Government recognized BC needed a consistent and transparent approach for making allocation decisions across the province. A new Harvest Allocation Policy and Procedure was needed:

• To implement a decision-making process that is more objective, data-based, and consistent; and
• To determine allocation outcomes that are more achievable, efficient, and reflective of stakeholders’ interests.

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 stakeholders’ 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.  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 agreed to by all parties in the Task Group at the time, and 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 to 2011 was agreed upon, with full implementation in 2012.

A concern was raised that the harvest allocation policy would have a severe economic impact on the guide outfitting industry if fully implemented in 2012.

In February 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.

The report, entitled the Harvest Allocation Policy Review recognizes that the Harvest Allocation policy is both transparent and consistent but greater flexibility is needed to deal with the diversity of allocation-related circumstances that exist throughout the province.  The report offers 11 recommendations to address this issue. The report was distributed to representatives of the BCWF, GOABC and BCTA, and in May 2011 the Ministry received the official statements from the BCWF and GOABC on its recommendations (see http://www.env.gov.bc.ca/fw/wildlife/harvest_alloc/).

Ministry staff analyzed the report’s recommendations in light of the BCWF and GOABC’s official statements, and considered the data and staffing availability to implement those recommendations.  An initial response to each of recommendations was developed.  Those responses were reviewed by Chris Trumpy to ensure they were consistent with principles of his original recommendations (see http://www.env.gov.bc.ca/fw/wildlife/harvest_alloc/).

The Ministry Responses to the recommendations of the ‘Harvest Allocation Policy Review’ document were presented to representatives of the BCWF, the GOABC and the BCTA at a meeting in Richmond, BC on June 22, 2011.

At that meeting, Ministry representatives walked through each of the responses with the stakeholders to ensure they fully understood the details of each response.

After that meeting, stakeholder representative took those responses back to their respective associations for further discussions, and provided a formal reply to the Ministry in early July 2011.

There are a number of changes that will be made to the policy in 2012 to address both the concerns of guide-outfitters and resident hunters. These are outlined in the Backgrounder document (see http://www.env.gov.bc.ca/fw/wildlife/harvest_alloc/).

The new policy is responsive to regional differences and provides greater consistency and transparency.

Prior to 2007, methods for allocating harvest opportunities were criticized for being inconsistently applied between regions, ambiguous or unfair.

The new policy offers a consistent method of determining allocations that is transparent, practical, and measurable. 

The new method is based on the relative importance of hunts to residents and guides, and considers their ability to harvest their allocated shares.

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 guide’s territory in a license year. The quota is indicated on the guide outfitter’s license.

Under the new policy, the harvest allocation split between residents and guided hunters is applied to the guide outfitter 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 annual allowable harvest for the guide outfitter would be 20. Harvest allocations splits are established on a five-year time frame, called an allocation period.

By contrast quotas apply to an individual year. For example, guides are allowed to harvest up to 30percent of their 5-year allocation in a single year. This is an administrative guideline.

The Ministry responses to the recommendations further recommend instituting a flexible quota system and allowing guides with small moose allocations to harvest a higher percentage of their 5-year allocation in a single year.

The flexible quota system is a new approach to calculating quotas. It allows increasing a guide’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 guide’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.

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.  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.

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.

Utilization scores are based on 10 percent increments. The Ministry is recommending changing 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.

Some guides use historical harvest success rates of their clients to determine bookings.  A regional success factor is a multiplier (or inflation factor) that is applied to the calculation of a guides’ quota to account for the less than 100 percent success rates by 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 × 1.5 = 15 animals.

Regional success factors have previously been used in some, but not all, regions to calculate guides’ quotas. In developing the Harvest Allocation Policy, the use of administrative guidelines alone was intended to replace the inconsistent use of success factors by guides.

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.

Other guides are concerned that the use of regional success factors could lead to potential over-harvest issues. 

After careful consideration, government has decided not to continue the use of regional success factors for guide outfitters. Instead, a suite of regulatory tools will be used to provide help provide guides with the flexibility and certainty they need to manage their business. These include:

• Allowance for regional manager discretion;
• Capping allocation shares to no more than 10 percent from previous levels;
• Allowing guides with small moose allocations to harvest a larger portion of their five-year allocation in one year;
• Instituting a flexible quota system;
• Increasing utilization increments from 10 percent to 25 percent in allocation share calculations;
• Allowing guides to exceed their quota if they apply area-specific success rates in consultation with the Regional Manager; and
• Implementing a quota variance principle.

The Harvest Allocation Policy protects resident hunter priority by:

• Ensuring that the majority of 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 hunters’ opportunity first when removing unnecessary barriers to harvest; and
• By ensuring that when restrictions are necessary, guided hunters’ opportunities are limited before resident hunters’ opportunities.

The author of the ‘Harvest Allocation Policy Review’ estimated an annual revenue loss to the industry of approximately $6 million, which is why we’ve adapted the original policy – to help mitigate any economic impacts.

Specifically, the policy mitigates economic impacts by:

• Ensuring allocation shares do not change by more than 10 percent between allocation periods (i.e. offers higher allocation certainty while booking hunts with clients);
• 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 restructuring will be necessary for some businesses to remain viable.

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 2012, these various factors will no longer be used in quotas. In regions where these mechanisms had been employed, guides will see a reduction in quotas.

Some guides will also see a reduction in their quotas through the removal of the “hardship rule” that ensured no guide would receive more than a 20 percent reduction in their quota during the 2007-2011 implementation period. 

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.

When the Harvest Allocation Policy was signed off in 2007, it was determined that 2007 through 2011 would be a transition period for the resident and guided hunting communities.

While some aspects on the policy were initiated, other aspects – especially those that could create hardship for either user group, were delayed to provide time for adjustment.

In November 2010, the Ministry recalculated harvest allocation shares using the available, but incomplete information (2007 through 2009 harvest data), in order to give hunting groups a sense of what their allocation shares could be for the 2012-16 allocation period if the policy was fully implemented.

Regional staff used those preliminary estimates to determine what guide quotas might look like, and provided that information to guides so that they would have a better idea on how their quotas may change in 2012.

Yes, in addition to the changes that have been made to the policy, which provide benefits to both sectors, the Ministry has also committed to:

• Reviewing the policy again in 2014 to make sure it is working as intended;
• Undertaking an economic assessment of the value of resident hunting in the province and completing a provincial Limited Entry Hunt (LEH) review; and
• Providing additional funding for big game wildlife inventory (2011-12: $865,000; 2012-13: $395,000) which benefits all users of the resource.

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 Ministry’s website. 

This will ensure a transparent decision-making process that is clearly understood by all parties.

This year work on the Hunter Sample and LEH survey results was delayed by eight months due unanticipated complexities experienced during the development of an online partnership with BC Stats. The delay was further complicated by the need for systems expertise to resolve the issue.

According to the Harvest Allocation Policy, the previous five years of data should be used to calculate the allocation shares for the next allocation period. The original intention was to use data from 2007 through 2011 to determine shares for the 2012-2016 allocation period. However, as 2011 harvest data won’t be available until after May of 2012, the use of 2007 through 2010 data is the next best option. 

The Ministry will also only use data for years when hunts were being managed in accordance with the Harvest Allocation Policy. So for example, hunts that were administered under the policy beginning in 2008 would only have three years of data included in the calculation of 2012-2016 allocation shares.