Contact the Premier's Office & your MLA!
We’re asking all interested British Columbians to act now by contacting the Premier’s office and their MLA to state their opposition to the proposed changes to hunting regulations in the Peace Region. Click below to find the contact information for your MLA and to download our prepared script if you would like help with your message.
BC trades away outdoor recreation rights to continue industrial encroachment in the Peace region
Please watch this important message from Jesse Zeman on a development that affects all resident hunters in British Columbia. Our press release follows, and there is information below that on how you can take action.
Letter to Minister Katrine Conroy
March 24, 2022
File No.: 304470.00004/19647
The Honourable Katrine Conroy
Minister of Forests
Dear Minister Conroy:
Re: Region 7 Moose and Caribou Hunt Regulatory Proposals
I write on behalf of the British Columbia Wildlife Federation (“BCWF”) with respect to the Province’s anticipated decision regarding hunting in northeast British Columbia.
As you know, the BCWF represents over 43,000 members. Our organization’s members are committed to conservation, sustainable outdoor recreation, and intra-provincial tourism.
Our members are deeply concerned with the proposed changes to moose and caribou management in Wildlife Management Region 7B for resident British Columbian hunters.
In summary, the BCWF strongly opposes the proposed changes because:
- They ignore a science-based approach to wildlife management, including considering the specific circumstances of each Wildlife Management Unit (“WMU”), which should be paramount.
- They disregard the importance of moose and caribou hunting to resident British Columbians.
- Though we support the protection of treaty rights, the Province has not demonstrated why such drastic and sweeping changes are required to achieve that outcome.
For the reasons set out in this letter, the BCWF urges the Province to:
- Defer its decision in order to create a forum for the Province, First Nations, the BCWF, and other stakeholders to seek alternate solutions to protect treaty rights that would have a smaller impact on resident British Columbian hunters.
- Implement focussed policy and management tools that will improve habitat and conservation, foster reconciliation, meet the Province’s obligations to Treaty 8 members, and allow for meaningful resident hunting opportunities where harvests are sustainable.
It is our understanding that the Province is considering curtailing harvesting by British Columbians of moose and caribou populations in Region 7B including by:
- Reducing the number of resident British Columbian moose hunters by 50% and reducing moose harvest by 50% in Region 7B, which includes removing all general open season authorizations for moose.
- Eliminating all opportunities for resident British Columbian hunters to harvest moose in two areas (the Peace Moberly Tract and Moose Lake).
- Eliminating any opportunities across Region 7B for resident hunters to harvest caribou (the “Proposed Amendments”).
The Proposed Amendments are an unreasonable departure from science-based management and will deprive British Columbians of existing rights to hunt. If implemented, they will unreasonably eliminate moose and caribou hunting opportunities for resident hunters, contrary to both science-based management and express provincial policy.
Moose hunting is of utmost importance to resident hunters for food, as well as recreational, health, and social values, and outdoors and wilderness experiences. The Proposed Amendments, if implemented, will further decimate hunting-related tourism and hospitality industries throughout the northeast, which have already been impacted by the COVID-19 pandemic.
We assume the province’s planned regulation changes to Limited Entry Hunting for moose will be an any bull hunt, which will have a disproportionate effect on the number of hunters and hunting days. The Proposed Amendments in Region 7B could result in significant annual impacts to resident British Columbian hunters, including:
- A reduction in the moose harvest from 1154 to 571.
- A reduction in the number of moose hunters by 75% from 5701 to 1425.
- A reduction in the number of moose hunting days by 80% from 54,008 to 10,801.
- The loss of the equivalent of 3,334 British Columbians’ annual supply of red meat from moose meat.
- A reduction in economic expenditures for moose hunting by 80% from $17.9M to $3.6M.
- A reduction in economic expenditures for caribou hunting by 100% ($470,000).
The BCWF supports protection of First Nations’ Treaty 8 rights. The BCWF and its members are committed to supporting and advancing reconciliation efforts generally, and in relation to hunting activities. The BCWF supports measured efforts to prioritize First Nations’ hunting access for that purpose, while still respecting a science-based management approach, and the ability for British Columbia residents to share in these experiences alongside First Nations hunters.
As a result, we request that the Proposed Amendments be reconsidered in light of the significant impact that they will have on resident British Columbian hunters, reconciliation efforts, and the affected wildlife populations. There are ways to ensure Treaty 8 rights are respected and a science-based approach is continued without imposing profound consequences on resident British Columbian hunters.
Moose hunting grants important benefits to resident British Columbian hunters
The benefits of maintaining opportunities for resident British Columbian hunters to hunt moose cannot be overstated. Moose are the most sought after species of big game in British Columbia. Resident hunters from all parts of the province are motivated by the opportunity to access outdoors, spend time in the wilderness alongside friends and family, and to harvest sustainable, healthy, ethical meat for their families. The BCWF predicts that the Proposed Amendments will result in a reduction in the overall number of resident hunters who hunt moose in Region 7B by 75%.
For the majority of British Columbian hunters, the opportunity to legally harvest game is central to their identity and health, in a way that surpasses mere recreation. Many hunters have hunted moose their entire lives and have grown up eating moose that they have harvested with family members.
BCWF members value the opportunity to continue this important tradition with their children. The number of moose harvested by resident hunters in British Columbia has already been reduced by 66% over 40 years. A 50% reduction in the opportunities available in Region 7B would further erode the ability of these residents to continue this important way of life. Overall, the BCWF predicts that the Proposed Amendments will reduce the number of days resident hunters spend moose hunting and enjoying nature in Region 7B by 80%. Such an outcome would also detract from – rather than promote – the goals of Truth and Reconciliation and mutual
Wildlife management decisions should be based in science and respect local conditions
To be reasonable, any decision with respect to hunting regulations on the basis of wildlife populations must also be evidence-based and scientifically sound. The Province must consider and rely on scientific evidence of the status of wildlife populations in each WMU within Region 7B to make sound decisions and set best practices for each WMU.
In 2020, the Ministry’s Together for Wildlife strategy promised to implement evidence-based decisions that are supported by research and monitoring.1 The Province’s science-based approach has been guided by wildlife inventory in accordance with the Provincial Framework for Moose Management in B.C., which sets out certain harvest policies.2 Any departure from this approach would be unreasonable and inappropriate.
Nevertheless, instead of conducting such a site-specific analysis, the Province is proposing sweeping and unscientific reductions across all of Region 7B. The Province admits there is no scientific basis for the reductions to licenced hunting being imposed on such a broad scale and across such a vast region, nor any science-based plan. The Province has not demonstrated that wildlife populations in each WMU in Region 7B cannot sustain resident hunting after taking into account Indigenous hunting rights. The rationale for the proposed plan provides no evidence that there will be a benefit to moose populations.
Considering each WMU individually is important because there are differences between WMUs within Region 7B, including the level of industrial development, ability to access the area, and population status for moose and caribou. A significant portion of Region 7B has extremely limited access (float plane or horseback only). The difference in level of industrial development, use, and access of these areas should be considered differently than in highly accessible areas.
The Proposed Amendments have not considered the diversity within Region 7B that ranges from areas of high anthropogenic change to areas of intact wilderness.
Additionally, decisions such as this should expressly identify and rely on population and sustainable harvest science. To make such sweeping amendments, the Province should show why the populations in each WMU require the Proposed Amendments.
According to 2021 data on estimated moose populations and moose survey summaries, 23 of 27 Wildlife Management Units in Region 7B are near or above the post-hunt moose harvest objective ratio of 30 bulls:100 cows. And 19 of 27 MUs exceed 40 bulls:100 cows in the region.
A number of WMUs in the region, including those in the Muskwa-Kechika Management Area, which is over 17,000 km2, have an extremely low road density, are very difficult to access and have high bull-to-cow ratios. Most of the MUs can sustain more harvest than the current hunting season and regulations allow.
Applying a blanket policy across the entire Region does not take into account the differences between the various WMUs, the relative health of populations of moose and caribou in each WMU, or the Province’s own data with respect to the state of wildlife.
1 Ministry of Forests, Lands, Natural Resource Operations and Rural Development, Government of BC (August 2020, online), Our Principles, Action 9, Action 16 : together-for-wildlife-strategy.pdf (gov.bc.ca)
2 Provincial Framework for Moose Management in British Columbia, Government of British Columbia (February 2015, online): Provincial Framework for Moose Management in British Columbia (gov.bc.ca)
Similarly, the complete closure of two areas (the Peace River Tract and Moose Lake) to licenced hunters is unprecedented. To completely close an area to licensed hunters, the Province should demonstrate why those areas cannot sustain resident hunting.
Caribou populations and the impact of reducing the moose harvest
BCWF is aware that the southern portion of the Peace-Liard Wildlife Management Region has a number of endangered mountain caribou populations.3 However, the total population of hunted caribou in Region 7B, is approximately 2,651 (1,100 Rabbitt, 450 Frog/Gataga, 500 Muskwa, 450 Pink Mountain, 151 Liard, not including Horseranch which is shared with Region 6) in areas that are remote with very limited access and minimal hunting pressure. The number of animals annually harvested by resident hunters (17) represent less than 1% of the entire caribou population in the northeast and does not impact endangered southern caribou populations. The BCWF asserts that there is no scientific basis that could support the requirement for a complete closure of the caribou hunt. This element of the Proposed Amendment is neither responsive to the realities of local geography nor the health of the populations and sustainable harvests.
Additionally, the Province’s decision to reduce the moose harvest in 12 MUs in the Region where there is currently predator management to protect caribou populations fails to respect the predator-prey balance that is necessary for effective caribou recovery. An increase in moose populations will lead to significant increases in predators, including wolves, which will in turn increase pressure upon these caribou herds currently under management. Maintaining moose hunting in the areas is a key tool to support caribou recovery efforts.
Yahey does not mandate a curtailment of resident hunting opportunities
The court’s decision in Yahey4 does not mandate a reduction in recreational hunting opportunities available to resident hunters. Instead, the decision and the remedies granted were focused upon the impacts of cumulative industrial development, primarily the Province’s successive dispositions in relation to oil and gas and forestry.
The Court’s reasons and the remedy require the Province to reform its land management system and implement a method of considering cumulative effects. It does not mandate a reduction in hunting opportunities for resident hunters. The Court found that “the likely cause of this decline is anthropogenic habitat disturbance including substantial industrial development.”5 The Court concluded that the Provincial mechanisms for habitat protection were ineffective, as they only limit, but do not prevent industrial activity. The scope of this decision was not inclusive of the entirety of Region 7B of which a large proportion is protected and mostly free from anthropogenic change.
3 Government of British Columbia. (2021). Central Mountain Caribou. https://www2.gov.bc.ca/gov/content/environment/plants-animals-ecosystems/wildlife/wildlifeconservation/caribou/central-mountain-caribou
4 Yahey v. British Columbia, 2021 BCSC 1287.
Further, the area at issue in Yahey covered only a portion of Region 7B. The evidence of witnesses stated that First Nations hunters must travel further from the reserve in order to harvest, not that there was no ability to harvest throughout Region 7B.
We recommend more tailored measures to address Blueberry River First Nation’s preferred hunting areas as opposed to blanket reductions across the entire Region 7B. This could include reduction (not elimination) of resident hunting near Treaty 8 communities, while maintaining and increasing harvests where sustainable away from those communities.
We believe that the broad and sweeping nature of the Proposed Amendments, which span a significant portion of the province and devastate access to moose and caribou hunting by resident hunters are not supported by the Yahey decision. There are more effective alternatives that the Province should consider to support the rights of Treaty 8 First Nations. Such alternatives would more directly address the impacts to Blueberry River First Nation’s treaty rights, align with the court’s findings in Yahey and limit the impact on resident hunters.
The Province should not make resident hunters bear its failures
The real way to protect hunting for both Indigenous and licenced hunters is for the Province to commit to habitat protection, habitat restoration and habitat enhancement through a collaborative process inclusive of all stakeholders that will foster Truth and Reconciliation, rather than stoking divisions.
Over a number of years, the BCWF has urged the Province to address regional issues such as road density and a lack of habitat management and restoration. The BWCF has highlighted these issues in meetings with Ministers and senior administrative staff. The BCWF has attempted to directly fund habitat and ecosystem restoration projects in Region 7B, only to be rebuffed. These issues impact both resident hunters and Treaty 8 hunters and such restoration activities would benefit wildlife and all hunters in the Region. Habitat and ecosystem restoration would also directly respond to the Yahey decision, which determined that where wildlife is declining, it is likely due to anthropogenic habitat disturbance, including from industrial development.
The Province has an obligation to make a reasonable decision that is supported by evidence and creates true reform for habitat preservation to support wildlife populations. The Province cannot take a reactionary approach and continue the status quo of unsustainable resource development in Region 7B.
The Province must engage with stakeholders to implement appropriate policy measures
The Province has an obligation to engage with stakeholders with respect to wildlife decisions. It is imperative that the Province engage with resident hunters early in the process of developing wildlife management actions and certainly prior to the implementation of any decision so that there is a collaborative understanding and assessment of the full impacts of its chosen path. Your proposed changes will impact thousands of British Columbians for whom hunting is a core part of their lives. They deserve to be provided with the science relied on by the Province and to discuss alternate options to achieve the Province’s goals.
We request that you defer any decision until a process has been established to involve First Nations, BCWF and other interested stakeholders, and seek alternate solutions that meet everyone’s interests in the true spirit of Truth and Reconciliation. We have a positive working history with Treaty 8 First Nations and we are confident that we will be able to work with them to provide alternate solutions that focus on wildlife and habitat, and works for our respective groups.
Alternatively, if such a process is not developed, BCWF recommends that the Province implement an evidence-based and scientifically supported interim approach, including:
- Maintenance of the caribou General Open Season where it currently exists.
- Maintenance and liberalization of moose harvest in MUs with more limited access or sustainable population levels such as the Muskwa-Kechika Management Area.
- Liberalization of moose harvest in targeted caribou recovery areas.
- Focus the creation of policy objectives and management frameworks that limit (but do not eliminate) licenced hunter harvest in either time or space to only areas critical to Treaty 8 First Nations’ communities.
- Commitment of $500 million for wildlife and habitat restoration and management in the Peace-Liard Region, including:
a. The creation of objectives for wildlife and habitat in the area.
b. Funding for monitoring, inventory, research and most importantly restoration.
c. The establishment of processes to involve First Nations, stakeholders, industry, and the public in management.
d. A commitment to remove barriers to habitat restoration objectives, including controlled burning.
- A commitment that any changes to hunting regulations are only an interim two-year measure that will be reassessed and re-evaluated in accordance with scientific evidence, and that the BCWF will be included in such reassessment processes.
We look forward to your response and to working together to minimize the impacts proposed to resident British Columbian hunters.
Jesse Zeman, Executive Director, BC Wildlife Federation
Chuck Zuckerman, President, BC Wildlife Federation
Cc: Premier Horgan
What Can You Do?
Please remember that the issue here is the response of the BC government.
The BC government is prioritizing resource extraction over resident hunters and outdoor recreation with no science-based rationale for the conservation of wildlife in the Peace Region. The BCWF supported Treaty 8 First Nations in taking legal action against industrial development infringing on their treaty rights and agreed with the decision of the court case.
The best course of action that you can take right now is to use the tool below to send a letter directly to your Member of Legislative Assembly and let them know that you disagree with their decision to negotiate closures and reduce hunting opportunities for licensed hunters in the Peace Region.
For Immediate Release: March 10, 2022
UPDATE: Moose harvest for BC hunters slashed as a result of a court ruling that cites cumulative impacts of industrial activity impacting treaty rights.
A government proposal will see the moose harvest for local resident hunters cut by as much as 50 per cent in the Peace-Liard River region of northeastern BC. Caribou hunting will be closed across the region for all licenced hunters.
The Government of British Columbia has negotiated a deal that will see 195 forestry, oil and gas projects proceed in the traditional territory of the Blueberry River First Nation. Another 20 industrial projects in Blueberry territory are still up for negotiation, according to the Ministry of Indigenous Relations and Reconciliation.
The government has abandoned decades of science-based wildlife management, according to B.C. Wildlife Federation executive director Jesse Zeman. This is not a sustainability issue. The proposed agreement will severely curtail moose hunting for British Columbians in areas with the highest moose densities in B.C. while negotiations on permitting for industrial activities continue.
Sustainable Caribou and Moose hunting in the Peace-Liard currently supports 5,957 resident hunters and their families, who spend a combined 56,000 days enjoying Supernatural B.C. These every day British Columbians also put more than $18.4 million in hunting related expenditures.
Among the expected impacts of the deal:
- The number of BC residents allowed to harvest moose for food in the region reduced by 70 to 80 percent.
- A loss of more than $14-16 million in hunting-related economic activity from resident hunters.
- The allowable harvest of moose reduced to fewer than 650 animals, from a population that can support a sustainable annual harvest of 4801 to 7455 animals.
“Ordinary British Columbians who hunt for food are being traded-off in favour of resource extraction,” said Zeman. “The BCWF is concerned that this is the tip of the iceberg and that these kinds of deals are coming to parks, campsites, streams and lakes in British Columbia. After two years of this pandemic the province should be encouraging British Columbians to get outside and enjoy nature; instead it’s telling them they’re not welcome in the Peace and they should stay at home. The government’s approach puts science, fish, wildlife and habitat, as well as the mental and physical wellbeing of present and future generations of British Columbians last.”
The settlement was mandated by the court to address a very specific issue.
The Supreme Court of British Columbia ruled late last year that the Blueberry River First Nation’s treaty rights to hunt, trap and fish in their territory have been breached “by allowing industrial development in Blueberry’s territory at an extensive scale.”
According to the court’s ruling, “the cumulative effects from a range of provincially authorized activities, projects and developments (associated with oil and gas, forestry, mining, hydroelectric infrastructure, agricultural clearing and other activities) within and adjacent to their traditional territory that has resulted in significant adverse impacts on the meaningful exercise of their treaty rights, and that amount to a breach of the Treaty.”
“The BCWF has similar concerns as outlined in Blueberry’s case against BC, and in fact, declined to testify on behalf of the Province. For years both Treaty 8 Nations and the BCWF have pushed the provincial government to focus on wildlife management and habitat restoration in the region,” said Zeman. “This proposal does nothing to address the impacts of industrial activities nor does it provide support for on-the-ground actions that benefit wildlife and habitat in Treaty 8 territory. Successive governments have had more than a decade to respond to the concerns of Treaty 8 nations and stakeholders, but didn’t. Our government is trading away the rights of British Columbians in order to continue unsustainable industrial resource extraction instead of working with First Nations, local governments, industry, stakeholders and the public on solutions that work for wildlife and all involved.”
The BC Wildlife Federation fully supports the rights of First Nations to hunt and fish in their traditional territories for food, social and ceremonial purposes and our commitment to conservation and habitat restoration is shared between First Nations and non-First Nations.