Jesse Zeman, Executive Director
B.C. Wildlife Federation
101 – 9706 188th Street
Surrey, B.C., V4M 3N2
The Honourable Katrine Conroy
Minister of Forests
P.O. Box 9049, Stn Prov Govt
Victoria B.C., V8W 9E2
June 10th, 2022
Minister Katrine Conroy,
The B.C. Wildlife Federation (BCWF) writes this letter to address the improper decision-making by the Province in relation to resident and guide outfitter bighorn sheep and goat hunting opportunities in Wildlife Management Region 4.
The BCWF is disillusioned by the mismanagement of wildlife generally, and bighorn sheep and goats particularly, in Region 4, and by the significant and unwarranted reduction in resident hunter opportunity for bighorn sheep and goats in Region 4. For decades, we have witnessed significant declines in wildlife populations, a lack of a coherent management plan, and a failure by Region 4 Ministry staff to apply Provincial policies. Recently, the Minister has made a decision to move bighorn sheep hunting from a General Open Season (GOS) to Limited Entry Hunting (LEH) status. The Ministry has also made a decision to artificially limit the number of goat LEH authorizations.
For the reasons set out in this letter, the BCWF requests that the Province immediately (1) revise its decision so that bighorn sheep hunting is under a GOS rather than LEH and appoint an independent panel to review sheep regulations and (2) increase the number of goat LEH authorizations. The BCWF also requests that the Minister implement an independent review of wildlife management in Region 4 staff’s compliance with Provincial policy and the propriety of their decision making.
A. The Replacement of the GOS Season with LEH is not Warranted by Conservation Concerns
The Province has provided COVID-19 relief to guide outfitters so that they are able to harvest additional numbers of bighorn sheep, which the Province justifies with the assertion that there are no conservation concerns with bighorn sheep. We refer to the “Final Quota COVID Requests & Recommendations –Region 4_Mar31” spreadsheet prepared by the Province. That spreadsheet sets out the basis for COVID-19 relief for guide outfitters and notes in the rationale for relief that “extra diligence required to ensure there is biological support to do so and no concerns with potential overharvest.”
The BCWF was led to believe that COVID-19 relief would apply predominantly to R selected species (moose and elk), with a few exceptions for K selected species (sheep and goats).
In fact, while the BCWF was under the impression there were only supposed to be a few exceptions for K selected species, government spreadsheets reveal 20 exceptions for goats for guide outfitters from a total of 31, and 6 exceptions for sheep from a total of 19.
The Provincial administrative guideline policy is a 30 per cent exception rate to allow for flexibility. Practically, this means guide-outfitters can harvest 50 per cent more than their annual allocation in any one year. For example, if a guide-outfitters five-year allocation is 10 sheep, they would have an annual allocation of two sheep. With administrative guidelines of 30 per cent they would be able to harvest three sheep in any one year. The spreadsheets reveal COVID-19 relief that results in 50 per cent administrative guidelines, allowing a harvest two and a half times more than the annual allocation.
The rational provided by regional staff for 50 per cent administrative guidelines in the spreadsheet indicates “no conservation concern. Full curl restriction in place,” on all regional comments regarding sheep populations. The guidance and these exceptions occurred concurrently with the ministry telling the public there is a conservation concern for sheep in Region 4, that sheep hunting must move from GOS to LEH and that the harvest rate must be reduced. To be clear: Government has been telling the public the harvest rate is too high, while its own spreadsheets say “no conservation concern, full curl restriction in place” when it is rationalizing increasing the guide-outfitter harvest to 250 per cent more than the annual allocation.
Even today it appears Region 4 is using 44 per cent administrative guidelines for sheep, which is nearly 1.5 times more than the provincial policy of 30 per cent. This allows guide-outfitters to harvest nearly two and a half times their annual allocation. Again, the ministry has told the public that sheep must move from a General Open Season (GOS) to Limited Entry Hunting (LEH) due to conservation concerns, while allowing significant deviation from provincial policy to benefit guide-outfitters.
We also refer you to the research by Dr. Marco Festa-Bianchet, one of the world’s leading research scientists in the area of bighorn sheep ecology. Dr. Festa-Bianchet analyzed data from hunter harvest in the Kootenay region, and preliminary analysis suggests that hunting regulations are not having a negative impact on sheep horn growth. Dr. Festa-Bianchet also did not indicate a concern with the then current management regime being used in the Kootenay region. This tends to suggest the factors limiting bighorn sheep are not related to hunting.
B. Replacing the GOS with LEH was motivated by an improper purpose
The BCWF asserts that the Province has amended the bighorn sheep regulations in the absence of the appropriate expertise to give the appearance to the public that it is ‘doing something’ to restore sheep populations by changing the hunting regulations. This is supported by the lack of experts working for the Ministry and the above issue where Ministry staff state, “no conservation concern. Full curl season in effect”, while simultaneously telling the public there is a conservation concern, and finally, changing the hunting regulations. The logic of the Province is that (a) residents must harvest fewer animals because there are conservation concerns and (b) guides may harvest more animals because there are no conservation concerns and residents are harvesting fewer animals.
This is an improper purpose, and is wholly unreasonable, because it violates the Province’s own policies with respect to conservation and stated order of priority and allocation of hunting opportunities between guide outfitters and residents.
C. The Improper Purpose and Unreasonableness of the Province’s Decision is Demonstrated in Several Ways
The Province’s decisions with respect to bighorn sheep hunting are internally inconsistent, do not comply with the Province’s own policies, purport to be based on conservation when they are clearly based on favouring guide-outfitters over residents and do not follow the conservation science. There are several clear illustrations of this.
Mt. Assiniboine- Provincial Policy and Utilization
The first is the Province’s decision with respect to the Mt. Assiniboine sheep population. Unlike most herds in Region 4, according to the Province’s maps, Mt. Assiniboine is an isolated sheep population. The Ministry’s “Kootenay Bighorn Sheep Management Plan” states “Sheep were more wide-spread in the late 1960s including in the Mt. Wardle area within Kootenay National Park and along the Cross River and off the Mitchell River, but current numbers and distribution are well reduced or absent.” Adjacent sheep populations such as the Cross River herd have been gone for over a decade with no attempt to restore or conserve them. The current population estimate for Mt. Assiniboine is 45 sheep, well below the 75 minimum required for a hunt as set out in provincial policy. It appears these sheep declined between 2012-14, but no inventory was conducted until 2019. Per provincial policy this hunt should have been closed years ago, yet Region 4 staff have refused to follow provincial policy, while again stating there is a conservation concern in all of the other populations which are either contiguous or have population estimates above 75.
Utilization for this hunt by resident hunters has been extremely low for decades. During the 2007 allocation review it was disclosed that regional staff had actually allocated this hunt 50 per cent resident and 50 per cent non-resident. Historically, resident hunters would harvest one sheep every two to four years, while the outfitter would be allocated two per year and harvested 1.2 per year on average. Since then, the sheep population has declined and resident hunters harvest fewer than one sheep every ~5 years and the guide-outfitter is struggling as well. Between 1997 and 2017 the long-term realized allocation is approximately 25 per cent resident hunters, 75 per cent non-resident hunters because the Ministry refused to release enough LEHs to resident hunters to harvest sheep. Again, the province has stated we must move to LEH across the region due to issues related to conservation, meanwhile it continues to allow a hunt, which according to provincial policy should have been closed years ago. Ironically, this hunt has been managed to ensure resident hunters do not participate or harvest sheep. This is not a low demand hunt; in 2021, the odds for this hunt were 59:1.
Inappropriate Use of Success Rates
The government LEH goat spreadsheets show resident hunters harvested only 36 per cent, 47 per cent, 62 per cent and 69 per cent of their allocation respectively for 2017-20. This result is a function of the Ministry limiting the number of LEH authorizations. In the “Final Quota COVID Requests & Recommendations – Region 4_Mar 31” spreadsheet we see Region 4 staff recommending 50 per cent admin guidelines for all guide-outfitters, citing that neither group is using their AAH and that “residents only using 25 per cent of allocation.” When we review the “Goat LEH finalwithextras” spreadsheet we find that resident hunter goat utilization from 2017-20 is 0-48 per cent in MU 422 (45 per cent 422A; 10 per cent 422B; 31 per cent 422C; 48 per cent 422D; 32 per cent 422E; 10 per cent 422F; 0 per cent 422G). In 2021, Region staff increased the minimum success rate to 20 per cent from 10 per cent, which artificially reduces the maximum number of LEHs by half. The rationale to reduce the maximum number of LEHs by half is “due to access from forest fires” in areas where resident hunters are harvesting 0-48 percent of their allocation. This approach is incoherent. Region 4 staff are intentionally reducing the number of LEH authorizations when utilization is extremely low or non-existent while providing 50 per cent administrative guidelines to guide-outfitters citing low resident hunter utilization. This vicious circle has been observed for decades in the Kootenay Region.
We anticipate the same approach with sheep going forward. Government data indicates that only eight of 18 sheep (fewer than 50 per cent) allocated to resident hunters were harvested between 2017-20. The reason for this under-harvest is because the region has used a success factor of 25 per cent (assumes one in four LEH authorizations will harvest a sheep) for decades and continues to do this rather than adjusting the LEHs to allow resident hunters to hunt and harvest sheep. The Province is manipulating the policy tools, such as success factors, to reduce opportunities to resident hunters. There is no data-driven or scientific basis for these decisions.
The 2022 LEH spreadsheet shows ministry staff are using success rates of 25-72 per cent for bighorn sheep LEH in Region 4. The majority of the hunts in the spreadsheet use 25-40 per cent success rates. The success rate during the GOS is less than 10 per cent, which means the Ministry assumes resident hunters will be two-and-a-half to four times more successful simply by moving from GOS to LEH. Okanagan region sheep hunts are all any-ram LEH (all rams are open to harvest) with much easier access and the success rates average 40 per cent, varying between 30-100 per cent depending on sheep population proximity to access points. The areas in the Okanagan are far more accessible than sheep populations in the Kootenay and do not have a horn curl restriction. Please keep in mind these hunts have extremely high demand, with odds ranging from 40-320:1.
Between 2017-21 Region 4 staff issued 10 LEH authorizations in Mt. Assiniboine which resulted in one sheep being harvested, a 10% success rate. For 2022, Region 4 is using a success rate of 30% to artificially limit the number of LEHs. The long-term success rate in Mt. Assiniboine has never been 30%. The region staff are using success rates that are far too low given the access in the Kootenay region and horn curl restrictions. The outcome of this approach is an intentional under-utilization of sheep by resident hunters, while the region uses 44 per cent administrative guidelines for guide-outfitters.
Impacts of LEH
The disproportionate affect of the Province’s decision with respect to bighorn sheep on residents and guide outfitters is telling. Based on the Ministry’s spreadsheet, the impact from moving GOS to LEH with 60 per cent of the harvest allocated to resident hunters and 40 per cent of the harvest allocated to non-resident hunters will eliminate the number of resident hunters by ~70 per cent from 350 hunters to ~100 (tag purchase is typically less than 90 per cent). The odds for these hunts will be extremely high; it is unlikely most of those who used to hunt annually will ever receive an LEH draw.
Based on the three-year pre-covid harvest, there will be six guide-outfitters impacted by 0.33-1.33 sheep over the five-year 2022-26 allocation period. Hunt prices will increase due to the reduced harvest rate, and lack of resident hunter ‘competition’ on the landscape, which will offset the financial impacts of reducing the harvest rate. Overall, the new 2022-26 five-year guide-outfitter allocation is 41 sheep, the harvest will be fewer than 30. Resident hunters will be disproportionately impacted by this regulation change and allocation.
Overall, there is a consistent pattern in Region 4 that is highly concerning. Provincial policy appears to be ignored in Mt Assiniboine, an area where it very clearly should be closed, while we have regional management plans dictating sweeping changes that do not appear to be supported by science. Ministry spreadsheets reveal “no conservation concern. Full curl season” in rationale to increase guide-outfitters annual harvest by 250 per cent while the ministry is telling the public there is a conservation concernthe harvest rate must be reduced and resident hunters must move to LEH.
Resident hunters are suffering the overwhelming proportion of the impact while commercial interests are not. These are long-standing issues in the Kootenay region, particularly with goats and sheep where we have observed inflated population estimates, allocation issues, and improper use of the allocation policy to benefit private interests while ensuring resident hunters do not achieve their allocation. It has been flagged dozens of times and has never been dealt with. It has resulted in a loss of confidence by the BCWF in Region 4 staff.
Accordingly, the BCWF requests that the Minister:
- Reconsider the decision to move bighorn sheep from a GOS to LEH in Region 4. In the interim, appoint an independent panel of experts to review this decision.
- Increase the number of LEH authorizations for goat and sheep in Region 4 to be consistent with Provincial policy by applying accurate utilization and success rate factors.
- Implement an independent review of sheep and goat management in Region 4.
President, B.C. Wildlife Federation
President, East Kootenay Wildlife Association (Rg 4E)
Rick Manwaring, Deputy Minister
Logan Wenham, Interim Director of Fish and Wildlife