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New Moose Hunting Rules Proposed in Eastern Ontario

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New Moose Hunting Rules Proposed in Eastern Ontario

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New Moose Hunting Rules Proposed in Eastern Ontario

I assume that extending aboriginal hunting rights to Metis is part of their efforts to increase the moose herd too? (note the sarcasm)

Anonymous
New Moose Hunting Rules Proposed in Eastern Ontario

HERE IS THE SUBMISSION I MADE TO THE EVVIRMENTAL BILL OF RIGHTS PROCESS ON THIS SUBJECT.
A long read but lays out the facts.I wish the graphs which really show the picture could be shown here.

The proposal to introduce a calf tag allocation in WMU # 48 is unnecessary. The suggestion that the new proposed changes are needed raises the following questions:

-Why has the same success experienced by the province using the selective harvest tag allocation system not been realized in WMU # 48?
-Was verification analysis done to ensure proper system process procedures adherence under the guidelines of the Ontario Selective Harvest System.
-Was verification done to test the results of cause and effect analysis against the system process procedures?
-What is the scientific justification supporting the need for the change?
-How do these changes meet the provincial programs objectives?
-What are the social, economic and risks effects associated with these changes.
-What is a reasonable rate of growth and time frame to achieve the Target population ( 1000 )

The answers to these questions are lacking in the EBR proposal and the Eastern Ontario Moose Management Round Table Final Report, which contains vague answers to a majority of the questions, which very well could be by design. So below I have attempted to fill in the blanks, which should raise serious concerns: about this unorthodox approach, necessity, present and past management practices.
The research available on moose ecology suggests that the short term and long-term effects of calf tag allocations use could be detrimental to the reproductive potential and biodiversity of the resident moose population. I would suspect that the population structure is already tending towards social imbalances related to sex ratios and age classes differences due to years of excess harvesting of mature moose resulting from a improperly managed selective harvest tag allocation system.
There is evidence that the changes needed for population recovery have already occurred since 2002. For the first time in 20 years since the selective harvest system was implemented in Ontario the WMU # 48 2002 adult tags were allocated in a proactive way directed toward reduced harvest rates of mature reproductive animals (bull/cows), which is known to stimulate population growth.
The 2003 Eastern Ontario Moose Round Table Final Report contains data, which supports this conclusion. The 2002 WMU # 48 population is expected to rise from 564 to 610 by the start of 2004.
The 2003 tag allocations should be expected to achieve similar results tending towards lower future harvest rates. Ministry of Natural Resources; Dr. Euler put together a 2002 Harvest WMU # 48 Trend Graph contained in the 2003 Round Table Report. I suspect this is the same Dr. Euler who developed the modeling process, which lead to Ontario’s present moose management system.
The 2003 Eastern Ontario Moose Round Table Final Report’s graph using the 2002 Harvest Data in WMU # 48 predicts its effect on population growth. NOTE! This same modeling information was used for the new proposed management plan contained in the EBR proposal.??? The modeled 2002 harvest data trend predicts and clearly demonstrates that the present recovery will be equal to or exceed the new proposal and that only minor adjustment under the guidelines of the present Ontario Moose Management Tag Allocation System may be necessary. It would be fair to say that recovery has started to occur since: as a result of using the selective harvest tag allocation system as it was intended.

The present Ontario Management Selective Harvest System has proven itself as detailed in the 2003 Ontario Hunting Regulation on Moose Facts (pages 41 and 42).

The Ontario management system was established to be the best option for population management from the very start and after twenty years since it was introduced the results have validated its’ approach. The system was developed by (Euler 1983) which he showed through modeling that “ a selective harvest strategy based on harvesting a limited number of bulls and cows, while allowing unregulated hunting of calves, provided maximum benefit to hunters and ensured long term population growth. “ “Results of his model of harvest data and population data showed significant differences between modeled and survey population trends showing that locally generated inputs should reflect actual population trends more” (Ecology and Management of the North America Moose 1997).
“If population growth is the objective, harvest rates should be sex and age specific and generally fall less to than 10 to 12 percent. Strategies could include protection of prime breeding animals (especially of cow moose so that calf production is enhanced) direction of hunt pressure towards animals in the herd with the lowest reproductive potential (i.e. young bulls and calves) an reduction of non-hunting losses” (Ecology and Management of the North America Moose 1997).
The population management theory of 10 % to 12% harvest rate limits for a sustainable population is not a new concept as it was identified in a Ministry of Natural Resources 1972 publication by H.G. Cumming, Big Game Biologist “ The Moose in Ontario” “ for the population to remain stable, the same number must be removed. The proportion lost through accident, diseases and predators is not known, but a good estimate would be about 10 percent of the population. Since a minimum estimate of the population is 125,000, (1972) this means that 25,000 moose could be removed without harming the population in any way.”
The answer my lie in a statement made in a Ministry of Natural Resources 1972 publication by H.G. Cumming, Big Game Biologist “ The Moose in Ontario” in the section on “The Future” he states.
“ Some people may find surprising that hunting is not considered the major danger faced by moose in the future” “ There are good methods for measuring the effects of hunting on the moose population, and such uses can be controlled. Therefore, with wise management, hunting presents little danger to the Moose herd.”

As well a statement in the (Ecology and Management of the North America Moose 1997) may also hold a clue to a critical area of population management ignored by the Pembroke MNR since 1992 when determining the tag allocations.
” In the future managers must strive to obtain more reliable estimates of annual losses through wounding, poaching and Native and subsistence take in relation to the size of the moose populations. This information is prerequisite to sound population management in areas where these losses and harvests collectively constitute a major source of moose mortality. Such knowledge will reduce the risk of over allocating the resource in areas subject to both subsistence and non native recreational harvests.”

Review of the proposal reveals a list of 4 reasons, which the Pembroke MNR suggests are the major contributing factors to the population decline.

-Higher mortality rates in calves due to high calf harvest.
-Higher than expected adult moose harvests
-Recent mortality in moose population caused by tick outbreaks
-The overall impact of the moose harvest in and around Algonquin Park

What becomes apparent is that the factors listed may have been confused with:

(What is a Cause?) & (What is an Effect ?).

When the historical data is reviewed and applied against the key management elements and procedures of the Ontario selective harvest system (Annual Adult Tag Allocations) it becomes apparent that something in their logic does not make sense. Note! Harvest Rates are a direct result of Adult Tag Allocations, which are under the absolute control and esponsibility of the Ministry of Natural Resources.

Cause (2)
Higher than expected adult moose harvests

The present system is designed to dampen the effects of harvest rate on population levels. Tag allocations under the system are supposed to be adjusted annually to reflect past harvest rate canceling its negative effect on population levels. However for some unknown reason annual adult tag allocations were issued in excess (48 % of MMP) of the recommend management levels with an allocation as high as (92 %) in 1986. This despite a continued population decline trend in conjunction with high harvest rates from the very beginning (1983): no exceptions.
The average annual harvest rate was (17.8%) up until 2001.
Analysis of the annual WMU # 48 population data shows that there was a midwinter moose population (MMP) in 1986 population of (1500) which then declined to a MMP in 2001 of (650). If the average annual excess harvest rate since 1986 of( 5.8 % )is applied it accurately predicts the resulting 2001 resident population. To state as it does in the EBR proposal document that the adult harvest rate was unexpected suggests that the officials in Pembroke MNR responsible for moose management for the past twenty years and still today have failed to utilize or understand the significance of the available annual harvest rate data and how it is used to determine appropriate annual adult tag allocations
All the data available suggests if the adult tag allocations had been and are issued in the future according to the objectives then the Ontario selective harvest management system is adequate. This approach has the least social, economic and risk associated to it. Requiring no new government economic resources to manage with next to no need for regulation change.

cause 1
Higher mortality rates in calves due to high calf harvest

When the adult moose harvest data is emoved from the 2002 annual harvest data it uggests that an unregulated calf harvest would actually result in an (8.8 %) annual population growth. The provincial average moose population growth is ( 1.1 % )???
The statement contained in the EBR proposal under (1. Calf moose allocation) “experiencing continued high calf harvests that are affecting sustainability” questions the author’s EBR proposal assertion of sustainability

-The (8.8 %) annual population growth clearly demonstrate sustainable and meets the objective of population growth. 8 times the Ontario historical average growth rate.
-The population modeling in the Round Table Report demonstrates that there is approximately an annual (25 %) age class recruitment.

These two facts alone question the validity of the statement.

Sustainability: the ability of the population to maintain itself at a stable level or if the objective is recovery then the ability to grow.
The calf tag allocation approach of the Pembroke MNR fails to consider or mention the risks, which occurs by their unorthodox approach in the first two to three years of the new management plan. If for any reason there is an increased mortality rate during this time such as severe weather, diseases or that which is going to occur related to increase Métis participation in the 2004 moose harvest. This being the result of the recent Supreme Court decision on Métis hunting rights which could very well jeopardize the chances of moose population recovery. Their plan will result in a reduction to the reproductive potential of resident moose population during the first three years by as much as (8 % to 12 %) combined with reduced long term growth potential due to the harvesting of mature adult moose ( cows ) which is the basis of any sound moose management plan.

Cause (3)
Recent mortality in moose population caused by tick outbreaks

The 1998 Tick infestation, which is considered a Cause as the saying goes “was the straw that broke the camel’s back”, highlighting the population decline already in effect. Under normal circumstances a population fluctuation would have occurred with natural correction by a well-managed moose herd with assistance from the tag allocation system. The question here is why did it take the Pembroke MNR (2 years) to react to this widely known situation by quickly initiating an appropriate reduction in adult tag allocations long before 2000.

Cause (4)
The overall impact of the moose harvest in and around Algonquin Park
This cause should raise serious concerns in the Aboriginal community due to what it implies. This is a tactic the Pembroke MNR has used to redirect attentions of myself and those that will be most affected by the change (Licensed Hunters) into believing that the Aboriginal hunt is a huge part of the issue when clearly if the MNR had managed the population properly from the start in 1983 would be a non issue today. A review of the Round Table Report of
Dr. Euler’s Closed Hunting Season Model, which includes the aboriginal harvest, indicates that an annual surplus of 94 animals is realized with an active aboriginal hunt This reflects a 15.5 % annual population growth potential WMU # 48

ACTUAL CAUSES:
Years of EXCESS Adult Tag Allocations

-Excess adult tags = excess adult harvest = population decline-excess tags attracts more hunters
-Population harvest ratio = calf harvest higher percent of actual population as Adult tags reduced
-Population decline = reduced ability to recover from natural mortality factors
-Population decline = Aboriginal harvest has greater impact on population which would be not be an issue at target population
-Annual Adult Tag Allocations responsibility of MNR determined by harvest and population data under their control and analysis. MNR controls flow of data to public consultation process identifying Effects as Causes. Round Table makes decisions on false assumptions. Actual cause gets lost in the process. Round Table members perceive need for a change to the Ontario system when none is necessary; when only a review of management practices are required.

Is a Calf Allocation Tag System required in WMU # 48? Answer: No! ( reasons given in comments)

Are the management measurement tools mentioned in the proposal NEW? Answer: No

Are better measurements needed to manage the population more effectively in WMU # 48?

Answer: Probably NOT !
Especially not when there is clear evidence that the data already available was adequate if it had been applied to the criteria required for determining the annual adult tag allocations, as it was intended to be. The historical records in WMU # 48 indicate that all the management information needed wasn’t used to its full potential. This is not simply a case of hindsight when without exception every year (16 years) the annual harvest rate information indicated a population decline was a strong possibility if allocations were not adjusted appropriately. If the available data was ignored what is there to guarantee that the new information will be treated any differently under an un-proven management plan, especially when it has already set its tag allocation levels 9 years in advance with no identifiable contingency plan.

Should an Archery season be introduced as measure to increase hunting opportunities?

Answer: To introduce a new variable during the early stages of recovery will not only complicate the process but could have serious consequences.

There should be concerns of increased mortality rates resulting from wounding caused by hunter inexperience.
The notion that it will compensate for the reduction in hunting opportunities associated with the introduction of a calf tag allocation system is simply an exaggeration of the facts around hunting group size projections. The reality is that 75 % (1300 to 1500 moose hunters) of those who have participated in past WMU # 48 moose hunts will no longer be eligible. However they will still be expect to purchase an annual license if they wish to remain eligible to qualify annually for the A & B Pool tag selection process.
To introduce a new Archery hunt is irresponsible, especially when it is directed at harvesting the prime-breeding portion of a declining population, which is the foundation of any sound (ecology balanced) population recovery program.

Reminder!!!

“If population growth is the objective, harvest rates should be sex and age specific and generally fall less to than 10 to 12 percent. Strategies could include protection of prime breeding animals (especially of cow moose so that calf production is enhanced) direction of hunt pressure towards animals in the herd with the lowest reproductive potential (i.e. young bulls and calves) an reduction of non-hunting losses” (Ecology and Management of the North America Moose 1997).

Impact Analysis of Ministry of Natural Resources EBR Calf Tag Allocation Proposal:

Pro/ Option 7( 6% HRate )
Calf Tag Allocations WMU# 48
(MNR 2004 Proposal)
a).Serves the interests of those that have a need to harvest an adult moose.

Pro/Unregulated Calf Harvest” WMU # 48
(6.6 % Population Growth Objective) “
using the guidelines of the present Ontario Selective Harvest System
a.)Potential resident moose population increase: ( 6.6 Times the provincial average )
( 6.6 % annual growth rate)
b.)Short Range 3 years / 20 % growth) Can be managed using a reasonable rate of growth within shortest measurable time period. Combined with annual adjustments reflecting real-time population influences.
“Meaningful rates of change occur only when populations increase or decrease significantly” “even with the most precise moose population estimates available, changes of about 20 percent or more are required for detectable changes in rates of increase” (Ecology and Management of the North America Moose 1997). “ Among cow moose older than calves, considerable variation is found in the age at which first reproduction occurs. Most ovulate for the first time at either 16 or 28 months of age. (Ecology and Management of the North America Moose 1997).

c.)(Long Term) Achieve the Target population ( 1000 ) within 9 years. Several years faster then what was an accepted rate of decline based on Pembroke MNR response to the situation.
d.)Controls the harvesting of the mature adult portion of the breeding population.
e.)Could withstand the introduction of bull tag allocations Within the first year (15 Tags / 12 bull harvest rate) From an economic point of view Local Outfitters should receive a majority of these tags in the first two years
f.)Could withstand the introduction of cow tag allocations Within the fourth year
g.) Avoids harvesting adult breeders in the early stages of the recovery period. MNR Quote ” Thereby protecting the reproductive potential of the herd” Hunting Regulations Summary 2003/2003 page ( 41).
h.)As the resident moose population increases closer to target ( 1000 ) then adult tag allocations eventually could be returned back to acceptable levels using the accepted Ontario harvest rates of(10%-12 %).
i.)Demonstrates that both Aboriginal and Licensed moose hunters can co-exist with only minor changes to hunting opportunities for both creating an atmosphere which is conducive to consensus.
j.)Eliminates a negative MNR backlash on licensing fees unfairly charged. With little chance of participation. Option 7 resulting from Item( k.)($ 60,000.00 in excesses license fees)
k.)Eliminates the need to disenfranchise a majority of moose gun hunters who wish to hunt for moose in WMU # 48 as in Option 7 (6% Harvest Rate). (Approx: 1500 hunters)
l.)Eliminates the negative social economic impact on the local economy that Option 7 (6%) could have resulting from (Item k.) (1500 hunters>$598.00 each MNR 95) (Greater than $ 900,000.00 in annual lost revenues) not including taxes revenues.
m.)Eliminates the need and costs to change the present Ontario Adult Moose Tag allocation and Draw Systems. ($$)
n.)Eliminates the need and costs to make major changes to the Ontario Hunting Regulations.
o.)Eliminates the need and costs associated with development, implementation and communicating the proposed changes of Option 7.
p.)Does not disenfranchise a significant population of traditional senior hunters who may never get the opportunity to hunt again in their lifetime due to their age under the restrictions of Option 7 (6 % Harvest Rate).
q.)Does not discourage future hunting opportunities for youth.
r.)Avoids harvesting adult breeders in the early stages of the recovery period. MNR Quote ” Thereby protecting the reproductive potential of the herd” Hunting Regulations Summary 2003/2003 page (41).
s.)Does not affect the $$$ millions of dollars invested in infrastructure and equipment by tax paying hunting camp owners and moose hunters.
t.)Places all present and future moose gun hunters on an equal and fair footing with the choice to participate in WMU# 48. With the choice to hunt elsewhere if an Adult Tag allocation is more important then long-term conservation.
u.)Maintains an increased presence of responsible moose hunting stake holders to enhance the Ontario Moose Watch Program

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