Hi Folks,
Here is something to ponder. This is a draft of the Bowhunters response which they are circulating to their members for comment / review / submission, have shared with me, and allowed me to go public with it. From this, it is pretty easy to see what transpired, and just who was directing the flow...
"To whom it may concern,
Upon reviewing the 2020 hunting regulation change proposals, I am strongly opposed and deeply concerned with the proposal to eliminate a low impact resident bow hunting opportunity as outlined in the South Skeena Bow Only Moose Seasons (2020-06-06) proposal. It is very upsetting, as a resident hunter, that this government is even considering eliminated and "transitioned" a long standing low impact archery season to a LEH season as proposed by the local commercial guide outfitting association. Bowhunting, by its very limitations, is a widely used wildlife management tool that maximizes hunter opportunity while minimizing impacts to wildlife. Bowhunting will always equate to the maximum amount of hunters buying licenses and tags and pursuing wild game with the smallest impact on wildlife populations. I am strongly opposed to this proposal for many reasons, some of which are listed below.
The proposal is in direct conflict with the Provinces "Resident Priority" model:
The moose General Open Season in Skeena South was cut from 7 days to 3 days in 2018 to address a possible over harvest in some MU's - this should realize an immediate ~50% reduction in bull harvest. The impacts of this very dramatic reduction in resident hunter opportunity (and allocation) has not yet been tabulated or realized. Local Guide Outfitter allocations were not reduced in-step through this process!
Although not listed anywhere in this proposal - this reduction to resident hunter opportunity was proposed and submitted by competing interest groups (commercial guide outfitters association and one R&G club), and not government wildlife biologists. This proposal is based on anecdotal information and absolutely no harvest data as it is clear the biologists have no harvest data to support this proposal. Proposal originated from competing commercial pressures with no supporting data and was not discussed during the 2019 Skeena Wildlife Hunter Advisory Committee (SWHAC) regulation change proposal meetings.
The commercial allocation of the Annual Allowable Harvest (AAH) should have been adjusted prior to the significant reduction of the 7 day general open season in 2018 and it is not addressed or justified as a part of this proposal because there is no data to support it.
This proposal is based on anecdotal information and is being pushed as a data acquisition/management problem not a moose harvest or population problem:
It is clear from this proposal that the Biologists have very poor harvest data related to Skeena South Moose harvest and cannot reliably determine when and how moose are harvested. This is an easy and attainable fix and the fact it is a supporting rationale to eliminate a low impact resident hunter opportunity is exceptionally concerning.
To further obvious lack of harvest data, a proposal is also in place with broad stakeholder support that will address this shortfall in detailed harvest data (Skeena South Compulsory Inspection for Moose 2020-06-07). The harvest breakdown (date, method of harvest, unit, effort, etc.) will be clear once this CI program is in place and wildlife managers could make informed decisions in short order, not poor decisions to further reduce resident hunter opportunity. Would it not be preferable to simply wait and have defensible harvest data to support a fair and defensible statutory decision making process before eliminating more resident hunter opportunity?
Within the rationale of this single proposal the following language is used "this assumption", "will likely result in", "has likely lead to", "given the uncertainty", "the conservative approach". This language must call to question the weakness and validity of this proposed reduction of more local resident hunter opportunity. As a BC Resident Hunter this level of uncertainty used as rationale to eliminate my opportunity is simply unacceptable.
Also, within the rationale of this proposal it is clear a perceived increased use of newer more high tech crossbows is being used as a reason for a perceived increase in harvest (all anecdotal information), but within this same regulation change cycle there is also a proposal to limit the technology that can be used on any bow during bow only seasons (Scopes on Bows During Bow Only Seasons 2020-0-05). If limiting the technology that can be used during Bow Only Seasons is a concern and is currently proposed province wide how can that be the bulk of the supporting rationale for this reduction to resident hunter opportunity?
In closing, it is alarming that a proposal such as this has even made it to final review and comments through this process (regulation change process review highly recommended). The simple fact that the complete rationale of concerns for this proposal is also being proposed to be addressed in this very regulation change cycle (lack of detailed harvest data and high tech archery equipment) supports the statutory decision makers quick rejection of this application. Contrary to the closing remarks of this proposal, any open season hunting opportunity is preferred to a restrictive hunter management tool such as LEH. It is disingenuous to state that a transition from an open opportunity (bow only) to a limited one is maintaining this unique opportunity! Government should not be using a lack of management tools/data to justify limiting more resident hunter opportunities, particularly in light of recent, long overdue, budget uplifts within the Wildlife Branch. On the wings of many recent resident hunter opportunity reductions across the province, if approved this proposal will erode public confidence and trust in the government’s ability to effectively and fairly manage British Columbia's amazing natural resources (Objective 1.1 of the 2018/19 - 2020/21 FLNRORD Service Plan).
Sincerely,
Resident (Bow) Hunter"
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I have learned a lot regarding this proposal, and the processes involved in creating them, since I first wrote the provincial government in this regard. As such, I am writing them again very shortly. When I finish that I will post it here for others to formulate ideas from.
Cheers,
Nog
Author
Topic: Letter Suggestions re: BC Hunting Restriction Proposals (Read 1975 times)