A few weeks ago, I received one of those gems of wisdom that occasionally circulate on the internet. It said, “When you are dead you don’t know it. It’s others who feel the pain. The same thing happens when you are stupid.” I don’t know exactly how that fits into this story, but I thought I’d pass it on. Maybe I’m the stupid one?
MNR announced their decision on how to fix the tag allocation problem. It is exactly what they proposed last October. Like the perfect pregnancy, it took nine months, to the day, to deliver. I expect the time lag was to give the impression that they were seriously considering the comments that people submitted to the Environmental Registry of Ontario (ERO).
Once a proposal is posted on the ERO, there is pressure to accept it, so the proponents don’t look like fools. On that basis alone, they could have made the announcement on Nov. 23, the day after the ERO closed. All that was required was to justify the decision in a way that convinced senior managers and politicians that it was a wise proposal.
I downloaded the comments and read them all, then thought I’d do some analysis of my own.
First, there was a discrepancy in the results. The notice said there were 356 comments, but only 325 made it to my computer. Either way, it doesn’t leave a very positive impression of the integrity of the review process or the capabilities of the folks doing the assessment.
It is difficult to assess a comments-based study objectively. If someone says, “I agree”, it conveys acceptance of every word in the proposal. Counts of words, like “agree” (there are 50, but eight were “don’t agree”) can be used. When people “disagree” (there are eight), they must explain in their own words their reason. Things like “tone” (“this is the best proposal ever” or “this is ok”), “relevance” (“why don’t you do something else?”), and other factors should be considered. With three parts to the proposal, there may be different levels of acceptance for each part, or general acceptance for the whole thing. Most techniques use subjective assessment. Analytical software and mathematical techniques exist but are too sophisticated for me, so I created my own.
I used five categories. One for general agreement/disagreement, one for each of the three parts, one for comments that did not directly address the proposal (alternative options), and one for group applications.
If a respondent said, “I agree” or “disagree”, I interpreted that as applying to all three changes. It was possible to have general agreement but disagree with one or more of the parts. I only counted support or rejection for any part if a specific statement was made about it.
It was obvious that there is a high degree of misunderstanding about the status of moose in Ontario and the allocation process. It is astounding how many respondents still want protection for calves. I guess this is to be expected because MNR has failed over 40 years to convince hunters that calves are the least valuable component of the population to protect. In this regard, hunters are their own worst enemy. It is cows that need protection while calves have high natural mortality.
Most comments relate to “tags” and “opportunities” without recognition that those opportunities must be directly related to the size of the moose population, if they are to be “real” opportunities. This is certainly something that most respondents did not seem to understand.
If it’s only tags that hunters want, that can be satisfied by opening moose seasons in southern Ontario units. Every hunter could be given a bull, cow, and couple of calf tags. I know it doesn't make any sense, but neither does providing more killing opportunities when the moose population is not increasing, when harvest plans already exceed recommended guidelines and when there are far too many tags to control the harvest.
Respondents were not given an opportunity to decide among several clearly presented options. MNR decided how they wanted to fix the problem that they created, then asked people to comment. It would take a very co-ordinated effort to overturn what MNR staff proposed. Frankly, that is an extremely unintelligent way to resolve problems, especially if the proposed solution is worse than the original problem.
One of the justifications for implementing the proposal was that “the change was misunderstood by some hunters.” Sure, blame the respondents and discount their opinions.
A friend owns a large construction company. When he was discussing the poor quality of a job with an employee, the response was, “If I didn’t do it right, it’s because you didn’t explain it right.” He accepted and learned from that reply.
MNR was criticized as early as 1997, in the Simmons Report, for failing to communicate effectively. This is just another example. It can be argued that most of those who agreed misunderstood the proposal because it was not compared to another solution that would meet the needs of both hunters and managers far better. There was a comment from a retired Ontario (moose) biologist who said he didn’t understand the proposal. Finally, I’d like to state in unequivocal terms that, in my view, it is MNR managers who don’t understand. See examples below.
There were responses from organizations representing 800 and 100,000 hunters. While they presented a consensus of their members, it is impossible to partition out the exact number of agreements and disagreements within the organization. One organization did not specifically address the proposal and the other agreed with the responses of most others. I treated them as individuals. Interestingly those making the decision to implement the proposal ignored this large block of opinions entirely.
Here is my assessment. Only 72 out of 325 respondents (22 per cent) agreed in general with the proposal. Sixty (18.5 per cent) disagreed. One of the most important findings is that far more respondents (131 or 40 per cent) did not directly address the proposal at all but offered other solutions. I interpret this as a general rejection of the current allocation system in toto.
Setting a deadline to accept tags and providing a method to get all tags into the hands of hunters is a no-brainer. I use those words intentionally. At least the first should have been a part of the original process. A few people rejected the “last chance” step, citing overharvesting and a decline in the moose population. Putting more tags in the field would not solve that problem.
Several respondents commented that the proposal was not well thought out or explained. Although an early cutoff date was proposed, there is no indication of when it would be. Many people thought it would be the day before the season opened (it does say “prior to the opening …”), leaving no time to organize a hunt. There was no indication of how the “last chance” allocation would be managed. “First-come, first-served”, random draw, points, phone-in, and internet were mentioned. MNR has had four years to think about these things and still doesn’t have an exact plan. Need I say more?
The most astonishing thing is that 79 respondents rejected the idea that hunters should lose their points if they don’t claim a tag. That is almost eight times as many as the 11 respondents who thought it was a good idea. The OFAH and its 100,000 members rejected it. Even if you add the “agree in general” and “think hunters should lose points” (83), there are more people who “disagree in general” and “don’t think hunters should lose points” (139). This proves my point that MNR managers will ensure that their own proposal is implemented regardless of what the public thinks.
This is the most despicable (“deserving of contempt”) and dishonest act I’ve ever witnessed from the MNR. It shows just how low they have sunk professionally. And Mr. Mike Harris Jr., the minister, doesn’t seem to care, although he probably doesn’t know the truth about what his staff are telling him.
It is noteworthy that the rationale for implementing the proposal made special mention that ”some commenters suggested a group application approach would help…”. Only 24 replies mentioned group applications. The explanation for rejecting group applications shows how totally ignorant (i.e. lacking understanding) they are of that tool and its history. That ignorance was clear in this statement from the 2019 review: “The majority of hunters considered group applications to be fair. What is unclear … is why hunters felt it was fair.” (section #8b).
Obviously MNR staff somehow determined it was unfair and just couldn’t understand why others couldn’t see that. Sixty-two percent of hunters applied in groups and 73 per cent supported tag transfers. For this reason, they chose individual applications and the chaos that it created. They never understood, and still don’t, that it was the abused tag transfer policy that was hated, not group applications.
Rejecting group applications during the entire change process from 2019 shows that MNR managers are incapable of reading or understanding anything that they haven’t written themselves. I am quite certain that they read my articles. Having designed and proposed group applications, tag transfers, and written the original tag transfer policy (later changed by MNR with support from the OFAH, from its original intent to one that permitted the extreme abuse), I am in a unique position to correct them, yet again.
I wrote this (with slight modification) in an earlier article.
Group applications, with the original transfer policy, lets a group of hunters apply for one tag to save points for future years. One application. One “distribution process”. All tags awarded, (possibly within two weeks of application closing, June 15?). Everyone knows what’s happening with lots of time to plan and organize the hunt. The administrative system just has to be pulled from the boneyard of MNR computer programs and used again.
The problem with group applications is that, at least under the current situation, there are too many hunters, too few tags, and parties, if all hunters applied as one group, would have to be extremely large to get a tag.
There are two realities. The first is that this condition already exists, but with the current system, the path to developing a plan for the party is fraught with confusion, multiple applications, multiple choices, and lengthy time delays. Many parties don’t know if they can hunt until August.
I will reiterate that group applications have nothing to do with getting a tag in the current year. They have everything to do with maximizing opportunities for the party to get tags in the future. Groups did not receive any advantage over individual applicants. They were treated as individuals within the draw process. In fact, group applications move some tags to lower group sizes, exactly as “chance” would dictate. The same process should apply to points. A tag would go to the highest point holder (if enough points were held) and the rest would get a new point and not be considered any further. No need to decline unwanted tags.
Having read the comments, returning to group applications with a tag transfer policy as originally designed, would meet almost all of the 325 concerns. MNR has obviously misrepresented support for the proposal and ignored the many benefits that group applications offer at the management level. It permits later quota setting which allows inclusion of latest population estimates, winter severity, and estimates of mortality from things like ticks.
The problems with the current allocation process are created by that process itself. If hunters applied in groups they wouldn’t need to decline tags or reapply (now twice).
There are a couple of ways to address how points would be handled in a transfer, depending on points held in the group. In all cases, it would go to the second highest point holder. I would suggest that if the second point holder had enough points, the original tag holder would regain his points and the second would lose his.
If the second did not have enough points, the original tag holder would lose his points. It isn’t perfect but maintains the principle that tags go to those individuals who have waited the longest. The alternative would be that the tag goes to another group with someone having higher points, so the original party doesn’t get to hunt. I’d describe this as a really stupid alternative, and I can do that since I suggested it.
Some respondents suggested the same principle about losing points should apply to all hunters getting a tag. The decision to let successful applicants keep points is because biologists tried to be politicians and gave people something they don’t deserve because it might buy support for a dysfunctional process, even though it is contrary to the intend of what that process is supposed to do.
Regardless of how the allocation is processed, retaining points after getting a tag means that some hunters will get more tags while others wait longer. If people choose to get a tag in a second or third choice step because of a screwed-up allocation process, that’s their choice, and they should “pay the points” for that decision. If the harvest control system actually did control the harvest, there would be no second or third choice tags – period.
There were many reasons cited why parties will put more people into the second step and they rejected losing points. Several commented that if hunters are put in this position, they will accept the tag and hope to kill an extra moose rather than lose points. Of course this will totally defeat the intent of the proposal. MNR failed to consider this or mention it as a problem. As long as they can show all tags are gone, they don’t care were.
The problems with MNR thinking, as I see it, is that they are trying to fix the failed system they created because it exists today. They are not thinking about how to create an effective management system for the future, if, and that is a really BIG if, the population ever increases at all, or if it actually achieves its ecological potential.
There are some comments I found compelling and perhaps of interest to readers. A couple of respondents said that (anti-hunting) doctors wouldn’t give them a medical certificate to justify a tag transfer. It’s not like getting your parents to give you an excuse slip for sleeping in. The intent is to allow transfers only if the tag holder cannot hunt for legitimate reasons. I expect that any doctor who was sufficiently concerned that hunting would be harmful to the health of the hunter, would provide the documentation, anti-hunter or not.
A number of respondents suggested that a party should be allowed to pool their points to get a tag. That is a perfectly manageable option but would not do what they think. Instead of taking 12 points for a tag, it might take 50. Then nobody in the party would be able to hunt for years while members accumulate the next 50 points.
Neither the proposal nor group applications will meet some concerns that had nothing to do with the proposal. There were many suggestions that certain groups (northern residents, old hunters, hunt camps, outfitters) should have special treatment. I have rejected these argument in other articles. A number suggested that Ontario should follow the Quebec system. I haven’t studied that and only reference what the commenters have said. What is happening in Quebec sounds like a very poor way to manage moose. It looks like another program designed to keep hunters happy while ignoring successful moose management practices. It’s a new version of old passive techniques that never worked because they do not provide direct and predictable control on the harvest.
The International Moose Symposium did a review of the status of moose around the world. I was exposed to so much information that my brain is still a blur. I think I recall a slide showing the moose population density in Quebec was the lowest of all reporting areas. Ontario was second last. I requested a copy of that slide, but it cannot be released before the report is published. Great choice picking Quebec as our role model. I don’t think Ontario needs to do much to replace them at the bottom, but it looks like they are trying their best to do so.
I know that I can be sarcastic and critical. I’m trying to be a better person and made a pledge that I wouldn’t disparage MNR managers with words like “incompetent” or “deceitful”. I’ve been pretty good - but you know what I’m thinking …
The proposed changes won’t go into effect until the 2027 season. If you don’t like being duped and want your opinion to be heard, go to the top. Make your feelings known to the minister, Graydon Smith ([email protected] or [email protected]), your MPP, or both.
Alan Bisset is a retired regional moose biologist and wildlife inventory program leader with the former Ministry of Natural Resources. He has written and published many papers on moose management, both Internally and in scientific journals. Bisset lives in Strathroy, west of London, Ontario. You can find his other submissions by typing “Alan Bisset” into the search bar at Sudbury.com.