Financial penalty for failing to submit a mandatory hunter report

Background

Information provided by hunters through mandatory hunter reporting is important for managing wildlife in Ontario. It specifically helps us monitor wildlife populations, set tag quotas and determine the availability of additional tags, make changes to seasons and bag limits and inform management policies.

All hunters that purchase or are issued a tag to hunt elk, deer, bear, wild turkey and wolf/coyote (in Wildlife Management Units where a tag is required) and any hunter issued a licence to hunt moose must complete a hunter report. Hunters are required to complete a hunter report even if they did not participate in the hunt or harvest an animal. Generally, reports must be submitted within 14 days following the end of the last hunting season for that species.

Ontario’s hunters have been very responsive to the mandatory hunter reporting requirements that were introduced in 2019.  In 2020, the ministry observed an 84% compliance rate across all species.  There were approximately 60,000 non-compliant reports (approximately 16%). Increased hunter reporting compliance leads to improved data and may lead to increased opportunities for hunters in some areas.

Hunters who fail to report or who provide false or misleading information are currently subject to penalties, including fines and possible restrictions on the ability to purchase a licence or tag the following year. 

Experience in Ontario with previous hunter reporting requirements for certain species has shown that hunter reporting compliance rates deteriorate over time if penalties are not applied to demonstrate the importance of this information. It is important to maintain high compliance rates, which results in high quality of data to support management decisions.

Proposal

The ministry is proposing an alternative tool to promote and improve hunter reporting compliance and improve reporting data.

As an intermediate step prior to preventing a hunter from purchasing a licence or tag, the ministry is proposing to charge a mandatory financial penalty for hunters who fail to submit their hunter reports.  The financial penalty:

• would be automatically applied to the hunter once the fish and wildlife licensing system detects the report has not been submitted by the deadline
• would be required to be paid as part of (or prior to) the hunter’s next purchase of the relevant product (generally in the following year)
• would be based on each individual reporting requirement (i.e. if a hunter fails to submit multiple reports, they are charged a fee for each)
• would persist on the hunter’s account until they are paid and would not expire

The financial penalty would be a standard fee, consistent across each individual reporting requirements. The fee would be the same whether the hunter is an Ontario resident or a non-resident. The ministry is seeking input on a proposed penalty in the range of $15-$35 dollars. The ministry recognizes that:

• If the fee is set too high, it may be viewed as more harsh than preventing a hunter from purchasing a licence or tag and may create a financial barrier to participation in certain hunting activities.
• If the fee is set too low, it could be viewed as an alternative to reporting and not provide the necessary incentive for hunters to submit future reports.

The ministry would maintain a graduated penalty approach. If a hunter failed to submit a hunter report in two consecutive years for the same species, they would be prevented from purchasing the relevant draw application, licence or tag the following year.

The ministry recognizes that there may be some legitimate circumstances that prevent a hunter from submitting their hunter report, such as a sudden injury, illness, or an error in the fish and wildlife licensing service. The ministry would maintain a process to consider waiving the penalty in very limited, exceptional circumstances.

The anticipated outcome of the proposal is that compliance rates with hunter reporting requirements will continue to improve and are maintained over time at a high level. This would provide improved reporting information to support wildlife management. Similar to the system preventing a purchase in the following year, the proposal would provide a more efficient method of promoting compliance that reduces burden associated with time consuming and costly investigations or prosecutions (similar to the system lockout penalty that prevents a hunter from purchasing a licence or tag).

Regulatory impact analysis

The anticipated environmental consequences of the proposal are positive.  The proposal is intended to improve hunter reporting data which is used to support sustainable wildlife management. Revenue generated from the proposal would also be directed to the ministry’s fish and wildlife special purpose account which supports the delivery of fish and wildlife management programs.

The anticipated social consequences of the proposal are neutral.

The anticipated economic consequences are neutral. Hunters who fail to report and are charged the financial penalty may view the proposal negatively. Some hunters who hunt certain species more casually (i.e. purchase a licence/tag in the event the opportunity for harvest arises while they are actively hunting other species) may choose not to purchase future licences and pay the fee for those species. However, the ministry’s hunter reporting program is widely supported and the proposal may generate some revenue to support fish and wildlife management programs.

The proposal does not impose new administrative costs to business.