Originally Published in the December 1991 issue of The Outfitter Magazine.
October 4, 1991
Dear Mr. Minister:
Thank you for taking time from your hectic schedule to meet with our board September 12th. The following are the NOTO recommendations in response to your Ministry’s “Policy Branch Draft Procedure for the Assignment of Bear Management Areas” as presented to you, verbally and condensed.
PROPOSED QUOTA SYSTEM:
The one bear per fifty square kilometer quota should not be implemented Province wide. The MNR has not adequately determined through a sound scientifically accepted biological examination of collected data, the necessity of this action. Operators on larger BMAs report to actually be taking more and larger bear in the same areas actively hunted for many years.
The crux of the problem which seems to be the instigating factor in considering a quota implementation in the first place, is that holders of small BMAs hold an increasingly larger potential for over-harvesting their areas, and correspondingly those of their neighbours.
The original intent of the BMA was, as is the case with trap lines and minnow grounds, to allow operators to manage their own individual areas for the purpose of maintaining sustainable, quality population levels. The incentive was mostly economic as poor quality and low population levels would, of itself, dictate the need for a reduced level of harvest.
For the most part this holds true. The exception would be in areas populated by multitudes of small adjoining BMAs. Here the potential for over-harvesting and operator conflict exists for obvious reasons.
BMAs over one thousand square kilometers in size be excluded from the 1 bear/50 km rule.
NOTO does not want a further increase in Fees.
BMA SALE OF ASSET OR TRANSFER:
NOTO remains firm and committed to the concept of BMA transfer in the event of a business sale. BMAs should be dealt with in the same manor as trap lines: where the actual “line” reverts to the Crown in the event of sale and only the “improvements” may be sold by the vendor. Where the vendor presents a qualified purchaser, MNR must agree to recognize and consider this persons option first. After all, bear baiting stations and associated equipment are in effect “improvements”.
INTERNATIONAL TRANSPORTATION OF WILD MEAT:
The Federal CITES Permit, newly required and issued from Provincial MNR offices, is both inconvenient and counter-productive. We understand the reason for introducing this new permit stems from federally negotiated agreements with certain concerned countries, and was not necessarily wanted or encouraged by Canada. Although this permit is free, it will create possible situations where meat is wasted because the permit cannot be obtained except during MNR office hours.
Allow issuing of CITES Permit by the same people already in place to issue Export Permits.
NOTO encourages the MNR to establish an on-going research program into bear population and management as soon as possible. BMA fees should go specifically towards this end. This program should provide participation incentives to encourage operators to share with the MNR in this research
NOTO recommends that the MNR restrict each hunter to only one bear hunting “harvest permit” per license per year. For example: an unsuccessful spring hunter may return in fall to try again, but a yearly “one hunter one bear” option should be mandatory. Party hunting for bear should also be eliminated.
SOWS WITH CUBS:
NOTO recommends regulation which would disallow the taking of female bears with cubs at any time.
RECOGNIZING LEGITIMATE OPERATORS:
The MNR, the MTR and NOTO must find a method to identify and recognize legitimate bear hunting guides holdings BMAs and operating as bear hunt outfitters who do not qualify for an MTR “Tourist Establishment License”.
That MNR and NOTO encourage MTR to establish a provision in their licensing which will all “Tourist Outfitter” status to legitimate hunt operators who provide a letter of recommendation from a licensed operator and a current financial statement. Those unable to meet these criteria would have their BMA revoked.
BMA HOLDERS MEETING:
NOTO recommends that the MNR call a meeting of all registered bear hunt operators. The first BMA meetings in 1988 were perceived by many as a land grab. Now that there is a moratorium in place and those operators still remaining in the bear hunt fully understand the system, a meeting to trade, isolate, clean up and consolidate among operators is necessary. MNR could use this as an opportunity to return for option, any BMA area returned to reserve because of non-payment of BMA fees. Legitimate operators require an opportunity to reclaim the area lost in initial negotiations, to trade with other operators where logistically sensible, or to add more area if it is indeed available.
NOTO must insist that the MNR understand the importance of not isolating bear hunting per say, in any commercial operator’s education course the future might produce. All guiding and hunting activities should be covered so as not to isolate bear hunting and draw unnecessary negative attention towards bear hunting specifically.
Please consider these recommendations. The Bear Management program is a very good one and only needs some fine tuning to satisfy all interested parties.
Bernie Cox, Chairman