- Why not fully implement the Harvest Allocation Policy in 2013, given the five year adjustment period that already took place from 2007-2012?
The Allocation Policy will be fully implemented in 2013/14 in all regions. Guides who are experiencing substantive economic hardship may have full implementation for some hunts phased in over the next four years.
- How will â€˜substantive economic hardshipâ€™ be determined and quantified?
Determining which specific guides may be affected by substantive economic hardship will be an early priority for the Allocation Working Group being established.Â All guides who receive an allocation will be reviewed.Â Those guides that are likely to experience more than a 30% reduction in harvest as a result of the policyâ€™s implementation will be considered a substantive economic hardship.
- Over what period will the transition for substantially impacted guides occur?
The transition began in 2012/13 and will continue for the next four years, until 2016/17.
- Will each of these areas be provided an Allocation Working Group to assist in transition?
The Allocation Working Group is a provincial entity consisting of regional and headquarters personnel that will serve all regions.
- What specific authority will the Allocation Working Group have in terms of their ability to mitigate economic hardship?
The Allocation Working Group will:
- Coordinate regional reviews to identify guides experiencing economic hardship, and assist those affected in coming into compliance with the allocation policy before the start of the next allocation period (within four years).
- Work with ministry staff to develop strong decision making processes and improve communications with individual businesses and stakeholder groups.
- Deliver on the direction from the Minister regarding a process to adjust the allocations for guides that have been found to be substantively impacted.Â
- Provide advice to the statutory decision makers who assign annual quotas to guides.Â While statutory decision makers must consider individual circumstances, the advice from the Working Group will be intended to promote consistent approaches to decision making and communications.
- How are First Nations traditional hunting rights affected by the Harvest Allocation Policy?
The First Nations hunt is not affected.Â Animals are set aside to meet conservation goals and First Nations needs first, and only after those needs are met are remaining animals divided up among user groups through the Harvest Allocation Policy.
- What method is used to calculate the Harvest Allocation for each species and what is the percentage split between residents and guides?Â Has this percentage changed from the 2007-2011 allocation cycle and if so how?
The harvest allocation procedure details the mechanism for determining allocation shares for each 5-year allocation period.Â In general, the calculation looks at how important each species/hunt is to the resident hunting and guiding communities, and examines how well each user-group is harvesting the allocations they are provided.
Percentage splits for resident and guides differ for each allocated species/hunt.Â There are currently 36 species/hunts managed under the Harvest Allocation system.
Current allocation splits do differ from those calculated for the 2007-11 allocation period, but most percentages changed by no more than 10% from 2007-11.
- How can guides account for varying hunter success rates and comply with their annual quotas and 5 year allocation under the new rules?
The new calculation method is more transparent, since it uses the annual allowable harvest for a population in question to calculate what can be assigned to a guide for a five year period (the five year allocation).Â Annual quota assignments, with guidelines, will be made to enable the guide to fully harvest his/her five year allocation for all hunts over the five year harvest allocation period.Â This system calculates and assigns quota based on the actual number of animals available to individual guides, rather than a formulas involving success rates.
- Why did government develop a new Harvest Allocation Policy?
Government recognized B.C. needed a consistent and transparent approach for making allocation decisions across the province. New Harvest Allocation Policies and Procedures were needed:
- To implement a decision-making process that is supported with a more objective, data-based, and consistent process for calculating the proportion of animals from a populationÂ hunt that is assigned to guides and to resident hunters; and
- To determine allocation outcomes that are more achievable, efficient, transparent and reflective of stakeholdersâ€™ interests.
- What was the process for developing the new Harvest Allocation Policy and when did it start?
In 2003/04, government determined it needed a consistent and transparent approach for making allocation decisions across the province. A new policy was needed to implement a decision-making process that was more objective, as well as determine allocation outcomes that were more achievable, efficient, and reflective of stakeholdersâ€™ interests.
In 2004, the Ministry convened a Task Group made up of representatives from the BC Wildlife Federation (BCWF), the Guide Outfitters Association of BC (GOABC), the BC Trappers Association (BCTA), and the Ministry of Environment.Â The Task Group developed a Terms of Reference and a set of guiding principles to help steer the review process.
With input from the Task Group, the Ministry developed a suite of eight policies and procedures, including a Harvest Allocation Policy and Procedure and an implementation plan, that were signed off in March 2007 (see http://www.env.gov.bc.ca/fw/wildlife/harvest_alloc/).
In order to enable residents and guides to adjust to the new policy, a five-year implementation period between 2007 and 2011 was agreed upon.Â
In early 2011, the Ministry commissioned former Deputy Minister Chris Trumpy to look at the impacts of implementing the Harvest Allocation Policy on the guide outfitting industry because government has a responsibility to be receptive to the concerns raised. Special allowances were made in 2012 to reduce impacts of full implementation, and the new policy will now be fully implemented over the period 2013-2016 with some transitional concessions for those guides who are found to be substantively impacted.
- How is the new policy different from what was in place before 2007?
Prior to 2007, methods for allocating harvest opportunities were criticized for being inconsistently applied between regions, ambiguous or unfair.
The new suite of policies offers a consistent method of determining allocations that is transparent, practical, and measurable.Â
The new method is data-driven, and is based on the relative importance of hunts to residents and guides, and considers their ability to harvest their allocated shares.
- How will the Annual Allowable Harvest, Allocation Splits and Guide Outfitter Quotas work?
The annual allowable harvest is the number of animals of a species that are allowed to be killed by resident hunters and guided hunters each year. There is a resident hunter portion and a guide-outfitter portion of the annual allowable harvest.
The harvest allocation split is the percentage of the annual allowable harvest that goes to resident hunters. For example, this could be 70 percent resident hunters and 30 percent guide hunters.
Quotas are the total number of animals of a species that clients of an individual guide outfitter may harvest within the guideâ€™s territory in a license year. The quota is indicated on the guide outfitterâ€™s license.Â
Under the new policy, the harvest allocation split between residents and guided hunters is applied to the guide outfitter certificate area or territory. For example, if the annual allowable harvest in the guide outfitter territory is 100 moose and the allocation split is 80 percent residents and 20 percent guided hunters, then the guide would be allocated 20 animals. Harvest allocations splits are typically established on a five-year time frame, called an allocation period.
By contrast quotas apply to an individual year. Quotas may be higher than a guideâ€™s annual allocation.Â For example, one method is to provide guides with a quota that allows them to harvest up to 30 percent of their 5-year allocation in a single year. This process is known as applying an administrative guideline, and is specified in the Administrative Guidelines Procedure.
- Will any flexibility be available for guides to fully harvest their allocations?
Yes.Â The flexible quota system is a new approach to calculating quotas. It allows increasing a guideâ€™s quota by a few animals if the number of animals the guide has left to harvest in the allocation period is less than one fifth of the guideâ€™s five-year allocation.
For example, if a guide has a five-year allocation of 50 moose and in the fifth year of his allocation he has eight animals left to take, his quota would be increased by 30 percent (8 x 1.3 = quota of 10)
This new approach should allow guides to more fully harvest their 5-year allocations, while providing them some flexibility to exceed that allocation should their clients be exceptionally successful at harvesting animals.Â Harvest in excess of the 5-year allocation could be carried forward into the following allocation period.
- What is the Quota Variance Principle?
The Quota Variance Principle outlines how guides may vary from established quota procedures to meet exceptional conditions, such as guiding in remote or inaccessible areas.Â To qualify for this variance, five conditions must be met:
- The resident hunting priority principle will not be impacted;
- Quota reduction in 2012 is in excess of 30% of the average quota for the previous allocation;
- The revised quota would not result in wildlife population sustainability concerns for the allocated species;
- The 30% reduction in quota is not a result of a change in the AAH for that species; and
- An affected guide outfitter can demonstrate that they have taken, or will take, proactive steps to mitigate impacts of the allocation policy through reforming his/her business practices.
- Why did the ministry increase the utilization increments in the allocation calculator if both representatives of the GOABC and BCWF were opposed to the change?
Since the allocation policy began to be implemented in 2007, there has been an increase in concern expressed by allocation user-groups that they need to fully harvest their entire portion of the allocation, or risk losing it to the other user-group.Â
Originally, utilization scores were based on 10 percent increments.Â The Ministry has changed this to 25 percent increments.
This change will allow user-groups to under-utilize by 25 percent before they are at risk of having their allocation shares adversely affected.
- What are regional success factors?
A regional success factor is a multiplier (or inflation factor) that is applied to the calculation of guidesâ€™ allocations to account for the less than 100 percent harvest success rates of their clients. For example, if a regional success factor of 1.5 was used, a guide with a one-year allocation of 10 animals would have a revised one-year allocation of 10 Ã— 1.5 = 15 animals.
- There seems to be different opinions on the use of regional success factors for calculating guide quotas. What is the concern and what has government decided?
Regional success factors have previously been used in some, but not all, regions to calculate guidesâ€™ allocations and quotas. In developing the Harvest Allocation Policy, the use of administrative guidelines alone was intended to replace the inconsistent use of regional success factors.
Some members of the guiding community believe regional success factors support guide industry and business flexibility, enable guides to fully utilize their allocated shares, and provide fairness. These guides do not believe that the administrative guidelines give them the required business flexibility that they need.
Others are concerned that the use of regional success factors could lead to potential over-harvest issues.Â
After careful consideration, government has decided not to support the use of regional success factors. Instead, a suite of other tools will be used to help provide guides with the flexibility and certainty they need to manage their business. These include:
- Allowance for regional manager discretion;
- Capping changes in allocation shares to no more than 10 percent from previous allocation period levels;
- Allowing guides with small moose allocations to harvest a larger portion of their five-year allocation in a single year;
- Instituting a flexible quota system;
- Increasing utilization increments from 10 percent to 25 percent in allocation share calculations;
- Implementing a quota variance principle.
- How is resident hunter priority being protected?
The Harvest Allocation Policy protects resident hunter priority by:
- Ensuring that the majority of Â the annual allowable harvest is allocated to resident hunters;
- By providing all of the annual allowable harvest in areas without guide territories to resident hunters;
- By considering resident huntersâ€™ opportunity first when removing unnecessary barriers to harvest; and
- By ensuring that when restrictions are necessary, guided huntersâ€™ opportunities are limited before resident huntersâ€™ opportunities.
- What is the estimated economic impact of implementing the new policy?
The author of the â€˜Harvest Allocation Policy Reviewâ€™ estimated an annual revenue loss to the industry of approximately $6 million, which is whyÂ transitional measures are being implemented for those guides who are substantively impacted and why other policy, legislation and regulatory provisions have are being made to increase guide certainty.
- What will government do to mitigate economic impacts to guides?
Specifically, the policy mitigates economic impacts by:
- Ensuring allocation percentages generated by the allocation calculator do not change by more than 10 percent between allocation periods (i.e. offers higher allocation certainty while booking hunts with clients);
- Guidesâ€™ individual allocation do not decrease by more than 30 percent over the next four years, calculated against actual harvests;
- Providing a suite of new tools to assist guides in fully utilizing their allocated shares, such as the Flexible Quota System.
- Developing a new Quota Variance Principle that clarifies how quotas may vary from established procedures to meet exceptional conditions, such as guiding in remote or inaccessible areas.
Since the policy was re-drafted in consultation with stakeholders in 2007, it has been understood that some industry restructuring will be necessary for some businesses to remain viable.
- Why are quotas reduced for some guide outfitters as a result of this new policy?
In the past, guide outfitter quotas in several regions had been increased through the application of regional success factors, access to the allowable harvest in areas without guide territories, or through historic agreements with Ministry staff. When the policy is fully implemented in 2013, these various factors will no longer be used in developing quotas. In regions where these mechanisms have been employed, guides will see a reduction in quotas for some hunts.
Guides could also see a reduction in their quotas as a result of regional allocation splits changing between 2007-11 and the 2012-16 allocation periods.
- Some user groups are saying the new policy can still be subject to different regional interpretations. How do you respond?
At its core, the Harvest Allocation Policy determines the AAH percentage splits for some wildlife populations.Â These percentage splits are applied to a populationâ€™s AAH in order to determine the number of animals that may be taken by guides.Â This figure is then divided up amongst the guides whose are involved in hunting that population.Â This figure is then multiplied by five years to produce a five year allocation that identifies the number of animals that should be taken by the guide over the full five year period.Â Further direction is provided by a suite of policies and procedures that outline the use of annual quota to enable guides to achieve their five year allocation.Â
This policy advice is consistent across the entire province.
However, the assignment of Quota is the responsibility of the Regional Fish and Wildlife Manager.Â As the Statutory Decision Maker he or she takes policy advice into consideration.Â However he or she must also consider individual or exceptional circumstances when making decision and this can lead to some variability.
Furthermore, the productivity and size of populations may vary by region which could result in AAH changes and varying quota adjustments by region.Â Â Â Â Â
One of the Ministry Responses does include allowance for regional managers to apply their discretion in unique or exceptional circumstances when allocating harvest opportunities.
Although concerns have been raised that this will lead to different regional interpretations of the policy, the Ministry Response also includes a provision that any deviations from the policy must include consultation with the Manager of Wildlife and representatives of the guiding and resident hunting communities. Where possible the final results will be posted to the Ministryâ€™s website.Â
This will ensure a transparent decision-making process that is clearly understood by all parties.