Open letter to Honourable Steve Thomson, Minister BC Ministry of Forest Lands Natural Resource Operations:
Re: Multiple 70(1) b Permits – Regions 4, 5, & 8
The BC Wildlife Federation recently became aware of multiple 70(1) b permits issued in Regions 4 [Kootenay], 5 [Cariboo], and 8 [Okanagan]. These permits enable guide-outfitters to operate, hunt, and harvest [wild game animals] in resident-only areas.
Resident-only areas have been set aside to allow residents to enjoy spatial hunting areas without interference, competition, or over-harvest from guide-outfitters. While these permits are issued annually, our member regions have never been consulted or notified that guide-outfitters have been enabled to hunt in resident-only areas.
The original intent of these permits was that they could be issued if management objectives had not been achieved through liberalization or changes to resident harvest. In all these cases, there has been no attempt by staff to encourage resident harvest or consult on the issuance of these permits.
In Region 4, 16 different permits were issued for black bear, cougar, wolf and bobcat. The rational for permits are:
70 (1) (b) permits have been issued for predators only, always for one year only. Resident and GO groups have generally indicated that we should target harvest of predator populations in this Region. These permits support that.
In addition, we have tried to limit issuance of permitting to areas: 1) where there is low resident hunter use, 2) where there is a low (estimated) likelihood of resident / GO conflict and 3) Mountain Caribou recovery areas (reducing predator populations to support caribou recovery).
None of the species identified fall under the allocation policy as they are not Category A
The permits were:
Predator hunting permits issued in 2012-13
YEAR MANAGEMENT UNITS SPECIES COMMENT
2012-13 Sw Portion 4-22 Cougar, Wolf, Bobcat
2012-13 Mu 4-14 Black Bear Low Resident Demand
2012-13 Mu’s 4-08, 4-15, 4-18, 4-30 Cougar Caribou Recovery
2012-13 MU’s 4-15, 4-16, 4-17,4-30, 4-31, N Portion 4-32 Wolf, Cougar Caribou Recovery
2013-14 Sw Portion 4-22 Cougar, Wolf, Bobcat
2013-14 Sw Portion 4-22 Black Bear Low Resident Demand
2013-14 Mu 4-14 Black Bear Low Resident Demand
2013-14 Mu’s 4-08, 4-15, 4-18, 4-30 Cougar Caribou Recovery
2013-14 MU’s 4-15, 4-16, 4-17,4-30, 4-31, N Portion 4-32 Wolf, Cougar Caribou Recovery
2013-14 Mu’s 4-03. 4-04 Black Bear Low Resident Demand
Region 4 contains more than one-third of all the cougar hunters in the province. Most of these permits fail even regional guidelines for permits. The Cranbrook area has the highest density of resident cougar hunters in the province, despite the first two tests that there is low resident hunter use and there is low likelihood of conflict. Resident hunter use and conflict are both extremely high in this area. Secondly, many of the MUs where these permits have been issued do not have caribou in them. Bobcat are not considered a limiting factor in terms of ungulate populations and the impact of guide-outfitter harvest of black bears on ungulate populations is statistically insignificant. The issuance of a bobcat tag through a 70(1)b is a handout. Staff have not attempted to increase resident opportunity or harvest for any of these species or populations.
In the West Kootenay, BC Wildlife Federation member clubs have requested an increased bag limit for cougar to limit caribou and mule deer predation for over a decade. Government has consistently denied this request citing conservation related concerns, yet permits have been issued for cougar across most of the caribou recovery areas. Government has limited resident harvest and opportunity, yet given guide-outfitters tags in resident-only areas. Also, MUs 4-15 and 4-18 are high resident use area for cougar hunters.
If government wanted to increase harvest for black bears, cougar, or bobcat, in these areas bag limits, season lengths, license fees could have been reduced as has been done in Washington State but none of these were changed even when requested. Government never tried to increase resident use for these species in these areas. Often government indicated it wasn’t feasible to increase harvest in these areas.
These permits have been issued for the benefit of guide-outfitters, not wildlife, resident hunters or management outcomes.
Following is a summary of permits issued in Region 5:
• 8 permits were issued under Section 70(1)(b) of the Wildlife Act in the Cariboo Region during the 2013/14 fiscal year.
• A ninth permit issued during 2012/13 expired on June 30, 2013.
• 7 of the active permits were issued over Crown land while 1 was issued for private land parcels.
• This form of permit was issued only for specified areas of land situated in 5 Management Unit Sub-Zones.
• The permits were issued for terms ranging from 4 to 11 months. All 8 active permits expired on March 31, 2014.
• Species for which guided hunting was authorised are (varies by permit) –
– On Crown land: black bear, cougar, lynx, bobcat, wolf, coyote. No ungulates, sheep, goats or species on LEH were included in these permits on Crown land.
– On private land (where the private land holder permits only certain persons to hunt): black bear, cougar, mule deer. No species on LEH were included in these permits. Mule deer were included as the land holders were seeking closely controlled hunting effort to influence mule deer causing impact to agriculture crops.
• Permits of this nature were issued consistent with applicable policy and procedure, and after considering advice from government legal counsellors.
First, there has been a significant lack of conservation ethic associated with these tags from residents and other outfitters in region. According to Region 5 staff, there are now management concerns due to high non-resident harvest in resident-only areas. Resident hunters are being impacted in resident-only areas by non-residents through statutory decision maker’s ability to effectively manage the resource.
In 2010, Region 5 staff reduced the mule deer opportunity and bag limit for resident hunters citing low sex ratios. Estimated sex ratios were derived from composition counts which are not supported by current methodologies; ironically no counts have been conducted since. Region 5 indicates mule deer tags were given to a guide-outfitter because mule deer were causing impact to agriculture crops but that these were not LEH species, meaning they were for mule deer bucks. Population management, influence, and disturbance, comes from managing female harvest. Landowners have the ability to manage hunting efforts through allowing access to select individuals or other tools which have been used through agricultural hunts which occur in the Peace. This was not a management hunt; it was clearly a one-off trophy hunt in a resident-only area where residents have had opportunity and harvest reduced significantly. This approach is entirely consistent with full privatization of the resource, something the BC Wildlife Federation has been extremely concerned with.
In summary, there are a few issues that arise through the methods and effects of 70 (1) b permits:
1. 70 (1) b permits have not been used in a manner consistent with the intent.
2. Resident only areas have been marginalized to the point where management objectives have been compromised by guide outfitter related harvest.
3. Statutory decision makers do not possess the integrity or accountability to properly implement, apply, or consult on policy.
This is not the first time statutory decision makers have ignored, improperly interpreted policy, or acted as autonomous agents. As 70 (1) b permits have been applied in a manner which is not consistent with their intent, the BC Wildlife Federation suggests the following criteria:
1. That 70 (1) b permits be applied only when changes in resident hunter opportunity are not sufficient to achieve management outcomes.
2. This includes reduced or free species licenses, increased bag limits, lengthening of seasons, and removal of access restrictions.
3. Resident hunters are consulted by managers and spatial and temporal restrictions are applied.
4. Resident hunters are compensated for the use of resident-only areas through a fund which is used for ecosystem restoration in resident-only areas.
The BC Wildlife Federation expects government and its agents to act in a manner which is transparent and consistent with policy. Compromising wildlife values and resident-only areas is not consistent with sustainability or resident hunters’ priority access to the resource.
The BC Wildlife Federation is extremely disappointed in the marginalization of public access to the resource.
Yours in conservation,
Wilf Pfleiderer, chairman
BCWF Wildlife & Allocations Committee
BC Wildlife Federation