RHABC's Allocation Policy Views - 2007/05/21

This is RHABC, East Kootenay Chapter’s comments on the following Allocation Policies.
Harvest Allocation (4-7-01.03) (P. 1 & 2)
- Unclear
- No conservation goals
- Based on kill goals
- No adequate inventory of wildlife populations
- No hardship strategy for wildlife which will lead to population decline
- Non-scientific
Harvest Allocation (4-7-01.03.1) (P. 1-7)
- Deliberately unclear
- Formula is non-scientific, mathematically unsound and is a push for commercialization
Quota (4-7-01.05.1) (1-3)
- No exit strategy for decline in population
- Resident hunter allocation will have their quota reduced if disaster hits a population. Guides will maintain their quota as it is part of their contract
- Quota can only be reduced by 20% each 5 year period
- Use of ambiguous words such as “should” makes the policies unworkable and unaccountable on the ministry
- Policies (1.3) and (1.5b) appear to be discriminatory and illegal
Administrative Guidelines (4-7-01.05.2) (P. 1 & 2)
· Totally lacking in wildlife conservation
· Actually promotes maximum harvest of category A species
· Wide open for abuse
· LEH species are where populations are species of management concern
Resident Hunter Priority (4-7-01.10) (P. 1 & 2)
- Historically allocations have been 90% resident and 10% non-resident split
- Resident Hunter numbers 85,000 or 93%
- Non-resident hunter numbers 6,000 or 7%
- The 70-30 or 60-40 splits do not reflect resident hunter demand
- LEH permits everyone should be required to apply for the draw
Commercial Hunter Interests (4-7-01.11) (P. 1 & 2)
- What is the need for the mandatory guide outfitter requirement?
- Uncertified area can now be made into a guide territory so resident hunters will have no areas to hunt guide free, unless it is too non-productive for a new territory
Allocation of Previously Opened Hunts (4-7-01.12) (P. 1 & 2)
- Supporting commercialization of hunting
- Resident will loose hunts when new territories are implemented
Under-Harvest of Allocated Share (4-7-01.13) (P. 1 &2)
- Contradicts the sound principles of conservation
- Resident hunters will be penalized for any reason ie. Weather, road closure etc.
- Example of LEH authorization process
AAH requires harvest of 100 elk by residents
25% historical success ratio of permits to actual harvest
Therefore, 400 permits are needed for maximum harvest
If only 75 elk were harvested then the guide gets 25 permits
- Forces hunter to kill legal immature animals
- Demands maximization of the harvest
- Forces hunters to become killers rather than conservation minded sportspersons
Harvest Allocation – Implementation Plan
- Double standard – discriminatory
- Uses ambiguous words such as “should”
- No conservation
- Section 5 still allows for the Regional Manager to give 50% of species to the guides at their whim. Where is 60/40 or 70/30?
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