hunting moose since 1965 and we have a range of ages in our hunting group from 17 to 74. An annual hunt is an important part of our heritage and our social fabric - it brings extended family together once a year.

We have made every effort to build an inclusive group in order to increase our odds in the current draw allocation system, where we have had fair success in the draw when tag numbers reflected a moose population that was within the MNR's stated population objectives. We see the current system as a fair system, where the rules were available and communicated to hunters, and that all applicants had a chance to draw a tag on an annual basis. We recognize that there were certain policy objectives that tilted the odds against individual hunters, such as the Northern Resident Draw, the Guaranteed Group allocation, and the Hunter/Tag Ratio Allocation (where applicable). We believe that those mechanisms did not support a level playing field for draw applicants. However, we also see the positive policy objectives of increasing access to tags by using the a Group system, and recognize that it was a benefit to all applicants that hunters that applied to the draw in groups, and that when hunters in groups were assigned tags, it resulted in the rest of the group being removed from the draw. It is our impression that a lot of hunters do not understand and have not made an effort to understand the benefits of the current system.

We are sympathetic with those that have been unlucky in the current system, or that have been unable to develop cooperative hunting groups to increase their odds. But we believe that rules are rules and the result was going to be that over time some hunters were going to be less lucky than others.

We support the 2020 proposed changes in this current proposal and believe in sustainability.

However, we are vehemently opposed to any changes to the tag allocation system that seeks to retroactively "correct" some perceived wrong or put hunters in a situation where there is an uneven starting point in a new system. As a matter of public policy, this is wrong, regardless of whether this is a hunting related policy or not. Not only is it wrong, it has the potential to create a much larger level of dissatisfaction and polarization within the hunting community, and towards the MNR.

The proposed preference points system, if retroactive, has the potential to eliminate tag opportunities for years for whole groups of hunters that have invested in building relationships to increase their odds of drawing tags, never mind the level of investments in hunting camps and economic benefits to communities where we hunt. Specifically, it is our belief that a retroactive system has the potential to eliminate any chance of drawing tags for older hunters (depending on the demand in WMUs), and will create long wait times for new hunters, which will discourage a significant number of hunters from participating in hunting (particularly in Northern WMUs where there is no deer season).

We are unclear on the policy objectives of a retroactive points preference system. Is the government changing its policy from increasing hunting opportunities and maximizing tag access in order to guarantee the right of every individual to a moose tag if they are willing to pay into a new system and wait long enough (while moving current system detractors to the front of the line)?

Further, we have no analysis from the MNR regarding these proposed changes. Where is the policy research and analysis? Has the MNR been in contact with counterparts in the US that have implemented a preference points system? The government and the MNR needs to be transparent with hunters before implementing this radical a change. Do most hunters realize that that going forward, that they will no chance of drawing tags for years at a time in many WMUs?

Our perception is that there is a cross section of hunters, many who do not share the same policy objectives of hunting in groups and sharing tag opportunities in the past, that have now had their opportunity to voice their displeasure over a short two-month period, and that they are in the minority.
We question whether expediency and politics is becoming a higher priority than sound public policy in resource management. As a result, we are of the opinion that much broader public discussion with hunters and other stakeholders is required on the merits of preference points system, never mind a system that allocates points retroactively.

To conclude, we recognize that there are many recommendations and potential tools in the report issued by the Big Game Management Committee to make positive changes for the benefit of all hunters. But a retroactive preference point system is not one of them. We believe it will be popular in the near-term for a certain cross-section of hunters, but would be extremely damaging to the long-term interests of the Ontario hunting community, and result in a system that would be even more difficult to rectify.