Wildlife Act Review

Your goal of simplifying the Act by using plain language is admirable.  I assume you will be utilizing an English professor and not a lawyer.  

I   Priority Access for residents
As long as priority for residents remains policy and not law—not in the Act—we will continue to see regional managers making decisions based on personal experience and pressure-group politics by commercial interests.  As it is now, it is the personalismo as practiced in South America.

As resident hunters are taxpayers, and whereas foreign hunters don’t get to vote in B.C., resident hunters by law get and receive priority access to hunt all B.C. Wildlife.  This means, inter alia, that in any hunted population not more than 10% of the harvest will be allotted to foreign hunters.

II  LEH
Whenever a species population becomes of such concern that wildlife managers, out of conservation principles, put the species onto Limited Entry Hunting, then the hunt shall be only for resident hunters.

It makes no sense for a government to declare that a herd/population is in trouble, so we have to put that herd on Limited Entry, but we still allow foreigners to hunt the “endangered” population.  No other jurisdiction in North America (excluding Mexico) does what B.C. currently does.  It has to change if you hope to stop the decline in B.C. hunter numbers—with its attendant impact on the Wildlife Branch numbers and budget.

In the interim, the favoritism for foreign hunters must end. The foreign hunter doesn’t even have to enter our lottery hunt/draw; (s)he is an automatic winner every time—while the taxpaying, voting citizen hunter has to draw, often with steep odds.  This discrimination ought to be fixed by the Wildlife Branch/the government before it is fixed by the courts.  In short, this is your chance to remedy a blaring discriminatory policy.

III Science-based decisions
“It is the law in B.C. that wildlife management decisions are to be made on the best available science.”
A move to science-based decision making in wildlife management 15 years ago would have prevented the precipitous decline in B.C. hunter numbers. It would also put an end to the embarrassing 6-point elk and 4-point mule deer restrictions that resident hunters have opposed by walking away from such biologically unsound games birthed by and for commercial interests.  The precipitous decline in resident hunter numbers in the Kootenays tells the story.  The old sports stores also know.

IV  Government subsidy of a “business”
Government has no business subsidizing commercial hunting because government has no business subsidizing any business.  In short:  The government’s policy of ensuring the viability of the guides and guiding is unacceptable in a modern, free enterprise economy.

Judge J. L. McCarthy, in his investigation of the relationship between guides and the wildlife Branch (18 improprieties), pointed up “The compulsory hiring of guides by non-residents should be abolished.” [p. 59, Vol. 3, Feb. 23, 1979]  McCarthy on p. 58 proposes a Wildlife Act Revision, and on p. 60 he has an outline.  I believe it may be helpful to you to refer to his work, all done for MOE, as much of what he found as a problem still remains—e.g., “Officer______seems so typical of the Branch’s attitude towards the regulations.  That is, ‘I’m not going to let the regulations interfere with the administration of the guiding industry as I personally happen to see it to be.’” [p. 6, Vol. 2, June 6, 1978]

As for creating a self-governance structure for commercial users of wildlife, history has amply demonstrated that self-regulation is no regulation.  That’s in economic history texts as well as history texts.

In conclusion, I urge you not to allow anyone that produced the new Allocation Policy to get near the writing of the new Wildlife Act.  Clarity is totally absent in a 24-page document that, minus the definitions, has 12 pages containing 26 “shoulds.”

I have also read the review of the proposed changes to the wildlife Act.  Mona Helcermanas-Benge wrote a well informed response to your proposed changes.
I fully support Monas comments and see no reason to paraphrase another detailed list. However I would like to add the following.

FREEDOM of THE WILD

The entire report seems focused on the economic and entertainment value of hunting, the environmental science is conspicuously absent.
There is plenty of reference to making hunting easier and more accessible, given the current technologies and vehicles there is absolutely no need to make hunting easier. The whole notion of increasing hunting is abhorrent. Simple common sense shows the animals are on the losing end of a very imbalanced equation.
People all want “freedom” and like minimum or no restrictions; but every inroad, every new quad or 4x4, every attempt to make hunting easier, every new technology all adds up to less freedom for the animals. We are moving towards a system (common in the USA and Africa, which I have visited) where animals are bred and contained in a fenced area for hunting, like “shooting fish in a barrel”.

Apart from a brief mention of Ducks Unlimited there is no reference to any specific conservation strategy in your proposed changes to the act. Instead you continually refer to easier accessibility, reduced restrictions and the vague notion that hunters help in the management of game. With few isolated exceptions the idea of hunters living in harmony and balance with nature is simply not true.

Consider the UK and Europe, the wilderness is long gone. Logged out when England still had an “infinite supply of timber” for ship building and fuel.

Canada is big but the population is rapidly increasing, it is like watching an old movie of Europe as we cut into the wilderness with development and selfish entertainment like hunting. THE WILDERNESS IS FINITE AND DEMINISHING AT AN ALARMING RATE…..this is fact.  

 The single threat to global warming is not environmental protection but increasing Human Population. The hunters have opportunity to let the numbers of hunters decrease naturally as interest in other pursuits take over, this would make a small and positive contribution in the face of the expanding population. (Human population is the most serious problem of our time, but that’s a separate though linked topic)

I sat in a friends’ family room full of hunting trophies, they were all beautifully mounted; but there was a cold macabre and lifeless feeling from all those glassy stares.
More recently I visited a lady who specializes in photography of Grizzly bears. Her walls were covered in magnificent close ups of Grizzlies set in their natural surroundings, they were awe inspiring…….and the bears are still FREE.

The hunter spoke proudly about his guns, and his quad, particularly the high quality engineering of his rifles and how effective they were at killing his prey, meanwhile the photographer was full of enthusiasm for her camera gear. The big difference is that the photographer has to tread more carefully in the domain of the animal, to be at one with nature. Her work demonstrates the spiritual connection, to be so close and quiet and share in the living world of the wild.

The proposed changes to the act appear written by hunters for hunters. I urge a balanced debate, the wilderness is fragile the wild animals need our protection, not increased onslaught with improved technology and easier regulations.

The Wildlife Act is in dire need of amending.  I have been in Canada a year now after 5 years of working in California amidst some of the most stringent environmental legislation in the world, and was both shocked and ashamed to see what pathetic legislation (or lack thereof) we have in BC for natural resources that we supposedly value.  In its current state, the problems I have seen, experienced, or discussed amongst frustrated wildlife professionals are disturbingly consistent.  The biggest problem stems from lack of legislated regulations.  Both our provincial Wildlife Act and our newly fledged federal Species at Risk Act (SARA), have no teeth. 

In dealings with big business (e.g., developers, corporations, international conglomerates, etc.), guidelines and recommendations aren’t going to cut it.  Regulations have to be drawn up, and enforced.  Fines (big ones) combined with delays in issuing permits for project approvals, are one way to start.  But if fines are to be imposed for violations, the penalty fee must match and/or possibly exceed the pocketbook of the violator. Otherwise, it will simply be written off as a cost of doing business (i.e., a few thousand dollars is nothing for companies that can afford a few million in operating expenditures).  Shutting down projects in cases of prolonged inaction also hits the pocketbook.  This is the clout that the American Endangered Species Act carries.  And while it is applicable on both private and government land in the USA, in BC we could start by providing guardianship and effective stewardship on the vast tracts of our Crown land, be it for timber harvest, mining, municipal development, etc.

For major violators, or repeat offenders, a provincial “black list” needs to be created, accessible to the public (possibly released to the media), and the reasons why they are listed as such.  This will provide a means of societal “peer” pressure to get violators to behave.  Until they clean up their act enough to be removed from the list, they are to be carefully scrutinized by agencies for any project approvals while being targeted by watchdog groups.  The agencies must also stick to their guns in these cases, for they will also be under public scrutiny.  Thus, an effective set of regulations helps to achieve such goals, making it easier for agencies to enforce.

In amending the Wildlife Act, there has to be jurisdictional clarity amongst the different levels of government, be it provincial, federal, municipal, or various departments within such agencies.  If one agencies’ jurisdiction is to supersede another, this has to be clearly defined.  An example exists in cases of provincially managed species that occur on federal lands.  No provincial wildlife permits are required for projects that may “disturb” these species unless they are SARA listed.  This serves to defeat the purpose of the provincial Act.  And I have experienced provincial biologists expressing dismay over the manner in which their federal counterparts work on provincially “protected” species without their consultation (or knowledge in some cases). This needs to be addressed.

Other frustrations I have experienced amongst wildlife professionals since returning to BC include:
A severely understaffed and underfunded Conservation Officer (CO) Service.  How many COs are there per km2 in BC (particularly for the heavily populated areas)?  The lack of adequate COs for their area of coverage says everything about where provincial priorities lie and how much they really care.  Consequently, in some cases (i.e., inadequate funding resulting in incomplete training, etc.), COs may also be lacking in what should be considered ‘basic’ natural history knowledge (e.g., I have encountered a CO who wasn’t familiar with what an amphibian entailed; I can only hope this was an isolated case and not the norm).
Frustrations amongst Ministry of Environment biologists (often leading to bitterness) due to poorly managed projects (continually being cut back/underfunded & understaffed), lack of action, or unacceptable delays on proposed management efforts, or misapplication of science (e.g., captive rearing and release of  spotted owls).
Frustrations amongst consultants since they can advise their clients on the best means with dealing with wildlife issues (e.g., mitigation measures), but if it is not legislated, the client need not comply, particularly if such suggestions are costly to implement.  This is part of the reason why the “biostitute” reputation still lingers in BC post-FRBC and needs to change.  If a client is not ‘required’ to follow recommendations that may cost them several thousand dollars, why should they?  Under California & federal legislation, this would not even be questioned, but factored into the cost of doing business.  This needs to start happening in BC.

What is the point of the red and blue listing process?  Such categories mean nothing since there is no legislative backing to it.  I personally experienced such a situation two months ago when I came a across an amphibian breeding pond set amidst a new development project.  There were at least three species of amphibians breeding in this small wetland, including the blue-listed red-legged frog.  However, the investigating CO, assessing the area for Water Act violations, etc. found his hands tied.  There was nothing he could do if they wanted to backfill or drain it.  Discussing this with him and MOE biologists, I was disturbed to hear that this happens more regularly than publicized.  If we are truly concerned about SAR and want to effectively manage our wildlife resources in BC, then how about putting our money where our mouth is?  Let’s put a ‘bite’ behind the ‘bark’ of our legislation, otherwise, you need not change anything.

We have the opportunity to learn from over 30 years of endangered species legislation from our southern counterparts.  Let’s not repeat their screw-ups, but be proactive in applying good science in a timely matter to our wildlife resources.  Creating protective legislation that is actually effective is a good way to start.

1)  Regarding your wildlife review I  feel necessary to point out that increasing hunters fees would bring you more money than lowering fees.                                           
2)  More money is being generated through eco tourism than by hunting! 
3)  Eco tourism and hunting don't mix   
4)  If hunters think that it is their right to hunt  animals than I feel it is my right to view and/or photograph the same animals without harming them   
5)  Innocent people  and/or their pets on hikes are liable to be shot at by inexperienced
hunters
6)  Many people around the world take a dim view of the Canadian seal hunt.  If you encourage more hunting in BC then BC is going to lose out on many tourists who will stay away
7)  Confrontations between unarmed animal lovers and armed hunters will result in bloody conflicts in the wilderness...imagine trying to photograph  live wildlife while someone else is trying to shoot it dead
8)  If only a small percentage of BC residents like to kill and a larger percentage don’t why cater to the bloody minority
9)  If this new legislation goes through then I will be embarrassed to be a British Columbian 
10)  DO NOT ENCOURAGE MORE HUNTERS IN BC.   MOST OF US ARE FULLY AGAINST IT

I am extremely concerned with regard to the B.C. Wildlife Act Review and the direction of the proposals in the discussion paper.

 I think it is very important that we get the right legislation in place and therefore would ask that we take the time necessary to consult with as many stakeholders as possible.

In this spirit I would request that the review body  go to the various interest groups like the Conservationists, Eco-Tour Operators, Animal Welfare Groups, Wildlife Rehabilitators, First Nations and Rod and Gun Clubs etc. to review the current Wildlife Act so that when changes are made they are well thought out and bring out opinions from all sectors.

At present it seems the proposals in the discussion paper are heavily biased toward the hunting outfitters and toward self regulation and increasing the numbers of animals killed. I believe such a position is shortsighted and counterproductive to the interests of all British Columbians.  Please take the time to re-think and re-write the current  proposals in order for this document to serve all British Columbians and future generations so that B.C. remains "the best place on earth".

I disagree with the Ministry of Environment taking an active role in trying to recruit hunters.  This is not an appropriate role for this Ministry, whose primary mandate should be to protect wildlife and their habitat.  The Wildlife Act should provide a way for citizens to charge the Ministry in court if they are not upholding their duty to protect wildlife and habitat.

The introduction to the Discussion paper states a goal of “improved client service”.  Who are the Ministry of Environment’s clients?  I hope they are referring to the wildlife and the citizens of BC (not hunters and guide outfitters).

I have heard that over-hunting is already a problem.  I disagree with reliance on voluntary compliance with regulatory requirements.  We need an expanded and adequately funded Conservation Officer (CO) service to ensure enforcement of wildlife protection rules-especially if the number of hunters increases!  The number of COs should be at least proportional to the number of hunters.

I am glad to see First Nations are involved on a government-to-government basis.

There should be a First Nations conservation officer/monitoring program in place, as part of an expanded CO service. This would provide opportunity for FN to work as CO officers and environmental monitors.

How will an increased number of hunters be balanced so as not to infringe on First Nations rights? How will wildlife populations be managed to ensure enough wildlife are available for First Nations subsistence and cultural purposes, given the proposed increase in hunters?

Management of nuisance wildlife should not be downloaded to hunters and trappers.  They may not be properly trained to consider all options to managed problem wildlife.  This role should remain with an expanded CO service. 

I disagree with legalizing the ownership of Dead Wildlife and Wildlife Parts because this makes it difficult to enforce anti-poaching laws.

Please do not allow a spring bear hunt, as I understand this would make it more difficult to enforce trafficking of bear parts.  Also, the spring hunt can lead to mother bears being killed, and cubs who can not fend for themselves to die.

I disagree with the concept of hunting as a “sport”.  Hunting for food and cultural purposes is appropriate, but this is quite different than hunting for pure “sport”.  Conceiving of hunting as only a “sport” (and a “cool” one at that) is disrespectful to animals and is unlikely to lead to good wildlife conservation actions.

NB I fully support the recommendations in the submission provided by West Coast Environmental Law.

I feel this process of review of the Wildlife Act has been poorly advertised, especially considering the critical impacts it may have on wildlife in BC-which the public cares about very much.

I am requesting that the government departments involved in this review will take sufficient time to rethink some of the issues in this very important proposed legislation.  Before anything is taken to the Legislature next spring, I believe that it is imperative to involve all stakeholders in finalizing any proposed changes to the Wildlife Act.

Hunting
1. I am most concerned that you are considering encouraging increasing the number of hunters at a time when habitat reduction is depleting many species;  Hunting licences are a reasonable cost although equipment is expensive but anyone, male or female, over the age of ten can  currently obtain a licence and  hunt  if they so wish.  Allowing for people to ¹try out the sport¹ without proper certification is a retrograde step.

2.The province advertises as Supernatural BC.  With the Olympics looming, do
images of dead animals shot by hunters really encourage this to overseas visitors other than rich trophy hunters.

3. The spring hunt of Grizzly and Black bears should be stopped.  Bears coming out of hibernation are thin and in poor condition.  Females will usually have cubs that will then be orphaned at an age too young to survive in the wild on their own.

Falconry
1.  In most countries, a person applying for a falconers permit is required to work with a licensed falconer for at least a year before having birds to train on their own.  This needs to be the case in BC to protect the well being of the birds themselves and ensure the best practices of the art are practiced.  I am aware of a number of cases where falconry birds have been injured or lost due to inexperienced handlers.

2.  Falconers should be required to have basic standards for care of the birds and review of permits or licences before renewal as well as an inspection of both birds and facilities by several knowledgeable representatives, possibly including a veterinarian.  I would further suggest that rehabilitation centres, zoos, educational centres displaying animals
and  companies that keep animals for the movie industry would also have to comply with similar standards .

Wildlife Rehabilitation
1.  If rehabilitators are not allowed to rehabilitate non-native species, there must be humane options for the public to access, including on weekends, to deal with such animals found injured or orphaned.  An educational program would be required to inform both the rehabilitators and the public of the reasons for such changes.  Rehabilitation centres should NOT be required to euthanize otherwise healthy animals.

2.In all instances, self-policing is not an acceptable option.  It  can lead to abuses of the system ; a panel including several qualified people in the field  as well as practitioners, would be a better and more equitable system option. In most other areas, self-policing is not or has not worked to the benefit of the overall group (the current concerns about the RCMP are a good example).

I hope you will consider all the varied options that will have been brought to the Review but look forward with a wise vision of where we can be and be an efficient example of how well laws and regulations can be made.

Before I get into some specifics, I would like to open by stating that I am disappointed to see that far more emphasis being placed on hunting and "harvesting" of wildlife than on protecting it. This attitude is reflective of a very old and bygone era where everything living and existing on the planet’s surface is there for our as humans use and exploitation. We now know that the planet as a whole is an intricate system of relationships and that all life has high value to it. Some people have to hunt to be able to feed themselves and so be it. Any hunting beyond this boundary is at best entertainment and is totally unnecessary and an affront to the intelligence level of our species. As humans have evolved through time we have changed and indeed stopped practices from the past that at one time had been acceptable but then became no longer so. At one time slavery was widespread and women were seen to be inferior to men- no longer is that acceptable now. And so it should be that we no longer look at the lives of other species on this planet as being inferior to our own and therefore legitimize our exploitation of them for our pleasure. The science supports this and it is time for our legislation to reflect this.

 The changes that need to be made to the Wildlife Act should reflect the need for habitat protection and connectivity and a reduction in the level of human encroachment upon both through urban, tourism and resource development. It is our responsibility to ensure that this happens and it is your responsibility in government to understand what needs to be done and to lead us forward into the future rather than taking steps backward into the past.
 To conclude I accept that hunting is necessary for some people to live and for this reason only I think it will be necessary for the practice to continue. It is extremely inappropriate and severely disappointing that the Environment Ministry has a strategic project to increase the number of hunters in this province by 20,000 over the next decade. You cannot promote this and be serious about species and habitat conservation at the same time, which means I fear that you are not serious about species and habitat conservation. I hope that I am wrong.
  
I have some specific comments as well:

1.    Proposals for change- Alien Species

I agree whole-heartedly with the first point allowing for restrictions to be put in place for the introduction of alien species. However I feel that it should not be up to the Minister alone but there should be an independent panel created of scientists and wildlife experts that are peer reviewed and that makes binding recommendations to the Minister, in order for the proposals to be based on sound science and not political whims.
I would further urge at this point that BC ban the possession of exotic pets. There is no need for this province to permit the ownership of exotic animals as pets and this practice should be banned.
The second point about developing lists is also a good one but I would urge that the public never be allowed to translocate or release any species that is not native. There is no possible way to know all the possibilities of a release ahead of time and the public certainly does not have the knowledge or expertise to be bale to conduct this appropriately.

2.    Proposals for Change- Disease

I think the Wildlife Act should not permit the import of any live alien or exotic species, as commented above.
Again I feel that it should not be up to the Minister alone to designate and take measures to manage for a disease threat- it should be up to a panel of scientists and wildlife experts to instruct the Minister as to what to do. We should be placing the management of wildlife in the hands of experts not politicians who do not have any expertise on the issue and who are open to political interference.

3.    Proposals for change- managing human/wildlife interactions

Modifying the hunting license system to facilitate hunting on agricultural lands to control problem wildlife amounts to unregulated hunting.  It should not be up to the farmer or rancher to decide what is a nuisance animal and what is not. This should fall to the local CO whose first priority should be conservation, and who in consultation with wildlife experts can make a decision based on the best available science. Allowing people to willy-nilly shoot stuff they don’t like is an extremely backwards step and will further enforce the idea in the publics mind that species conservation is not taken seriously in BC. There will be a negative reaction in the burgeoning wildlife viewing industry and for tourism as a whole if “Supernatural BC” rolls back regulations on hunting like this proposal puts forth.
The next point of enabling a measure to ensure that members of the public that respond to wildlife conflicts (e.g. trappers & hunters) are qualified to assess conflicts and properly remove, capture and handle wildlife seems akin to having the fox guarding the henhouse. The only people that should be making these types of assessments are independent scientists and wildlife experts, not people who have a fiscal stake in furthering hunting and trapping. There is no way that these people can nor will make an unbiased decision here. 

4.    Proposals for change- Possession of Live Wildlife

 The strengthening of laws in regards to the humane treatment of captive wildlife is extremely overdue and urgently needed. It should also be extended to domestic animals as well, and the penalties should be no different than those for humans. Everything must be treated humanely, the time for distinctions between our species and all the rest is long over.

5.    Proposals for change- Wildlife kept in Captivity

The standards for all these facilities should be upgraded to be the most environmentally friendly in the world, and any facilities that are not should be shut down immediately. The government needs to take a more active approach in this area by contributing more funding to these facilities in order to ensure that they are funded properly to do the work that they are doing.

6.    Proposals for Change- Ownership of Dead Wildlife and Parts

Adopting stronger controls and strengthening penalties is an absolute must if these practices are to ever be stopped.
Authorizing the import possession and transfer of parts legally taken in other territories is not a good idea because it defers the responsibility to the laws in the other territory which may not be as stringent as they need to be. Recognizing export permits from elsewhere should only be done if the jurisdiction has similar or more strident policies in regards to wildlife. Allowing ownership of dead wildlife caught by nuisance animal trappers and those protecting their property is a bad idea because the determination is being made by people with a direct benefit from this practice. Again it should be up to scientists and wildlife experts to determine the necessity of this and not the people with an economic stake in the decision. This would be the fox guarding the henhouse again.

7.    Proposals for Change- Hunters

“Hunting is a valuable recreational experience that promotes appreciation for and understanding of wildlife species and their habitat in a natural environment.” This is such a false and misleading statement that I cannot let it go by without comment in good conscience. Nothing in that sentence is true. The fact that the Ministry has a Hunter Recruitment and Retention project tells me that the Ministry cannot be serious nor trusted to look after wildlife in this Province. The Ministry should reflect the position that hunting for enjoyment is an ancient activity that’s time has passed and needs to begin to seriously address species conservation and habitat protection. This project merely makes the Ministry and the Government of BC an extension of a small and dwindling number of people who cling to this ancient and barbaric practice like it is a right. In this aspect hunters are no different than the smokers of the world who feel that they can do whatever they please and disregard the rights of others. This is an unacceptable project by the Ministry and government of BC and must be abandoned immediately.

Therefore the enhanced odds system for limited entry hunting draws is unnecessary. Modifying the hunting licensing system to get younger hunters started sooner is the same as dropping the age for tobacco and alcohol for this group. At young ages people are not capable of determining right from wrong effectively and are easily susceptible to outside pressures. This proposal must have been written by a hunters group as with the rest of this section- it reads like a dream list for hunters and as such does not reflect the people of this Province as a whole.
Providing general open seasons for young hunters on mule deer does etc. puts the responsibility on their incapable shoulders for the decision of what they are killing. There are many things that youth are not permitted to do and this should continue to be one of them.
Regulations should not be simplified and made easier for hunters- they are too easy already.

8.    Proposals For Change- Responsibility for Licensing Commercial users

The government should not abdicate management responsibility of licensing or regulating any commercial users whatsoever. The proposals to have the commercial users industry groups regulate themselves is akin to having the inmates running the prison. There must be government supervision and enforcement- industry cannot be trusted to police themselves, this is something that has been proven time and time again in society and is an abdication of the government’s responsibility to the people.

9.    Proposals for change- Guide Outfitters

Any changes that are to be made to the allocated quotas should only come from a recommendation from an independent panel of scientists and wildlife experts, not just a decision made by the Ministry. The Hunter retention project is clearly showing that the Ministry has a pro-hunting bias and therefore does not reflect the views of a majority of British Columbians, let alone be able to responsibly address conservation based concerns. Only an independent panel of scientists and wildlife experts that are peer reviewed can be trusted with something so important as the future of BC’s wildlife.

10.                  Proposals for change- Fur Traders

Changing the requirements only works if there is enough staff and resources at the Ministry to check up on these exports and to ensure that the system is not being abused.

11.    Proposals for change- Commercial Wildlife Viewing

The Habitat Conservation Trust Fund surcharge is an excellent idea, and should be extended to all activities involving wildlife in this Province.

12.    Proposals for change- Taxidermists and Exporters

The regulations and controls on this industry need to be strengthened and enforced not lowered. The government needs to be more active and accept that it has responsibilities in this field and should not abdicate these.
Allowing ownership of animal remains involved in collisions and wildlife human conflicts opens up too large a Pandora’s box of abuses to be permitted. It opens up to many opportunities for illegal hunting and poaching.
Allowing expanded circumstances under which the government transfers ownership of animal parts just puts the government in the middle of the trade of animal parts and that is not where the body regulating wildlife should be. It clearly opens the door to conflicts of interest and should not be permitted.

13.    Proposals for Change- Effective Decision Making

Changing the Wildlife Act to reduce decision making complexity, placing the decision making at the most effective level and allocate authority consistently seems reasonable, but the only way for this to be consistent, respected and effective is if there is a panel or a series of independent panels of scientists and wildlife experts that are peer reviewed and given the resources to manage wildlife and their habitat in a way that promotes the wildlife. Downloading the decision making to municipal levels where the people making the decisions have an interest of any sort in the decision is not the way to go to have the wildlife of BC managed responsibly. There needs to be a strong and respected provincial authority managing wildlife not regional groups of special interests.

 Finally I feel it is important to note that BC must enact a provincial species at risk act and the responsibility for determining the species at risk and what must be done to protect them must be performed by a panel of scientists and wildlife experts that are peer reviewed and able to make binding recommendations. We have already seen in this Province what happens when this does not happen in the example of the Northern Spotted Owl. Government failed to heed the recommendations of experts, continued to remove habitat by logging old growth and now is faced with the responsibility for its extinction. This will continue to happen if politicians are left to make the decisions on how to best protect wildlife instead of the experts. The people have repeatedly spoken loudly and clearly for protection of wildlife and its habitat and it is time for the province to step up and respect the will of the people and provide for wildlife effectively.

I have taken the time to review the wildlife act proposed changes, and it seems to me to be heavily weighted towards a dwindling hunting user group. I understand the motivation to maintain or increase hunter numbers, but I think that the proposed changes are missing the changing attitudes of British Columbians, not to mention the stated goal of raising backcountry revenues. The Province's approach has been to market "supernatural BC" and the "best place on earth", and to pepper the backcountry with Ecolodges, Heliski,
Catski, mountain bike, hiking, and other ecotourism tenures. These people are more the type that want to see live animals, as opposed to seeing the photos of blood-stained hunters posing with dead grizzly, elk, moose, or wolf.

The decrease in hunter numbers reflects changing attitudes in BC - we are moving away from the "conquer the wilderness" wild west mentality that really does define our history, and entering a more enlightened era where hunting of appropriate populations (i.e. white tail and elk, which are at all-time highs) are encouraged, but the base pursuits of trophy and sport hunting (such as killing mountain goat, grizzly, bobcat, lynx, wolf, cougar, etc for the pure "sport" or pleasure) are becoming less and less palatable to the general public.

I would like the proposed changes in the wildlife act to reflect these changes in the BC population, as opposed to catering to important, but dwindling special-interest groups.
Opportunities for sustenance hunting (as mentioned above - whitetail, elk) should be maintained, while we really do need to get with the times and begin to phase out "pleasure killing", or trophy hunting of carnivores and animals like mountain goat. It really is time to finally halt the grizzly bear hunt as well. The latest numbers for the
area where I live (the Purcells) are 50% of the MOE numbers used in 2004 for environmental assessments of major development proposals (Proctor et al, March , 2007). This combined with all the new mining development, increasing backcountry use due to
changes in recreation and changes in BC commercial recreation policy, huge increases in motorized recreation, mega-resort (small city) proposals such as the proposed Jumbo Glacier Resort - all of which negatively impact an already dwindling grizzly population - requires a moratorium on grizzly hunting.

Also we need more stringent legal restrictions on motorized hunting access, to counter the massive increase in motorized users.

Thank you for your time.  I look forward to seeing the voice of the BC citizens reflected in the new Wildlife Act.

I believe that this new direction is misguided to say the least.  The last thing British Columbians need is another 20,000 or so hunters running around on ATV’s shooting whatever moves in the bushes of this province.  Women and children with guns?  Please, whose brilliant idea is that?  It’s bad enough that men are out there doing that.  I personally know a couple of fellows where I work who hunt, and I will tell you, I certainly wouldn’t want to encounter them on some remote logging road, these people are scary.  The only reason they are out there is to kill.  Period.
Provincial coffers would be much better off if the government were to concentrate more on eco-tourism/wildlife viewing.  It is long term, and we will look a lot better on the world stage.
Please reconsider this current approach, and don’t give in to the hunting lobby.  In this modern age, I believe we should have moved beyond this caveman mentality.

Thank you for inviting comments from the public. This is true democracy at work.
As a hunter, I welcome the opportunity to comment.

I am comfortable with the current pricing structure for resident permits, although the new hunter and under age 18 are welcome.

I would like to see a separate muzzle loader season re-introduced. I used to take part in the muzzle-loader season (one week prior to centrefire) back when you had it.

For small game, and upland game birds, could you have a reciprocal deal with other provinces, where if I have a BC license, I can hunt in Alberta, and vise versa?

Could the CORE course be a high school elective subject? As such, there would be no cost for the course itself (although the license fee would still apply)

I would very much like to see a handgun hunting season introduced. Yes, I am well aware that Federal law would have to be changed to allow the carrying of a handgun in the bush. Perhaps start with single shot only handguns (“wrist rifles”) such as the Thompson Center Contender. In spite of what some un-informed will say, HGH is very possible, and many countries have a HGH program.

No doubt you will hear from many that say we should not have any hunting at all. Be sure to ask them if they are willing to put their money where their mouth is. In other words, are they willing to accept a $50 Outdoors fee, simply to go hiking or wildlife photographing, in order to make up the loss of hunting revenue? It is easy to say others should give up something, the real test is how much is someone willing to give up themselves.

The Wildlife Act sees Wildlife as a “resource” managed by the government in the Public Interest. (p. 5) The majority of the Public Interest is opposed to hunting. They want to see this “Resource” protected. The paper states the Act encourages and enables British Columbians to take a greater role in environmental stewardship, however, it seems to simplify methods of destroying it. From eliminating the CORE exam for junior hunters to extending the age range for junior licenses and reducing the price of species licenses, it is easier for Wildlife to be left vulnerable to human predation. It is not necessary to go on a Recruitment drive for hunting, especially with your HOGWASH of “being a valuable outdoor recreational experience that promotes appreciation for and understanding of wildlife species and their habitat in the natural environment”.  (P.21) It is not necessary to destroy the Environment to appreciate it. I am insulted that statement is in print. The year is 2007, let's not take a step back in time with this opportunity to move forward.

     I support changes to this Act, but would like to see more advocacy for conservation of individual animals. For instance, no trap should be allowed in areas where endangered species are identified. Every individual matters, especially endangered ones. We as Humans must not forget that there are eight billion of us, and that we are NOT endangered.

     I agree with the proposals for change when it comes to violations of the Act, and being more stringent with penalties.  I strongly disagree with the consideration to allow bow hunters to hunt within a current no-go zone of 400 m of a highway. The Majority of British Columbian's are against hunting.

I would like to add my voice to the many others who have concerns about the preservation of our  wildlife.
I am totally against any 'sport' hunting. I think it is unnecessary, archaic and totally barbaric. We need to preserve our wildlife while we still have some, not destroy it.
Other countries have eradicated their wildlife so now they come to see ours. I am quite sure that tourism for live animals is greater than for shooting them.
Please consider the voice of the people of this province and save all our wildlife.

We find it discouraging that our Government would take a retrograde step to foster the killing of wild animals when the whole current tenor of society is to preserve nature and protect what we have.  We live in an area in which there are many deer and to a man, every one of our neighbours loves these animals.  Roadkill is one thing but to encourage young people to take another life is beyond our comprehension.  As the rules now stand, those who wish to hunt can do so.  We still have many hunters near our wild property near Nanaimo. We can't imagine there being more.  There are many examples of businesses and industries which have declined and those involved being required to move on to other activities.  Fishing, logging, and Mining spring to mind.  It is not the government's role to try to prop up one area of endeavour (hunting) if the community does not want that.  Why not encourage fishing which generates far more money for the economy and doesn't put people and mammals at risk.

Who is going to police the new 20,000 hunters the Ministry hopes will be killing our wildlife by the year 2014?

Encouraging children as young as 10 years old to hunt, i.e. kill wildlife, promotes the attitude that the life of a wild animal or bird is worthless and its only purpose on earth is for them to kill it.

Providing open seasons for mule deer and white-tailed deer does for hunters under 19 years of age, or single seasoned hunters, in our opinion encourages the injuring of those animals as these hunters are inexperienced and, although they may be under the supervision of a licensed hunter, this does not mean they are proficient enough with a gun to kill an animal outright.  But who will be there to monitor this and who in the Ministry cares anyway.

What are the new methods of hunting and the new hunting tools?   This certainly needs clarification.

Why does the Ministry continue to allow Guide Outfitters to take hunters out for trophy hunting? Activities such as trophy hunting and the spring bear hunt are degrading and should be prohibited.

We do not believe it should be the mandate of the Ministry to promote the consumptive use of wildlife by hunters.   This is inconsistent with the general trend of opinion that demands protection of wildlife and considers non-consumptive activities - i.e. wildlife viewing - as more valuable and socially acceptable.

Wildlife - Human Conflicts

To suggest that hunters and trappers be used to respond to wildlife-human conflicts is wrong.  Their view of wildlife differs from the many people who appreciate wild animals for their beauty and where a non-hunter would try to resolve the issue by education and perhaps removing the so-called “problem” animal by humane methods, the hunter/trapper would more likely decide the animal should be killed - an easy solution for them, but not for the animal.

Trappers

The continued use of inhumane traps and snares is deplored by many countries and most Canadians and as the fur industry is of insignificant economic value, we do not understand why the Ministry continues to allow this very inhumane treatment of wildlife.

General Comment

In our view the whole Wildlife Act appears to be geared to keeping happy those people who kill wild animals and there is no emphasis put on protecting wildlife by conserving wildlife habitats and helping to promote wildlife viewing as part of the tourism industry.

I am very much against increased shooting of wildlife and the increased use of guns in British Columbia. The Premier has said he wishes to take a leadership role in regards to the environment. The environment is not just clean air.

I believe the Ministry of the Environment should be protecting the environment for future generations, not exploiting it. Increase eco-tourism, not hunting.

Thanks for the opportunity to give input to this matter. In the past I found that the only input requested was to justify a decision that was already made.  I was born and raised near lesser Slave lake and had a long barrel rifle in my hand most of my youthful life as did most of the other kids I grew up with. I do not recall one occasion where some one shot another. We lived off wild meat, and I hunted every year but admit I quit for about five years as the process, regulations and registrations was just to much. I did not have to take a course as I was grandfathered passed the Core training but my son took it and when I looked at the course it had to be written by a duck hunter of a lover of ducks. ( I hate duck meat) We are seeing our country run by credentials but of little value to the trainees and of more value to the trainers. I am all in favor of training but a book does little good to get one very familiar to his rifle so he can handle it safely. Attitude is a bid factor in safety and knowing your rifle not 100 different rifles and hand guns you will never see of use. The write up in the province was good, but most of the decisions in our society are done by those not directly affected. We need a better draw system for the real hunters and those that put in for draws but don't hunt should be disqualified. The regulations are getting so complicated nobody is sure of all the requirements. With all our tax dollars going to the ever hungry Education and health system there is little money for ministries like wildlife so we just keep writing more regulations to offset the lack of enforcement. Rather than complain this is what I feel has to be done. Get away from credentials and endless papers in one’s wallet and go to a applied hands on training system for the type of rifle one uses not a potpourri of every thing under the sun and end up not being efficient at anything. Follow the time honor best training system known to mankind that being like a apprenticeship. Second where possible give an open system so one does not need a draw. Third where there is a draw system only let the hunters that hunt succeed. Those that do not believe in killing game animals, should not be entitled to get the draws as a preservation of the animals. Forth is this is a systemic issue and our kids only watch TV, Video games and the only thing they see is guns used to kill other humans, so we try to offset this violent part of our society by attacking the long barrel game hunters as the problem. Until we address the academic and urban attitudes toward hunting of wild life fewer will fish of hunt. We have a great resource in Canada with our wildlife but if we demonize, credential, and regulate the ones that do hunt today they too will give up, sit on the couch, drink beer, watch TV and end up in the hospital for health care where all the money is.

The recommendations, contained in a Wildlife Act review discussion paper, include a liberalization of hunting regulations to meet a provincial goal of generating 20,000 new hunters by 2014.

As if we haven't already got enough lunatics with guns running around, now you want more? Yes let's get more families involved so there are more guns for the kids to take to school and shoot each other with. In this day and age - what are you thinking? We are a progressive civilized society and the greed ridden BC government wants to take us back to the day of the Neanderthals? Hey if you love wildlife - SHOOT IT! Never mind about preserving land or doing sustainable logging, hell no - take away every last spec of land for development, clear-cut everything else and then shoot every homeless animal in sight! Can it get any more asinine?

British Columbia has a huge and active array of nature and wildlife admirers. Ever hear of "Take only photographs, leave only footsteps"? With open season on deer, we'll have a multitude of fawns dying slowly and horrify, we'll have infringement on the rights of those who are true nature lovers and who do not shoot and kill the best of the species.

Tourists from around the world come here to hike and enjoy the wildlife.  Just wait till the major European papers get wind of how BC caters to those who destroy nature.

Stop destroying the habitat, stop killing the natural predators and leave the wildlife alone! And for heavens sake with a $4.1 billion surplus you don't need to rake in more money at the expense of the wildlife and the people who enjoy seeing it ALIVE.

I fully agree with re-considering the program of Limited Entry Hunting draws.  I can not express my and fellow hunters dissatisfaction and unfairness of the current program.   Most believe that it is merely another money grab and gives us nothing in return or very little.  I am more than willing to wait for my turn, but when year after year your not chosen and then discuss with others that a portion of hunters are receiving the draws continually year after successful year, it is very discouraging and that’s why you have so many hunters losing interest.


On a positive side it  appears that Alberta has their hunting draw program organized in a manner that will be fair to all. I encourage this Ministry, to strongly consider mirroring their program.   The  age of 19 or under hunting program is great way to introduce the outdoors to our young citizens.  They will have an opportunity to decide if they have chosen the right sport by the taking of a deer.  Perhaps some will just enjoy the outdoors in its natural state.  This great province has everything an outdoors person would ever want. 

Kudos for Darlene Clarke of Port Alberni for her genuine interest in sharing her outdoor knowledge with women and kids.  More of us should be doing the same. I firmly believe that this province has sufficient for everyone to share.  I would especially like to see more Wildlife Officers out in the field, not just to hand out fines for offences but also to conduct accurate counts of wildlife (game animals of all species).  This type of action would head off over hunting before it actually happens.   The sport of hunting or just simply getting outdoors supports a vast amount of businesses.

Summary: Change the LEH program so that if a person has been drawn, then and only then must they pay for the permit.  I would pay double the amount for my permit fully knowing that others may not and by this action it may keep up the revenue required to operate a sustainable program while being fair with all.  If I am not drawn then I should be considered for a better chance next year and so on.

Get the Officers out in the field for the game count or perhaps listen to the reports of fully knowledgeable hunters like myself and so many of my friends.

If ladies and kids are going out for a hunt they should be escorted by fully experienced hunters until they have the full knowledge or bush savvy that will keep them safe.  I think everyone will agree that hunting is not merely a walk in the bush.

The present proposals are so ill-advised and out-of-touch with reality that... it is difficult to conceive how even self-interested parties could have invented them.

Present statistics represent the trends that increasingly value experience with wildlife through viewing as opposed to recreational killing.  These trends are not unique to BC.

It's time for guide-outfitters to recognize they are in a dying industry [pun intended] and to re-invent themselves into something more in tune with the world's developing values.  And the government should examine its own priorities and values, because these suggestions should never have received any attention or publicity, or any respect at all.

Absolutely DO NOT change the wildlife act as suggested. This needs to be thought out by a cross section of people involved including hunting and sports groups, hunting lodge owners, retailers etc.

This sounds like a very naive proposal that was thrown together by politicians/government employees to try and increase revenue etc.

We have seen on the North Shore (Vancouver) that the DWPO system is ineffective. It can be time consuming for the Conservation Officers with little to show for their efforts. It allows non-complying residents to “play the system”.  Once the time on the warning has expired the resident can return to his old ways of not managing wildlife attractants, and the officer has to start all over with a new warning. COs should be able to fine people as soon as there is evidence of unmanaged wildlife attractants, whether it be the resident's intent or not. A traffic offence is deemed to be a punishable offence even if the driver makes the error unknowingly.

Hunters and trappers should not be able to evaluate the situation and kill a wild animal on agricultural land. They lack the training and experience, and there would be an obvious and very serious conflict of interest. Hunters and trappers would not have the information or desire to support the landowners' responsibility to look at alternative ways of preventing and solving wildlife-human conflict. The Ministry of the Environment has such responsibility and should only authorize COs to kill wildlife that is deemed to be dangerous.

Regarding the Hunters subsection of the MANAGEMENT OF RECREATIONAL USE OF WILDLIFE section in the Wildlife Act, I am appalled to find that the working paper has suggested that amount of hunting licenses be increased. Chris Hamilton, who is heading a review of the Wildlife Act covering hunting, has stated that the hunting industry needs to be revitalized due to lost clients. I hope this suggestion is revoked for the following reasons.

1)      According to the BC Wilderness Tourism Association, ecotourism has brought at least 18 times more income to the province than hunters have. People from all over the world come to the beautiful province of BC to enjoy our natural scenery and abundant wildlife. An increase in hunting licenses will, as Chris Hamilton (the head of reviewing the hunting section of the Wildlife Act) has said, cause many “more animals [to be] shot.” To sacrifice the most important attraction of the entire ecotourism industry for the benefit of the 85,000 active hunters is neither economically nor politically intelligent. Moreover, the increase in hunters may be seen as an increase in danger for tourists and locals visiting nature. There have been cases around the world where hunters have strayed into areas where hunting is not allowed and have accidentally hurt non-hunters, and vice versa. Although with safety precautions, these accidents in BC are unlikely, the potential danger may discourage more eco-tourists to come and thus hurt the economy.

2)      The Wildlife Act states that “the size of the harvest that can be supported in that region at a specific point in time and the corresponding number of eligible authorizations is determined by Ministry staff using the best available science.” However, many cases worldwide have shown that the delicate balance in ecosystems cannot always be predicted by the best current sciences. For example, scientists over predicted the amount of cod left for commercial fishing, and as a result, the cod population has dropped to a dangerously low level. Even though a moratorium has been put on cod fishing since 1992, populations have still not returned to an acceptable level. The natural forests BC support many animals found nowhere else in the world; I do not hope that due to a past time such as recreational hunting, there is a large chance that unique wildlife may be lost. In addition, although permits are handed out to limit hunters to only killing wildlife with a population deemed to be stable, it is common for hunters to kill animals they did not intend to accidentally. If the by-catch is endangered animal, this action would seriously affect the ecosystem. 

3)      In this current age, we do not need to hunt to stay alive. With so many environmental issues, such as endangered species, to tackle, we desperately need to teach our children to love nature rather than dominate it. But how can killing teach love and compassion for nature as suggested by Mr. Hamilton? The thought that our next generation is taught that killing is a recreation is appalling, to say the least. I strongly oppose to the increase in hunting licenses for the above reasons stated.

I have been hunting continuously in BC for the past 46 years, with the first 8 years on Vancouver Island and the remainder in the East Kootenay Region.  I want to comment on the issue of how to encourage more hunters as I see from some published comments that the government and BCWF would like to see a 20% increase going forward.

There is no doubt that the increasing urbanization of our society and the “disneyfication” of our wildlife has led to a lack of acceptability of hunting in many people's minds.  This in turn causes people who may be marginally interested in hunting, or who may be thinking about hunting to follow the path of least resistance and not take up the sport.  In my view the only way to combat the anti-hunting attitudes is by a consistent and long-term public awareness program that promotes more acceptance of those who do hunt and clearly shows the benefits of hunting on the general health of wildlife populations.

Having said all that; however, I think there is an even greater impediment to the enjoyment of hunting that has reduced the numbers of hunters steadily over the past several years.  I am specifically referring to the Limited Entry Hunting system that has been in place for many years.

I participated in the very first LEH experiment in BC about 32 years ago when I applied for a grizzly permit for Butte Inlet.  There were fewer applicants than permits, so I got a permit and then started looking for someone to accompany me.  All of my hunting friends and acquaintances did not want to go, because they would not be able to hunt.  Eventually, I did end up finding the father of a hunting friend who would go along as back-up.   That story of itself means nothing, but what I experienced at that time has now spread across our entire province and the general level of frustration in the hunting population has caused many of my acquaintances to hang up their guns.

Gone are the days when several of us would go out for a spring bear hunt, or a late fall mule deer hunt - set up camp and generally “rough” it for a few days.  Now, the chances of getting a spring grizzly tag are so small a single hunter is lucky to get drawn once in 5 years and the chances of finding a hunting partner are even smaller.  The spring bear permits are announced so late and the spring road conditions so uncertain that no one can really plan a hunting camp on the hope that a LEH permit will materialize.  Many other species are the same and I think it is the lack of opportunity for camaraderie that has driven many away from hunting.

So, if that is the problem, how to solve it?

I think going back to a relatively short open season in some areas and for some species would be a worthwhile experiment.   It is a known fact that even in open seasons not every hunter will be successful, but if weather conditions one year caused a larger than acceptable kill, the season could be shortened or adjusted the following year.  What this would do is increase the chances of a novice hunter being successful and would plant the seeds of enjoyment that would grow from that point.

By way of example: let me suggest that an open season on whitetail deer could be accommodated in much of Region 4.  At the present time, from anecdotal evidence, it appears as though more deer are killed on our highways than by hunters.  If we could shift these numbers, so hunters are taking more than are killed on the highways it would have a double benefit.  More hunters would be able to achieve success in the field and the claims on ICBC would be reduced.

In conclusion, I would like to say that I think LEH is a system that is likely needed for some species and in some locations, but what I think has happened is that the people in the Ministry who are responsible for setting seasons and monitoring the results have come to overly rely on it for a number of reasons.

I am writing to express my opposition to most of the recommendations contained within the Wildlife Act review discussion paper. My main concern is that, with this proposal, the government is trying to increase the number of hunters in BC.

The conflict resolution expert Chris Hamilton cited the reasons for the government wanting more hunters: wild game is organic; and hunting encourages people to care about the outdoors, helps to reduce wildlife conflicts with farmers, and contributes to rural economies. I believe that there are other ways to accomplish these things other than encouraging more hunting. Money invested in promoting wilderness and wildlife tourism, combined with publicizing BC's stance on the protection of wildlife, would not only show people how important we British Columbians think our wilderness is, but would foster that same attitude in others. Just as people flock to other countries for the wilderness (e.g., safaris in Africa and Asia), people would want to see how our province is a leader in wildlife protection.

I believe this would satisfy (a) encouraging people to care about the outdoors, and (b) contributing to rural economies. Onto the other terms set forth by Mr. Hamilton.

Yes, wild animals are organic, but we should be encouraging people in the meat industry to be producing more organic meat anyways - we should not be creaming out the organic meat that's naturally in our environment, while injecting the animals we raise for food with growth hormones and other unnatural agents.

As for helping farmers avoid conflict with wildlife, we should be promoting the peaceful coexistence of farmers and wildlife rather than making it seem as though it is the fault of the wildlife when farmers and wild animals clash. The wild animals of BC have a right to the land and resources just as we do, and we should not exploit the fact that we can deny them this right. Farmers should be educated on proper methods of setting up their property so it does not encourage wildlife to enter it, and methods of peacefully getting wildlife to leave the area when it does enter.

Already we harm enough animals through pollution and overtaking their habitat. There is, by no means, a good enough reason to hurt these innocent creatures further. Please do the responsible, ethical and compassionate thing, and DO NOT allow these regulations come into effect.

When I first read about this proposition, I thought it was a hoax. I was thoroughly confused and baffled, because I have long had great respect for my government, and had not thought that this kind of change could make its way onto paper.

This is why:

1) Economics. It seems that one of the motivating factors of this plan is to improve the BC economy by encouraging hunting, being one of its contributors. This is erroneous. While this plan will no doubt increase the contribution of hunting to the BC economy, in doing so it will harm the economy overall, and in a quickly recognizable way. Ecotourism - hiking, animal watching, and other non-lethal forms of outdoor entertainment - contributes roughly twenty times as much to the economy as hunting. However, the more popular hunting becomes, the less attractive ecotourism is. Animal watching is less amusing without animals to watch, and hiking is less amusing when one must wear a neon orange vest to avoid being shot by an amateur in the woods.

2) Safety. The proposed plan removes several barriers of training and safety regulation, in hopes that fewer hurdles will promote hunting. It will, just as removing the necessity of licenses and speed limits would promote driving. But in the event that someone does get hurt - which is inevitable - responsibility will be aimed at the government for removing these standards. If hunting cannot be at once safe and popular, I choose that it be safe. I cannot imagine that anyone would choose differently. If it could be both, then why would we need to reduce safety standards at all?

3) Increasing the numbers of hunters, to counteract declining popularity. Chris Hamilton, who is heading the review, stated: “Like any business, if I had lost half my clients from 20 years ago I would want to look at barriers and bring those people back”. To me, this seems as sensible as the minister of health endorsing cigarettes to combat the declining popularity of smoking. If hunting is no longer considered to be socially acceptable, why should we buttress a crumbling structure? Hunting is an activity that we should facilitate only when there is great demand for it. It is not our place to create that demand, especially when the province, and its wildlife, would be better off without it.

4) Encouraging people to care about the outdoors, by encouraging hunting. I can think of no more admirable a way to appreciate the outdoors than to strip it of its original inhabitants, and mount them on trophies. After all, is it not true that we can only appreciate what we have once we have lost it? In that case, I fully support hunting, as a noble deed on par with clear-cut logging and open-pit mining.

Excellent ideas, especially regarding online sales of hunting and fishing licenses.

My comments are rightly or wrongly summarized by the points raised in the 13JUL07 Steeves article, the address by Dr. Narver and the reports by West Coast Environmental Law, showing the evisceration of BC environmental budgets and consequent: down-loading; down-sizing; lay-offs; non-enforcement; and general disregard for the fish & wildlife conservation in BC.

No matter what form the 'new" BC Wildlife Act might ultimately take, it will be a reflection of the Campbell cabinet culture.

To date, that characteristic inattention to environmental issues in BC seems to take the form: "do the minimum amount necessary to stay out of jail" and in some cases almost borders on prosecutable negligence...who knows it may come to that in due course, if it hasn't already in some sectors.

It is to the point now that fish & wildlife conservation groups are considering offering to subsidize Conservation Officers lap top computers to support and improve their field efficiencies...and offering to privately fund proper fish & wildlife conservation inventory work.

There are simply too few CO's for our growing population and those that are here still aren't supported by their political masters.

In the recent CO organization review it came to light that morale within the CO corps is understandably low...despite what their political masters might want to hear.

As the reports above indicate...there is also now a deliberately created chronic shortage of fish & wildlife biologists and funding for those that remain is inadequate. The Campbell cabinet culture places priorities elsewhere.

As Ms Steeves says about the 'new' BC Wildlife Act:: "However, I found the 45-page discussion document shamelessly free of detail on which to base a discussion. Platitudes abounded. Philosophy ran rampant. Vagueness was all around."

Again an apt description of what flows from the Campbell cabinet culture in the environmental arena

In addition, the Land & Resource Management Planning (LRMP) process consumed 6 - 9 years of staff time and thousands of volunteer hours & expense, and squandered the good will of many of us lay-people, only to be abandoned without any explanation whatsoever.

As a consequence, a justifiably lingering sense of mistrust of the BC political "review" apparatus remains and the lingering sense of betrayal should not be underestimated when completing the review of the 'new' BC Wildlife Act.

We wish to express our astonishment and concern at the B.C. Government's proposal re- increasing the number of hunters of wildlife in B.C..  There are many reasons why this should be turned down. Here are a few:

1. B.C. wildlife belongs to everyone, not only residents but to others including the many tourists who come to enjoy our wildlife, not to a few individuals who take delight in killing defenceless animals.
2. Many species of wildlife are under pressure due to loss of habitat from human development, logging, climate change and both legal and illegal hunting.
3. The vast majority of B.C. residents would not wish to see young children encouraged to use guns, show little or no respect for wildlife and to enjoy killing or maiming defenceless animals. It would also increase the risk of accidents and possible anti-social acts with guns involving children.
4. If this is just a way to raise revenue, why not increase the license fee for hunting, not increase the number of hunters.
5. There are plenty of other ways for people to enjoy our wonderful outdoors.  Any shooting of wildlife should be with cameras not guns.

Excellent idea, unfortunately just too many people have lost touch with reality.  Hunting is part of all humankind's tradition and to this day meat forms a very important part of our diet.  The benefits are enormous, one of these benefits is the amount of respect one has for the meat one eats is increased a hundred fold when you harvest it yourself, you understand exactly what you are doing when you lift that fork to your mouth.  When your meat comes wrapped in plastic from the local supermarket very little thought is actually given to the animal. There are many other benefits of course but and others can speak of them, I'll just say the benefits greatly out weigh the negatives.

I am appalled and furious that environment minister Chris Hamilton has actively encouraged more hunters in British Columbia, and as a result he should step down from his post for incompetence.

I would like to know Mr. Hamilton’s personal background and see if he has any experience in any environment.  Other than being a business man I’m sure his experience is as limited as his views.

Born and raised in this province, with two grand parents that served in WW II, and having a parent that was a hard core outdoors person, the handling of firearms and hunting was treated with care, respect, and appreciation all of which   died out years ago.

The preservation of our environment is paramount and encouraging and advertising hunting as a recreation is neglectful and ignorant.

British Columbia is the last frontier compared to other parts of the world and Canada. There are no animals that compare to ours in size, health, and beauty.  Every province across Canada can't compare to what B.C has because they have destroyed what little they did have through mismanagement and greed.  Let us not follow the same path, please.

Why has our environment minister allowed our guiding territories to fall in to foreign control?  Why has our minister allowed these areas to operate with no hunting quotas?  Why has there been a huge fall in all out larger species across B.C?  Why are our most mature breeding big game males only 5 yrs old thus creating a shortage of breeding stock?

A news flash for our minister:  Our game numbers are in decline, Sir.  Logging, farming, mining, population growth, and hunting have already stressed out animal numbers.

Canada does not need more people, British Columbia does not need more people, and hunting does not need more people.  Quit trying to brain wash us so you can make a buck or enhance your political future. If you politics want to put something up for discussion, then lets discuss our immigration policies, but i doubt that would ever happen.

Step down Mr Hamilton, you are not only lost but you are dangerous.

*Please note, Chris Hamilton speaks for the Wildlife Act Review project.  He is not the Minister of the Environment.

I think this is wrong for several reasons. These are my top 3:
 
1. The crime rate in BC is at an all time high. Why would we encourage more people to buy guns and teach them how to use them. Isn't that just setting us all up for a disaster?
 
2. Isn't it a known fact that children who hurt/kill animals turn out to be some of the most dangerous adults known to man. It takes away a sensitivity chip that they will never get back. To kill a helpless creature and watch it die is NOT a lesson I would ever want to teach my children...and to top it off, after years of "gun training" and practice, imagine if they grow up and use those skills against other people??? And our government taught them everything they know..  Nice!
 
3. Aren't we supposed to protect our wildlife??? If you want to encourage people to be more active, encourage them to join a volleyball team or go kayaking or something...not shoot guns. It's disgusting to me that the government is encouraging hunting for health reason...what about mental health???
 
Please don't let this happen. Money isn't everything.

We believe that our wildlife needs better protection than what is presently afforded by legislation here in BC.

1)      Connecting habitat protection as a key instrument in wildlife protection. Without sufficient habitat protection legislation we’ll be hard put to achieve our provinces goals of being a world leader in Environmental sustainability
2)      Conservation HAS to be the single most overriding consideration in how we create our laws and make our decisions when managing natural resources
3)      British Columbians have time and again made it clear that we value our wildlife, wilderness and outdoor recreation. And we need our elected representatives to have the courage to respond to this clear directive
4)      As a British Columbian, an individual and a father I am becoming frightened with the rapid demise of our wildlife and natural resources. We need to do a great deal more to protect and expand what we have left. As a family we are willing to pay for this and yes limit economic activity and growth to protect what we have left.

I do not even know where to begin with this one. Canada in general and BC in specific seem to be making giant leaps and bounds backward. Up until very recently I believed we were living in a progressive society. The current Review of the Wildlife Act proves my former notion is simply not the circumstance presently. While the Review claims it aims “to modernize this legislation”, its very conclusion states in a blatantly obvious fashion that such is not the case:

“Separate but related work is underway regarding habitat protection and management, and species at risk. While this work is a critical component of wildlife management, it is not the focus of the review at this time”

The Article posted on the Ministry of Environment’s page whole-heartedly admits to the changing of attitudes regarding wildlife and the advancement of our civilization concerning outlook and opinions on preservation of the gorgeous habitats and creatures native to this province. And yet it basically seems to imply that the views and voices of the people matter not, that perhaps if hunting is made cheaper and easier (at the expense of safety, mind you) more women and children will be motivated to put down their cameras, pick up guns and start shooting the very beings they now marvel at. We are blessed to be living in such a Beautiful British Columbia; I would hate to see that diminished by a ridiculous review such as is proposed.

At this time, I raise the question regarding whether a true cross section of British Columbians have been consulted.  I do not recall that government carried out consultation regarding changes to the Wildlife Act in my community.
 
We have a number of concerns.  Primarily, we oppose any change that would increase the spring bear hunt.  This is archaic and barbaric.  Because we live in an area with an active spring bear hunt, it is common knowledge that many bear cubs are orphaned each year directly as a result of this hunt. We have seen enormous fuss raised and lip service paid to a few high profile orphaned grizzly cubs.  What the public does not realize is that many cubs are orphaned in secret each year, directly as a result of the Ministry sanctioned hunt. 

While technically, with grizzly, bears with cubs are not to be hunted, it is common knowledge that hunters who have perhaps waited years for a limited entry ticket become frustrated if they do not shoot a bear as the season progresses.  They then become conveniently nearsighted to the presence of cubs and will take a sow bear and claim ignorance, not to mention the number of sows (with cubs) taken as a result of honest mistakes.

Predator hunting, in general must cease, especially as regards species that are know to be at risk and one, like wolverine, about which we know almost nothing.

Opportunities for sustenance hunting should be maintained (if you shoot it, you eat it), but we must eliminate "pleasure killing", or trophy hunting of carnivores and animals like mountain goat.  It time to finally halt the grizzly bear hunt. Hunting pressures cannot be calculated in isolation.  They are only one of the impacts on sensitive wildlife populations, such as wilderness obligate species like grizzly, mountain goat, wolverine, to name a few.  Mining development, timber harvest exacerbated by the pine beetle, proliferation of backcountry lodges, motorized recreation and generally significantly increased access by helicopter and other motorized means to previously inaccessible wilderness refuges all combine to negatively impact many species, like the ones mentioned above.

Given that we, as a society, can control very few of these impacts, the ones we can must be used as tools to help enable the survival of wilderness obligate species.  That boils down to limiting and eliminating hunting of these species.

Another critical issue is the lack of compliance and enforcement personnel.  This situation must be immediately rectified considering the enormous surplus the province now boasts.  We must replace the two full time conservation officers and the one habitat biologist based in Golden.  Golden is located in the middle of a wildlife rich region and at the same time highly vulnerable to out-of-province recreationalists and/or poachers who do not respect and consider wildlife like BC residents do.  We have all heard stories about RVs from Alberta converging on lakes with processing equipment and fishing them out.  As well, Golden sits in the middle of one of the province's most important ecological treasures, the Columbia Wetlands WMA (CWWMA). The province has a regulation prohibiting the use of motorized vehicles like snowmobiles and ATVs within the CWWMA but is unable to enforce this regulation because of the prohibitive distance away of the single fulltime conservation officer located in Invermere.    

The Columbia Wetlands were legislated as a Wildlife Management Area because their value to wildlife was the primary identified value.  90% percent of the elk of the Upper Columbia basin winter in or near the wetlands, with surveys identifying over 500 elk, 200 moose, and in excess of 1000 white-tail deer.  (1998, Jamieson, Hennan)

The elk must be able to paw through soft snow to reach their critical food source.  Once the snow is compacted by snowmobile use, this becomes either impossible or requires much more energy. Winter is the most difficult time for ungulates, due to cold temperatures and limited access to food.

 Most of the mature females are pregnant during the winter months and much of their energy is expended on survival and successfully carrying their calves to term. Running around in response to snowmobiles wastes huge amounts of their stored fat and energy and dramatically reduces winter survival.  Again it is especially detrimental to pregnant elk due to the proven fact that excessive running in deep snow is known to cause miscarriages. This can have impacts on the population dynamics.

Snowmobiles are prohibited with good reason yet there is no way to enforce this regulation because of lack of personnel.

Again, we ask that the province continue to consult on proposed changes and consider the issues raised in this letter. Thank you and we look forward to a response addressing the concerns raised above.

Rather than the recent newspaper headlines of the BC Government “encouraging more hunters”, I feel the Province would do FAR BETTER to encourage Eco-Tourism dollars.  This could be achieved more through the preservation of our diverse Wildlife and ensuring it is adequately protected for the years and generations to come.

Grizzlies should be considered endangered BEFORE they become too low of a population for reproducing and heading them for extinction.  Same is true for many of the other varied species BC is home to - they should be protected (from hunters and development) for legacy to the generations ahead.

”Man's thumb on the balance of Nature” needs to be more balanced, these days - try to discourage “hunting practices” as a means for tourism dollars...  We need to better respect the caregiver/warden role of mankind with respect to our Wildlife - ensuring present conditions for the Wildlife ensure optimum living conditions, balance in species and population numbers. 
MLA Barry Penner - please safeguard our Wildlife “properly” so our children's children (and beyond) are able to know that BC is a guardian of Wildlife - respectful, appreciative and with a thought to longevity!

I am extremely concerned and dismayed by the proposed changes to this Act:
*       Environmentally - should be our first concern
*       More guns in people's possession - dangerous to safety of all
*       More guns in the hands of women and teens - irresponsible
*       Making hunting of wildlife cheaper - if anything should be more expensive (taxes and fees on parks, services have increased, for example), it should be hunting
*       Disregarding other options available - eco-tourism would fulfill objectives without the negative outcomes

The proposed amendments set us back 50 years.  It is a regressive, barbaric, counter-productive proposal and would create more problems than it will solve.  I am vehemently opposed to the philosophy and execution of these changes.

Please reconsider and discard the proposed changes.

I would like the Wildlife Act not to further expand, nor endorse Trophy hunting.

Habitat and endangered species protection should be the cornerstone of any revisions
of the new Wildlife Act.  A wild BC is the greatest asset we have and every development and change must be assessed for risk to the species widely regarded as needing protection. These include but are not limited to the following:

Great Blue Heron,  Surf Scoter, Bald Eagle, Red-legged Frog, Turkey Vulture, Trumpeter Swan, Brant, Northern Goshawk, Western Screech-Owl, Vancouver Island Pygmy-Owl, Vancouver Island Marmot, Sea Otter, Humpback , Gray, and Orca Whales, Roosevelt Elk,  White-tailed Ptarmigan, Double-crested Cormorant, and Marbled Murrelet.

Additionally many species of fish such as Cod, Pinks, also Eulachons are in decline and need limits as to over-fishing and by-catch.

Pesticides are not compatible with wildlife, nor any life at all, and their use should be regulated throughout the wild environment. The neuro-toxin--SLICE, which is not 
authorized for use in Canada, but is widely used by fish farms, and damages clam beds in a four-mile radius, is only one example of a pesticide whose use should be immediately banned in the marine environment.

It is very disappointing to hear the Government would even consider increasing the number of hunters in this Province.  Every weekend in Mission, B.C. we are afraid to walk on the nature paths and dikes along the water as there are so many gun shots going off.  With an increase in this (and children allowed to use guns!) our outdoor usage will be nil.  Why would children be allowed guns and hunting?  What about the problems in schools?  Why should innocent animals be hunted and killed?  What about the wild animals who go on private property – how safe will the owners of the land be if even more people are hunting?

Please explain these scenarios to me.  How are the many, many of us who do not believe in guns and hunting supposed to enjoy the outdoors?

Though I only just found out about this opportunity to comment on the BC Wildlife Act and have not had the time to thoroughly read the discussion paper.  I would like to provide some comment.  As a hunter/fisherman who enjoys the opportunities the sport provides to get out into our beautiful outdoors I would first like to express that we are truly blest.  So many places do not have the wilderness and outdoor resources that we do.  I choose to live in northern BC because of these opportunities and want to see these continue for my children.  Fishing and hunting are some of the best things a family can do together. Today people spend too little time not enjoying the great outdoors and time in it with their family.  It is not just the bringing home of the fish or moose that makes the trip successful regardless of ones success it is being outdoors and enjoying the whole experience that matters.  The following are some comments.

In my opinion the current Limited Entry Hunting (LEH) system needs some changes.  I am sure you are aware of the Saskatchewan and Alberta hunting draw systems.  I have family in both of these provinces and therefore am familiar with these systems.  To me it seems much fairer.  In our system it is entirely random, while in Saskatchewan and Alberta, each year you apply you have a chance but your chances increase each year you apply until you do get drawn.  To me this at least gives a hunter some assurance that he/she will eventually get a draw. 

Lately there have been some changes to some of the LEH allocations which I do generally support, but in some cases it has made some areas over crowded with hunters.  Part of the experience is to be able to go into the wilderness and not bump into a hunter around every turn.  Recently, 2004 or 05, there was an allocation change for Spring Grizzly hunting in MU 6-17, that approximately doubled the number of tags.  There are only a few good accessible areas to hunt and now hunters are almost literally lined up in the same areas to hunt.  This is not the experience I personally look for.  I had this draw before the allocation changed and was able to enjoy the experience but now I no longer want to hunt there. 

The issue of allocations to guides is also a concern.  On occasion my friends and I have bumped into guides while out hunting and on a few these occasions been threatened by the guides because they see us resident hunters as competition to their success.  They are charging enormous amounts of money ($20,000 + for sheep) to take, mostly foreign, clients out hunting.  These are fees I never have a hope of paying.  Therefore I plan my own hunt without the benefit of a guide with remote camps, horse, planes and preseason scouting information.  This is particularly evident in the northern sheep hunting areas.  Guides have all the advantages, they are able fly (or on horse) around and pre scout those sheep that are good trophies for there clients.  They study the sheep’s patterns of activity so when the hunting season starts they know exactly where to concentrate their efforts.  We the local resident hunter don’t have that opportunity, we have a short 1 or 2 week window to try our luck.  I hear rumors that if more resident hunters do not start taking more sheep that the guides will be given more licenses.  I hope this does not happen as it takes resident hunters 5-7 years on average to get a sheep.  Let’s not make it more difficult.

Lastly, I want to comment on the licensing to do with non-Canadian resident fisherman.  Here in Terrace we have a number of very popular salmon and steelhead rivers that are becoming crowded with non-Canadian fisherman.  They arrive with their truck and camper and spend 4-6 weeks on a river dominating it, they spend very little, other than groceries and fuel, in our community.  I try and get out on a weekend and I am in severe competition to find a fishing spot.  The particular examples here are on the Skeena River in July and August and the Copper River in the fall steelhead season.  Often these non-Canadians will hire a guide on their first trip and then on their subsequent trips come on their own year after year once they know where to go.  On those Classified 1 and 2 rivers these non-Canadians should be required to hire a guide to fish these designated rivers.  This may free up some space and at least provide some employment to our local fishing guides.

I am fully opposed to the expansion and encouragement of hunting in British Columbia. The wildlife of this province is a natural resource that must be cultivated, not exploited. A live animal can be viewed, photographed and enjoyed throughout its lifetime. An animal shot by a hunter can never be seen or enjoyed by anyone else.

This province needs to encourage the conservation and expansion of wildlife species, not the outright slaughter of the few remaining wild animals left in this province.
How can we become a “green” environmentally friendly province when we are killing the remaining wild animals?

The trend around the world these days is eco-friendly tourism. Expansion of hunting runs counter to this trend. Do we want BC to become an outcast in the world tourism market? Is pandering to a small, although vocal, special interest group worth the scorn of the rest of the world?
It's time to phase out hunting and cultivate eco-friendly tourism. Develop a strategy that allows many people to “enjoy” the same animals through photos and viewing experiences.
Only one person can shoot and animal with a gun, unlimited numbers of people can “shoot” the same animal with a camera.

To summarize my comments - I am completely opposed to any expansion of hunting in this province. Hunting should be phased out and eco-friendly tourism should be cultivated. We need to cultivate, not eradicate, our wildlife species.

I'm glad to see that the government is using logic and reason instead of vote counting when making judgments about how to manage our wild life. If you really want to improve hunter numbers though you'll need to take a stand against the feds gun control. Would you pick up a sport if it meant that men with badges could invade your home a steal your property anytime they wanted to?

Keep in mind that no one loves wild life more then hunters we were the first conservationist and we're still the only true, logical, and knowledgeable conservationists.

I think more should be done to promote eco tourism and hunting with a camera. There are few places in the world like B.C. and I will be spending less time in the woods if I know there are more idiots with guns out there. Also there should be no spring bear hunt.

To add to your [Dave Shipway] thoughts, given the rapidly dwindling 'refugia tufts' of primaeval forests out there, in a vast and growing sea of cut-over lands one expects that any species which are dependent on such forests must be concentrating in these places in unnatural densities. That makes the felling of such patches even more criminal than usual. And of course, the sorry farce of 'variable retention' whereby generally least or non-merchantable stands are left in road-bights so when they blow down the next year they're easier to salvage, or the even more farcical "single-tree-every-100-metres-variable-retention" model we see so much of can never support even non primaeval-dependent species. I've asked the continuous face of MB, Weyerhaeuser's and subsequent clones here on south island, Jim Sears numerous times to avoid falling in nesting season and like you said, it was like a request from a space alien...

I will limit my input to the current review of BC's Wildlife Act to one glaring fault in current forest practices: that of logging during the critical spring nesting period for migratory birds.

Most of these small and nearly invisible passerines are theoretically fully protected by international laws which Canada has signed onto, but most people in the logging industry in BC pay no attention to these birds' needs during the crucial spring nesting period. In fact, whenever I have raised this conservation issue with professional foresters or loggers, I get the same response as if I had been talking about space aliens. Nobody in forestry really takes these international agreements to protect migratory birds seriously, perhaps because they are poorly understood, and have no direct monetary value.

I hope that in the current review of BC's Wildlife Act, some effort will be made to address this blind spot in the seasonal strategies of the logging industry. Statistics for many migratory bird species in Western North America show serious declines these days. The reasons are complex, and causes could be habitat loss, predation or toxic chemicals anywhere along the migration route. But surely, the BC government has an obligation to do whatever it can to protect the rights of these birds to reproduce themselves, and should therefore amend the Wildlife Act in ways that enforce the international agreements that are already in place to protect nesting migratory birds, and also educate everyone in forestry about this important and commonly neglected wildlife issue.

Otherwise, we will get to that "silent spring" yet.

"There comes a time when ya gotta take the bull by the tail and face the situation."  ~ W.C. Fields

The majority of the proposed changes to the BC wildlife act are long overdue. We live in an age where all forms of passive entertainment have resulted in a society that is increasingly inactive and out of touch with our natural world. BC has an outdoor environment that is second to none and anything that can be done to promote hunting, or any other outdoor activity, is both welcome and much needed.  The benefits of implementing the proposed changes and further promoting these activities would be far reaching. The outdoors provide a venue for education, physical activity, and quality time with friends and family that cannot be found anywhere else.  I applaud Ministry of the Environment's proposal for drawing attention to the many benefits to be reaped by both individuals and society at large, through the increased involvement of men, women, and youth, in life's most basic and wholesome pursuits.

Some very positive suggestions are on the table including;

- streamlining/simplifying angling and hunting regulations
- programs to make it easier for youth to try hunting and for current hunters to mentor new ones
- increased penalties for illegal harvesting of wildlife

I only hope that the majority of these recommendations will be implemented.

I am born and raised in this province and have worked in a small northern town as well as in Vancouver. As a middle aged professional I pay income tax at one of the very highest rates.
I have worked hard all of my life, and love this Province. I truly think it is the best place in the world to live, since I am an outdoor person who hikes, bikes, and camps. I spend my summers in various parts of the Province enjoying the natural beauty. On these bases, I consider myself a "stakeholder" in the future of this Province, and the way we choose to develop revenue sources.
I am opposed to increasing the number of hunters as a means to generate revenue on several grounds, including the fact that in my respectful view, living things are not to be treated as "commodities" to generate "revenue" or "trophies". Currently, there is insufficient enforcement of rules and regulations in the field as it is. The Government proposals would  effectively declare "open season" on wildlife so as to improve revenue for the Government, and Commercial Hunters, trappers, and fishermen.

The following proposals in your report are of particular concern to me:

1. At p. 17, under the heading of Management of Wildlife – Human Interactions:

Your report, by proposing that the hunting license system be modified to facilitate hunting on agricultural lands to control problem wildlife effectively suggests substituting the killing of animals for the improvement of programs to prevent wildlife-human conflicts from happening in the first place. The author of this report seems to suggest that the supposed limited capacity of the province or community to ensure compliance with public education and garbage handling should be addressed by simply allowing more animals to pay the ultimate price for human conflicts. Is that because the Government would rather generate revenue through taxation or levies than spend it on improving garbage facilities and education programs, or spend time simply improving the strength of by-laws to enforce compliance ?

2. At p. 18, Wildlife Kept in Captivity: Zoos, Wildlife Parks, Science and Education Facilities

The author of the Report suggests that the current system of permit issuance for each activity of possessing, importing, exporting, transporting, and trafficking wildlife should be substituted for a broader licensing system that would allow the license - holder to carry out all of these activities.

This sounds to me as though the Government agenda is to reduce the cost to themselves of maintaining a higher level of supervision in these matters, and to alter the current starting point  philosophy from disallowing these activities except under certain circumstances, to generally allowing the same, provided  the person meets certain conditions. It sounds as though you are loosening the rules in this area, which I do not think is advisable: Are there dangers to the health of wildlife, both native and non native, which are potentially exacerbated by importing, exporting, and transporting,  more less wildlife, more often, with less regulation. Certainly, it would be more "efficient" "effective and convenient for these facilities, but, that, in my view, may well create its own problems.... IE problems that will increase animal suffering...

p. 19 Proposals for Change, licenses for Zoos...

My concern here is that you are endeavoring to facilitate the creation of Zoos.. which of course generate revenue for the Government.. However, the broader question, in my respectful view, is, this: Apart from the revenue generation goal, what is the purpose of creating more Zoos? Do we truly believe that Zoos are the best place for animals?

P. 19 Wildlife Rehabilitators

Again, in the name of efficiency, you wish to substitute a permit system with a licensing system for Wildlife rehabilitators. I favour more, rather than less, supervision and regulation of these entities. I am sure you are well aware that the general public is most interested in ensuring that persons who act in the capacity of Wildlife Rehabilitators are skilled and effective in the carrying out of their care of animals. If this proposal is implemented, there may be potential for the dispensation of an unacceptably low quality of care.

P. 20, under the Heading of Ownership of Dead Wildlife and Wildlife Parts

1. In respect of the ownership of animal remains killed in a collision:

the Author of this report is suggesting that persons who find or actually kill wildlife in a collision with  their vehicle should be able to profit monetarily. The rationale seems to be that first,  allowing the finder to sell it will encourage the finder to  clean up of the remains and thereby enable the Ministry to  download what should be the Regulator's task onto private citizens for payment, and second, to ensure that valuable species information is gathered rather than lost.

I suggest that legislation should require those responsible for road kill to notify the Ministry of its whereabouts, at which point the Ministry should clean it up and ensure that   Ministry Scientists collect species information.  No private individual should be able to profit financially from a road kill, because of the clear  prospect that the abuse of the privilege will occur.

2.  Regarding Old Taxidermy pieces:

In respect of selling old taxidermy pieces that do not have supporting documentation, it seems to me the Author of this report is suggesting simply exempting individuals wishing to sell these pieces from legal requirements that should apply, because the burden is too "onerous". With respect, this approach, except in cases where the items are proven to be over a certain age, may encourage the illegal taking and trafficking in wildlife and wildlife parts.

3. Under Proposals for Change

Authorize the import, possession and transfer of wildlife and parts legally taken in other provinces and territories: How will you ensure that the possession and transfer of the wildlife and parts taken in other jurisdictions were taken under regulations and standards that meet or exceed the regulations and standards that B.C. imposes ? Regulation in one's own jurisdiction is difficult enough. Regulation or supervision of the means by which wildlife and parts were taken elsewhere is impossible. I do not wish to encourage hunters from elsewhere to bring items back to B.C. that were taken pursuant to rules or regulations that do not accord with acceptable standards.

Recognize export permits from other jurisdictions; Query, how will you ensure that these permits were issued pursuant to standards that meet or exceed our own?

Allow ownership of dead wildlife caught by nuisance animal trappers and those protecting their property: I am not in favour of  this proposal because it will encourage the increased killing of animals that might otherwise be dealt with by other non fatal avenues,  but were killed instead  because the Government is paying people to kill wildlife;


P. 21 Under the heading of Recreational Use of Wildlife

Under the Heading Hunters

The author of this report starts from the proposition that Hunting is a valuable "outdoor recreational experience". I question the applicability of the assertion to the sport/trophy hunting context, and I am opposed to increasing the number of hunters in this Province.

This is clearly a revenue generation project of questionable moral integrity. The Government may wish to consider that there are many reasons for the substantial reduction in the number of hunters in this Province which have nothing to do with the structure of regulations and licensing. There has been a societal shift away from the killing of living things for entertainment, and a movement towards wildlife appreciation in the form of viewing, preserving, and caring for, wildlife.

Under p. 22, Proposals for Change

Respecting the introduction of "Junior hunters"

With all due respect, adopting this proposal would simply be folly! I am sure the general public has no appetite for youngsters toting hunting rifles around, and actually being encouraged by their Government to kill living things as a form of recreation.

Enable a one-time only single - season license for new hunters to try the sport under the direct supervision of a licensed hunter but without the requirement of the CORE exam:

With all due respect, this proposal is simply dangerous. There would be far too much responsibility given to supervisors who may be unwilling or unable to exercise supervision at any given time, and who are responsible for supervising an untrained youngster with a rifle... I can only imagine the potential for disaster..  I am sure you can too. Is it worth it?

P. 24 Responsibility for Licensing Commercial Users

The author of this report touts the benefits of self - regulation.  Unfortunately, we all know that the public queries whether a variety of organizations can effectively police themselves, i.e. doctors, lawyers, and the RCMP. Self regulating bodies often do not provide satisfactory practical and ethical supervision of their members, investigate persons suspected or accused of infractions objectively and vigorously, or dispense penalties that ensure effective general deterrence. In fact, Self - Regulation, particularly where there is money at stake, may lead to exploitation of the resource by the regulators who are charged with preserving it.

The functions outlined here are extremely important and must be conducted by an outside agency to ensure:  the effective management of the resource; the imposition of effective and sufficiently stringent codes of conduct and ethics; and to ensure that license issuance standards do not degenerate.  While those involved in Commercial hunting have a vested interest in preserving the resource, the members also have a vested interest in making money by introducing more individuals to the sport, effectively refuting complaints about its members, and relaxing standards to encourage easy access to hunting, while  lowering standards unacceptably. In my view, these competing interests of the members negative any suggestion that self -regulation is the regulatory method of choice.

Page 27 - 28 Trappers

Query: What standards do you have in place to ensure animals caught in traps do not suffer?
Query: Are trappers still using leg hold traps?

P. 28 Under the heading Fur Traders

The author of your report suggests that the number of export permits required to be issued should be reduced, while allowing the Trader to export more furs under the authority of a license, after which the trader files a report.  The proposed Changes increase the potential for abuse on the part of the trader. How do you propose to check  that the "Report"   filed by the Trader  is accurate ? What can you do about any inaccuracies  after the Trader has shipped the furs ? You are again suggesting less, not more, supervision, which, may facilitate the job of the traders, but in my view, may well also increase the potential for abuse of the resource. The proposed changes, if adopted, may produce an inadequate regulatory system.


p. 29 Under the heading Commercial Wildlife Viewing

The author of the report suggests that wildlife viewing should not interfere with hunting. Although I am not necessarily a "fan" of wildlife viewing, if it is done carefully, any conflict the wildlife viewing industry produces with hunting should be resolved in favour of viewing, all other things being equal. It may be that viewing does not generate as much income/revenue as does hunting. However, improved viewing opportunities are the preferred method of income generation.

Viewing wildlife in its natural setting is the preferred activity. Social change over the last fifty or more years has generated  an increased respect for the sanctity of living things: this is the trend  towards which people in general are moving. A vocal minority, Hunters, may wish to recoup their revenue losses by increasing revenue generation through improving the profile of hunting in this Province. However,  I suggest you consider the perspective of many other residents of, and visitors to, B.C., who are not in support of Sport/Trophy Hunting  and will not support a Government that promotes hunting to pacify the commercial hunting, trapping, and trading industries while simultaneously generating Government revenue.

P. 30 Under the heading of Taxidermists and Exporters;

The Author of the Report suggests that Taxidermists should benefit from a "simplification" of the current export permitting process. The suggestion is that the Taxidermists themselves should ensure that the taxidermy work is conducted on wildlife obtained legally, and that all records pertaining to lawful ownership be maintained by the Taxidermist him or herself. In other words, the business people  that profit from hunting are tasked with ensuring that they  only do business with hunters who have obtained the wildlife legally.

I am not convinced that this method will ensure effective and adequate enforcement of rules and regulations , or the regulation of the taxidermy industry, for obvious reasons.

P. 32 under the heading Compliance

Under Proposals for Change, the Author of this report suggests that the circumstances for automatic license suspension be expanded. I am in favour of this, however, I suggest that what is also required is an increase in the number of Enforcement officers in the field, and improved training to facilitate successful in Court Prosecutions.

Also, not all offences can be dealt with by Administrative penalties. There are matters that must be prosecuted in Court, and prosecuted effectively.  Enforcement of the penalty provisions under the Wildlife Act and the relevant provisions of the Criminal Code should be of paramount priority. To promote effective and successful prosecutions of guilty persons, further training of Conservation Officers in the effective investigation of offences is required.

I have two ideas that probably have been mentioned.  The ministry needs to work with the farmers and try to get more access for hunters.  Especially if you are a hunting club member.   I see there is a pilot program started this year in the Peace country.  I was very excited to see that and will look at using the program.  Also the LEH system needs to be changed like some of the States have it where if you do not get picked then your odds increase to get picked in the future.  LEH elk on Vancouver Island should be that if you get picked then you can not enter for three to five years.  With the point system them maybe we here on Vancouver island might get an elk in our life time.  Lastly we need to look at the antler restrictions especially for moose.  I have heard that up north when the restrictions come into effect  there are a lot of moose getting killed every year and left to rot due to the rules.  Why not just put the moose in 7a 7b all on LEH and make it a special draw for only $3  and have it any bull then you can control how many moose get harvested every year and then there are no moose left to rot.  The fee would be nominal and the odds should be good as there are a lot of moose up north.  Thanks for the chance to input my ideas.

Today's "Province" newspaper carried an article about recruiting more hunters by targeting women and young people. I'd like to emphasize strong opposition to both ideas. This is not to be interpreted as being opposed to equal rights for women. They have that right to hunt as it is.  My concern is this:

1. More hunters means more guns in our society, to which I am strongly opposed. We have too much gun crime now.
 2. More hunters flies in the face of environmental conservation.
 3. More youth with hunting licenses ultimately leads to more buying, owning or having access to guns by young people. Have school shootings by students not been enough of a disaster? Why would the government peddle more guns to students and other young people? Such a policy is utter stupidity.
 4. To implement this policy because of declining revenue would be greed and short-sightedness. Please drop all thoughts of such a policy in the best interests for our society.

I think changes to the wildlife act are long overdue, as to getting more kids and women into the hobby, Excellent!! 

I would like to see common sense changes made to the LEH system, aside from the many complaints from us hunters about distribution, I would like to see where a tag for does be allowed during the entire GOS.  It the purpose is population control, what dose it matter when the animal is taken.

While I suspect many people will object to the media accounts of the changes to come, these changes are required, the “Anti” will find another fish to fry once they find some other cause to bang their drum over.

Thanks, eagerly awaiting the coming changes.

When I first read in the Vancouver Sun about the proposed changes to the Wildlife Act I felt stunned, horrified, and sickened.  I briefly thought it was an April Fool's joke, then quickly realized it could not be, since it is July.  I still find myself in shocked disbelief that the Government of this Province, not some hunting group, is not only actually proposing to "recruit" 20,000 new hunters to B.C. but is specifically aiming to encourage young people to become hunters. 

My comments are:

1)  I do not believe that decline in the "sport" of hunting is due to the cost of hunting or complexity of regulations.  I believe that a vast majority of people have come to view hunting as an unfavourable activity while at the same time developing an increased appreciation and awareness of the intrinsic value of our wildlife and a desire to preserve and protect it in all forms.

2)  That the BC Government would even consider proposing to make it easier and cheaper for young and new hunters to pick up guns and kill animals in order to increase government revenues is completely and utterly appalling on so many levels.  Have we already forgotten what happened at Columbine and other schools?  Do we really want to encourage youngsters to pick up rifles, learn how to shoot them, and go off to kill the very wildlife that we are, at the same time, trying to conserve, protect, and promote as a natural attraction?

3)  The proposal to allow bow hunters to hunt within 400 metres of a highway is also ludicrous. 

4)  Perhaps I missed it, but I did not see a proposal to encourage the careful development of non-intrusive wildlife safaris for viewing wildlife.  If our government needs to increase revenues on the backs of animals then this would be the way to do it.   There is already enough carnage in this world without our own government trying to profit from it, or encouraging children to partake in it.

5)  I do, however, support the proposals for change under the headings "Possession of Wildlife", "Wildlife Rehabilitators", "Wildlife Kept in Captivity", "Compliance" and "Appeals".

I am in full support of the changes to the act.  Increasing hunting licenses and education, and would support a revamp of the LEH program to increase opportunities for hunters who participate annually.

I have been participating in a BC Wildlife Federation program called “BOW” Becoming an Outdoors Woman” for several years now.  The education on hunting and wild life conservation being so initially connected has been incredible.  They do an amazing job with education and opening the opportunities to experience some of the many facets of the hunting, fishing and wild life conservations that make up such an incredible part of our province and heritage.

I believe education on hunting should be mandatory for all people not just women and children.  Gun accidents/deaths are most often committed by criminals, and with less than 1% of all incidents happening to licensed hunters of any age speaks volumes.  With wildlife numbers and habitats growing due to protection and management by the Wildlife Act and participation of such organizations of BC Wildlife Federation, the facts speak for themselves.

I am pleased to see that finally something sensible is being done to counter the lies and misleading information the environmentalists and media present to society today.
  
I would recommend that a minimum course on safety modeled after a BCWF BOW safety course that we received this year in Winfield should be a must though.

I am writing to ask that you review the new wildlife act and take more time to talk to the people of this province. The new act seems biased in favour of certain groups and doesn't appear to take a broad and long term view at preserving the last piece of wilderness left on our planet.

Being a hunter for 39 Years in BC and a taxpayer, I have noticed a considerable decline in a hunting and fishing activities as sport activities. With the present government in power, everything  has been changed into business and profits. Again we may see a further money collecting venues and charges imposed on hunters and sports fisherman.

The Wildlife Branch needs an open and inclusive process for making regulations. Specifically, the Branch must hold public hearings on all its proposed regulations, as follows:

At least 90 days prior to adopting regulations and 60 days prior to holding hearings on those regulations, the Branch must publish in newspapers throughout the province a Notice of Hearing and Intent to Adopt Proposed Regulations containing:
A brief description of the proposed regulations;
Where proposed regulations can be obtained;
Dates, times and locations of hearings in various parts of the province;
How written submissions may be made.

Hearings must be recorded and those recordings kept together with written submissions for 5 years.

Better regulations will be the result of this process; that’s been the case in every jurisdiction where it’s been used.  Failure to implement such a process will invite Charter challenges against unconstitutionally vague/unclear regulations and unequal treatment of B.C. residents/taxpayers.

Firstly, I am responding to an article in The Province” newspaper on the 12th July.
I tried to scan the info on this site, but am short on time, therefore I can not be said
to have fully made myself aware. However, I do wish to comment on what I have
been made aware of in “The Province”.

I am appalled by what I read regarding the BC Government wants: “To encourage people to buy guns and go hunting”.  “To recruit women and children to hunt i.e. (shoot to kill) animals” and not only that, but they are even “willing to drop safety requirements in order to do so”.

This is highly offensive. The reason women and children and the great majority of men do not shoot to kill is because we do not want to. Shooting, killing and maiming any life form is a violent act and is socially pathological. These are things to discourage and remove, not things to encourage.

What is Hamilton thinking. This is “drumming up business” nonsense and is self serving propaganda from a self interest group. We Canadians, the majority of us, do not want to see the letting of blood from ANY creatures, both man and animal, neither at home, nor abroad.

Should we start seminars in school then…”How to use a shotgun to kill and maim animals”? This would be socially abominable. When a youth has a history of harming animals in any way, then it is a tangible sign of underlying mental disturbance, in particular antisocial personality disorder. We know this in psychiatry.

All in all, in no way whatsoever, should there be any encouragement for people and very especially our children to shoot animals in any way or form. “Hunting” is just an old fashioned, disguised way to describe the blatant killing of defenseless animals and I believe is a violent and antisocial act. The only acceptable way in this day and age for an animal to be shot is within an environmentally sound animal control / culling program, by wildlife officers.

Please take more time to re-think and re-work the review.  I don`t think it serves the majority of the citizens or wildlife of this province as it stands.

I read the newspaper article in “The Province” on page A3 Thursday July 12. 2007 and have the following that I would like to share
1. If the Province is serious about attracting more and new hunters then the best fastest way to do this is to reverse/change the ban on Restricted Firearms for the purpose of hunting.  There is a large contingent (including myself) that is not interested in Bow or Rifle hunting but would be very interested in hunting with more challenging firearms.  I am NOT talking about Prohibited Firearms but Restricted.  This ban specifically discourages many American Hunters from making the trek here to hunt.  If BC could obtain this provision for hunting in the province it would attract a lot of hunters from across Canada and the US that would otherwise travel to a different jurisdiction.
2. The following quote is taken from the news article in question: “The proposed changes would also permit a one-time-only, single season license for the new hunters to go out with licensed hunters without taking a required safety course...”.   Please do not even entertain a reduction in safety training for hunting or firearms.  This is counterproductive and you would be hard pressed to find any serious firearms enthusiasts or educated hunters who would approve of such a thing.  Just like the current fee system is correct, the current safety system is correct.
3. Streamline the process.  Even if 20,000 people from BC completed the required safety courses the time frame for permitting is too long to allow them to hunt this fall.  For example, from talking to friends recently, the wait time to obtain your PAL after completing the safety courses and filing your application is running six to eight weeks!  The soonest that a new group of hunters could get involved with the sport would be at least 6-8 months and many would be discouraged because of this and not get involved.  There is no good reason for this, if more people are required to complete the process, increase staffing and raise the fees.  Another 10 or 20 dollars will not discourage someone as much as waiting months for access.
4. Streamline the process for American hunters and the process of bringing their firearms into Canada.  As long as their firearms conform to Canadian legislation they should be able to easily do this on entry into Canada.  They are either a threat or they are not.  Customs must be able to improve the current situation.

Just my two cents from an interested party who used to hunt but currently finds the whole process to be too much hassle.

I understand from comments made by Chris Hamilton in the Province (July 12) that a motivation for the proposed changes to the Wildlife Act is bringing back lost customers (i.e., hunters). Should we really be looking at wildlife conservation as "like any business"? I desperately hope that our government has not been so mismanaged as to be relying crucially on hunting license revenues to balance its budget. This cannot be the primary motivation for the proposed changes, unless our leaders have forgotten where they are.

Why, then, is it bad that there are fewer hunters than there once were?

It's not that BC businesses are in trouble. Gun sales have not dropped in the last decade. (One business owner quoted in the Province article I mentioned suggests that people are going to target ranges instead of hunting.) Outdoor equipment stores are not losing revenue. There are a lot of ways to appreciate the wilderness without shooting at it. BC's natural beauty is, I'd guess, what attracts most new residents: I doubt we'll ever have trouble getting British Columbians out into nature.

Thus, I doubt the problem with a decline in hunting is a lack of nature education. It's simply false that the number of people enjoying the experience of BC wilderness has dropped, despite the statistics on hunting. In fact, while it is surely possible to develop respect for nature through hunting, it is simple common sense that nature education which does *not* involve killing parts of nature is more likely to inspire respect. Furthermore, desensitization to violence against animals is a very dangerous thing. It has long been known that those who are violent to animals grow up to be violent to humans as well.

And it can't be a problem with conservation. I cannot be convinced that the best way to deal with species out of balance is to allow more hunters with less training. Who could possibly have imagined it would be a good idea to allow teens to hunt with *no* safety training?! Supervision is no substitute for safety training when firearms are involved. This is bound for tragedy and disaster. But not only are untrained youth hunters a safety risk, they are liable to shoot the wrong species by accident. Conservation cannot be the motivation for the proposed changes.

Fewer people now want to hunt than once did. I see no reason why this needs to change. I do see reasons why it would be worse if we had more hunters. As much as I would not interfere with another's freedom to hunt, I do not want to see measures taken to increase the number of hunters in our province.

Please, do not make the proposed changes to the Wildlife Act.

I have taken the time to review the wildlife act proposed changes, and it seems to me to be heavily weighted towards a dwindling hunting user group.  I understand the motivation to maintain or increase hunter numbers, but I think that the proposed changes are missing the changing attitudes of British Columbians, not to mention the stated goal of raising backcountry revenues.  The Province's approach has been to market “supernatural BC" and the "best place on earth", and to pepper the backcountry with Ecolodges, Heliski, Catski, mountain bike, hiking, and other ecotourism tenures.  These people are more the type that want to see live animals, as opposed to seeing the photos 
of blood-stained hunters posing with dead grizzly, elk, moose, or wolf.

The decrease in hunter numbers reflects changing attitudes in BC - we are moving away from the "conquer the wilderness" wild west mentality that really does define our history, and entering a more enlightened era where hunting of appropriate populations (ie white tail and elk, which are at all-time highs) are encouraged, but the base pursuits of trophy and sport hunting (such as killing mountain goat, grizzly, bobcat, lynx, wolf, cougar, etc for the pure "sport" or pleasure) are becoming less and less palatable to the general public.

I would like the proposed changes in the wildlife act to reflect these changes in the BC population, as opposed to catering to important, but dwindling special-interest groups.  Opportunities for sustenance hunting (as mentioned above - whitetail, elk) should be 
maintained, while we really do need to get with the times and begin to phase out pleasure killing", or trophy hunting of carnivores and animals like mountain goat.  It really is time to finally halt the grizzly bear hunt as well.  The latest numbers for the area where I live (the Purcells) are 50% of the MOE numbers used in 2004 for environmental assessments of major development proposals (Proctor et al, March , 2007).  This combined with all the new mining development, increasing backcountry use due to changes in recreation 
and changes in BC commercial recreation policy, huge increases in motorized recreation, mega-resort (small city) proposals such as the proposed Jumbo Glacier Resort - all of which negatively impact an already dwindling grizzly population  - requires a moratorium on grizzly hunting.

Also we need more stringent legal restrictions on motorized hunting access, to counter the massive increase in motorized users.

I would like to voice my opinion as a Canadian citizen in BC that I and many others are strongly opposed to the government plan of increasing the number of hunters in BC.

Not only does hunting promote the increase in the number of dangerous firearms, but it also condones violence and killing which is detrimental for our youth.

Newer generations have come to realize that it is far better to promote respect and kindness towards animals and our environment, rather than to promote violence, killing, and destruction.  Nature is beautiful and wildlife is an integral part to maintaining its delicate ecosystem and biological diversity.

The BC government should be promoting more acts of kindness and awareness in our society such as environmental cleanups, eco tours, wildlife watching, wildlife rescue and species rehabilitation, and general environmental awareness.

The increased revenue sought by selling more hunting and gun permits could easily be matched by increased tourism and nature program incentives.

The idea that hunting solves "agricultural conflicts" is also very flawed, as people are not hunting just outside the boundaries of farmland as if they are some sort of security guards with guns.  It is in fact agriculture expansion which is causing a threat to biodiversity by causing habitat loss. If someone came into your neighborhood and tore everything down for countless miles around you and put up crops, wouldn't you need to eat still?

The idea of obtaining organic meat through hunting is not very practical, if you consider this logic on a large scale. What if everyone were to get their meat by going outdoors and hunting wildlife? This would cause great imbalance very quickly in the fragile balance of our wildlife species, which are already dwindling due to human expansion which has destroyed much of their habitat.  It is a very poorly thought out solution to suggest everyone go out and hunt to get organic meat, rather than deal directly with the real problems related to modern factory farming and our dietary choices.

Is the government really suggesting that we all start running around, shooting guns, and killing in order to get safe organic food?

It is such a relief to see that our government understands what is necessary to promote progress and peace in a society. Certainly giving guns to everyone and promoting killing what little wildlife we have left is a step in the right direction. Brilliant.

Ref articles:
http://www.canada.com/theprovince/news/story.html?id=c7a91031-86ca-445d-8c9c-e9b9900ab5eb&k=84213

Unfortunately, seeing the information regarding this important issue is wonderful, yet the time for British Columbians to write in is very minimal.   It says in the Province newspaper that we have until this coming Sunday to comment, whereas having 1 or 2 months on the subject is truly needed, not just a few days.
I thought I would write a general comment on my own findings, of hunting in B.C. for 30+ years now, of which the majority where in the northern part of our province.

Last year was the first year I didn't renew my license, as there are several contributing issues for not doing so.   Initially it was the lack of my own understanding of the “Amnesty” of the Gun Registry, as my own hunting rifle was registered when I bought it over 30 years ago, and I personally didn't feel I should again have to “pay” to re-register it because some bureaucrat (Federal Liberal) felt that we should spend Billions of dollars on a registry that wouldn't work, and it has proved itself to not work.

Second, I feel the current “Hunting Regulations Synopsis" has become as thick as a phone book for some towns, rather than the few pages needed back when I first started hunting.
The regulations are so tight in the northern part of B.C. where I prefer to hunt, that it hardly makes the drive, and spending my hard earned dollars to make the trip any more!  
Having to actually count the tines on a moose is ridiculous and difficult, as even seeing a moose is tough, but having it stand still long enough to count so many tines is unacceptable in my opinion.    On an Elk it is fine, as counting six tines is credible, but doing so on a moose is much different, and unnecessary in my opinion.   Making it “Bull only” is fine, but the Synopsis needs revision in this area.

Again, my opinion, but I personally don't agree with the Government’s opinion regarding allowing Native Indians to basically rape the soil we all live on, regarding being able to take any wildlife they wish...with no issuance of any licensing.    We all do need to live together, and I personally was born here in B.C. as were all Native Indians of my age, yet they have rights not given to me.  
I have seen Natives on many occasions hunting in the area I hunt in, basically killing anything that moves.   I've seen hanging poles at least 100 feet long, with ropes tied every 8 inches apart for the full length, where the Natives hung these “anything that moved” carcasses.
Of course, for that year and the subsequent year we saw no animals or sign of animals for the 2 week period we where there.    Not so much as a porcupine, which where abundant previously.
We heard that they brought in reefer vans with semi trucks to take out their haul.
We've seen Natives in areas with ATV's that the rest of us are not allowed to travel in, as there is signage explaining where and where you can't go.
Again, I don't agree with this signage either, but I do not cross the line of which I once was able to do back when I started hunting.  
Unfortunately, it's not so much not being able to go where I once could to hunt, while getting there with my ATV, but it would be nice to at least use my ATV to get to areas I once could hunt in, just to go and see the countryside, and take photos.   Sure, don't allow me to hunt in a specific area, but banning ATV's, where there are currently wonderful trails that take days and weeks to travel is a travesty.    Rather than banning ATV's from certain trails, banning hunting beyond a specific spot, so that at least one can travel the gorgeous areas that have been available long before ATV's were even made!    Many of these areas can now only be gotten to by horseback, and very few of us own horses, but many of us have ATV's, which are a wonderful mode of transportation to see the outback of northern B.C.   This of course is another reason I've been reluctant to travel to my usual hunting grounds, as the restrictions on ATV's is so great these days, it hardly makes the effort worthwhile.

Many hunters like the ability to hunt several species at once, so having restrictions where these species don't overlap is another negative for hunters these days.  Getting the time off from work, spending the amount of money it now costs in fuel, ATV's, trucks needed to get there and other commodities needs to have the hunting regulations/Synopsis coincide to make it worthwhile.   Hopefully feedback generally will help in that area, so long as the current government of B.C. makes positive changes.  The Regs/Synopsis have generally been extended year after year, making the possibility of going hunting hardly a rational choice.
I don't mind coming home empty handed, which I have on many many occasions, but the reason for that is because of the multitude of regulations in the Synopsis. 

I still have a lot of years in me that I can hunt, but will only do so if it makes sense to do so, with regard to spending the kind of money it takes to hunt, along with having regulations that ease the burden, and allow me to get to areas I have to get to see wildlife!
Now that I'm getting older, I can't walk all day as I once could in my younger years of hunting, so I rely on my Honda ATV, as so many now do at my age or older.    Making it harder for us to get to these areas then makes us wonder if it's worthwhile.   It hasn't in the past year or so, so I hope many positive changes are made in the near future so I can do what I love to do, and that is foremost seeing the gorgeous countryside of the northern part of our Province, and secondly to hunt.   
My kids have now grown and are at a time in their life where they are either moving out of our home, or not eating red meat as we once did, so truly harvesting an animal is not paramount, having the ability to see the wildlife deep in the outback of the north is what I find most appealing.    Please find it within you to open up the country more for ATV use, rather than restrict it as you've done in the past.

As a member of the Sapperton Fish and Game Club, Past President and now Hunting and Trophy Chairman, I have the opportunity to talk to many people about their hunting experiences.

I have found that there are many past hunters who have not renewed their licenses due to the fact that they had a license many years ago and there are no local government offices where they can go to get their new license.
Also a renewal process for outdated FAC's would allow Dads and Moms who have been busy raising families and paying mortgages to now buy new equipment and take the whole family for an outing.

Many have said they don't bother because their in their 60's and there isn't much time left to go through all that trouble to get their license.  Maybe drop the license fee at 60 years old from 65 years.  This may get Grandpa out with the grandchildren while he still can.

I first went hunting with a Christian group from Young Life. I got my license at 16 with this group and have had it ever since.
Encourage youth groups to go hunting by supplying leaders and C.O.R.E. program training, follow the laws and participate in group activities.

If there is a problem area encourage hunting in these areas for minors and offer the Fish and Game Clubs some incentive to take small groups of children for a hunting trip.

I support this proposal. I firmly believe that sustainable hunting is good for the environment, economy and represents the traditional activities and culture of both the Canadian and First nation culture. Hunting has been an integral part of all cultures and helps maintain a strong bond to the land and to the ecosystems on it. In order to promote and sustain hunting by all people the infrastructure to support the activity must be in place.

The infrastructure includes:

More Conservation Officers with financial support to carry out their mandates and to control poaching by all groups.

Ranges and gun clubs
The Provincial government must support and protect gun ranges and clubs. These are the incubators and schools for future hunters. Currently gun clubs and ranges are under attack by municipal governments and other groups. A prime example is the very hostile and anti-firearm position of the GVRD who is intent on closing all ranges in their area for purely social-political reasons. Support can come from political pressure to prevent local governments from blocking ranges, making it easier to apply for land leases and reserving areas for the activities.

Chief Firearms Office
Support the Chief Firearms Office. The staff in the BC office have been very good and have some of the best people skills I have met in the government, but they are very understaffed and need support to carry out the requirements. Also the CFO should be instructed by the AG to proactive and supportive in their approach to firearms issues.

Environmental assessments
I have witnessed numerous times when environmental assessments have asked for proponents to have a “no firearms” policy. This can have a negative effect on the ownership and use of firearms for target shooting and hunting. While poaching and over-hunting are important issues, a “ban” on firearms is too restrictive and this sort of anti-hunting attitude should be dealt with.

CORE program
Monies should be made available for schools in rural communities to hold these course, plus school policies should be reviewed to ensure there are no obstacles for courses. CORE programs in urban communities need support to push through anti-firearm/hunting attitudes and restrictive polices.

Laws and regulations
Currently it is very difficult for firearm related businesses to operate, restrictive, conflicting and confusing Acts and regulations need to be streamlined to ensure a safe, efficient system that does not unnecessarily block economic activity.

Gun Registry
The current long gun registry is deeply flawed and very expensive to operate for quite questionable benefits. These monies would be better spent on CORE programs and anti-gun smuggling police operations. The Provincial government should make it clear to the Federal Government and the various Police organizations that they do not support the long gun registry.

The current firearm training course for the PAL is adequate.

Hunting with handguns
Hunting with handguns is quite common in other parts of the world and there is a large number of makes and models offered for this sport. There are no ethical or safety reasons to disallow this type of hunting. In fact the danger radius of bullets fired from a handgun is far less than a high powered hunting rifle.

Authorizations to Carry type I  (ATC I)
The current ATC I only allows for the carrying of a sidearm while engaged in worked related duties in remote areas. This should be expanded to allow for sidearm carry for people engaged in recreational activities as well. I highly doubt that any predator will care if you are working or hiking! This would also allow Bow hunters to carry a sidearm for personal protection and for the humane dispatching of wounded animals. It would likely also be a required change to allow handgun hunting.

In conclusion I am pleased the government has recognized the importance of hunting to our culture, communities, environment and traditions. I hope also that the points I have raised are given due consideration and are implemented in whole or part. Thank you

At this important juncture with regard the B.C. Wildlife Act Review I appreciate the opportunity to comment as follows.

I think it is very important that we get the right legislation in place and therefore would ask that we take the time necessary to consult with as many stakeholders as possible.

In this spirit I would request that the review body go to the various interest groups like the Conservationists, Eco-Tour Operators, Animal Welfare Groups, Wildlife Rehabilitators, First Nations and Rod and Gun Clubs etc…to review the current Wildlife Act so that when changes are made they are well thought out and bring out opinions from all sectors.

At present it seems the proposals in the discussion paper are heavily biased toward the hunting outfitters and toward self regulation and increasing the numbers of animals killed.  Please take the time to re-think and re-write the current proposals in order for this document to serve all British Columbians and future generations so that B.C. remains “the best place on earth”.  Thank you for your time.

For many years, I lived and hunted in Ontario. In that jurisdiction, when a group is drawn for a moose, they are awarded one tag regardless of the group size. In addition, all of the party can hunt calves. The advantage of this is that it allows more hunters in the field without more moose being harvested. Perhaps this idea could be explored so that hunters would not have to wait so long between draws before they are selected. Ontario also has a minimum group size guarantee. I.E. if a group is of a specified size, they are automatically awarded one adult tag.

I am grateful to be able to pore over this before it takes affect and allow my opinions to be heard. Although I do not live anywhere near the area discussed within the Wildlife Act, I am a huge contributor to its tourism. I come out to BC specifically to view bears and because of the plentitude of other species I am also most appreciative to see them as well. I feel that because my main reason for visiting BC is to enjoy its plentiful wildlife, that I am at right to explain how I see the new propositions within the Wildlife Act.
I reside in New York City. I go out to Canada twice a year, for three weeks at a time.
Thank you for the privilege to be heard. 

“Modify the hunting licence system to facilitate hunting on agricultural lands to control problem wildlife.”
”Enable measures to ensure that members of the public that respond to wildlife conflicts (e.g. trappers, hunters) are qualified to assess conflicts and properly remove, capture and handle wildlife.”
This seems like an open invitation for ranchers, trappers and individual land owners who are not educated in how to properly assess a situation and will in most cases, educated or not, make a rash decision to killing problem wildlife simply out of convenience. Supervision is necessary. Without it, we are dependent on a sole individual's opinion regarding the situation no matter how docile or feral it is. Again, most will use a measure of convenience instead of handling it in a responsible manner.     

"The preferred approach is to prevent wildlife-human conflicts from happening in the first place. Some of these problems can be addressed through public education and support for municipalities regarding appropriate handling of garbage to avoid attracting wildlife, however, there is limited capacity at the provincial or community level to encourage compliance."
Mandated use of bear proof containers should be paramount in areas where wildlife and humans coexist. Sanitation departments should push back pickup time so that people can put their garbage out in the morning before work so that trash is not left out over night. People are attracted to the beauty and wildlife of BC and should be aware and responsible for doing their part to keep it that way. Fines for non compliance should be given without a doubt.
For instance, in the city of New York, it is a "city rule" to use alternate side parking as a means to allow street cleaners to do their jobs in keeping the streets free of debris that accumulates every day. Non compliance of this law provides the owner of the vehicle a fine. Cars are not allowed to block the "black box" and are fined. People are not allowed to cross at busy vehicle crosswalks and must make detours to cross else where. Recycling is mandatory and in most cases with responsible dwellers this entails two extra garbage cans and three separate types of plastic bags, inconvenient, yes, but environmentally sound. This is part of living in a big city. There are plenty of other inconveniences that people must comply with if living in the city is something they truly enjoy. These examples, though in other forms, are comparative to living a life in BC where wildlife is abundant and must be dealt with in a responsible, fair way using the provinces resources as a boundary to how you live.       

 "Farmers employ methods that scare off conflict animals or sometimes kill animals that damage their crops, or kill or harass livestock."
"The remains of animals involved in wildlife-human conflicts and those that are killed in vehicle collisions cannot be owned without applying for a permit. Animal control business operators who euthanize nuisance wildlife, individuals who find road-killed wildlife, and landowners who kill wildlife that damage their property, crops or livestock, cannot own the nuisance animal carcasses and cannot sell them. As a result, the modest value of these animals can be lost."
In one sentence it is stated that "animals involved in human-wildlife conflict...cannot be owned without applying for a permit" and then it goes on to say that, "animal control business operators who euthanize nuisance wildlife, individuals who find road-killed wildlife, and landowners who kill wildlife that damage their property, crops or livestock, cannot own the nuisance animal carcasses and cannot sell them." Which is it?  I believe that all wildlife not killed with a hunting permit and not reported is a form of poaching. At the very least, IF an individual kills an animal due to conflict, it is mandatory that it is reported. How can you regulate the population of a species when undisclosed information is withheld knowing full well that a percentage of animals are taken illegally as it is?  
Considering the statement above, agricultural and live stock lands should be mandated in the use of electrical fencing and other predator deterrent systems. Though financially it will seem a burden but in the long run it will allow protection for both predator and farmers securing safety and avoiding conflict all together, therefore, in the end, saving money AND wildlife.
Instead of allowing individuals to own "road kill", why not use this as a form of sustenance for bears and other wildlife who are forced into towns in search of food due to lack of natural resources? This has proven effective in Alberta. Instead of making it harder for BC's wildlife, why not make it easier. It makes BC a positive influence to other areas by exhibiting compassion and responsibility to their wildlife.    

"Allow ownership of dead wildlife caught by nuisance animal trappers and those protecting their property."
On another point, allowing individuals to use their own judgement can be a huge conflict of interest and can open the gates to these individuals to seek out "problem" animals or animals in general to add to their collection of trophies using the excuse that the animal was causing disagreeable harmony with property, live stock, apiaries, grains, etc. Opening the gates to this could potentially lead to undesirable poaching.

"Hunting is a traditional and legitimate use of wildlife in B.C. First Nations people have hunted for sustenance and for social and ceremonial purposes for thousands of years. Hunting is a valuable outdoor recreational experience that promotes appreciation for and understanding of wildlife species and their habitat in the natural environment. Through the Hunter Recruitment and Retention Project, the Ministry has set a target of increasing the number of hunters in the province by 20,000 during the next 10 years. Part of this strategy will involve restructuring and streamlining the regulations and looking at changes to the licensing system."
If hunting is indeed a "tradition" then "recruitment" of hunters is an oxymoron. Tradition dates back many years and is passed on from generation to generation with a few who drop the tradition along the way. Recruiting hunters as if it were the sole purpose of enjoyment to animals is a step back into the past. Tradition can flow on it's own accord without the help of those who consider BC's animal population as a means of amusement, aggrandizing and "way of life". To my knowledge hunting in rural areas was a means for the area to gain financial freedom in some aspects. Now you are proposing that licenses be lowered. So, I can only surmise that BC is happily allowing slaughter simply for amusement purposes. Not only is it disheartening to know that BC has an actual Ministry that recruits and supports hunters but that they see their animals as crops (harvest?!). I am not anti hunting and do believe that people who use hunting as a means of sustenance should be allowed to do so if that is their only way of gaining food. However, hunting predators is merely for "bragging rights" and "trophy displays". This is not how I ever pictured BC.  This Ministry and the Wildlife Act should be doing all it can to protect its wildlife and the surrounding habitat NOT focusing on how to recruit more hunters. 
As it stands, the spring hunt on bears is unregulated and many bear cubs are left orphaned or shot along with mothers. This is an atrocious way to show that BC cares and respects its animals. The spring hunt should be halted.  Many hunters can't even tell the difference between a black bear and a brown, let alone differentiate sexual orientation!    

"amend the act and regulations so that they reflect new methods of hunting and new hunting tools."
New tools? New methods? Hopefully these methods and tools still reflect the fair fight. Not that any man with a high powered weapon and a bear a half mile away is considered a fair fight. I don't understand this passage at all. What tools, what new methods? Out of car?

"modify the hunting licensing system for junior hunters."
Modify? Lower than ten? Ten years old is too young as it is. At that age they are not able to make their own decision. However, I know this is a battle I will never win.

"one-time-only hunters to hunt without having to take the CORE exam."
How many times is one time?! How will you regulate this??? Everyone who absolutely feels the NEED to hunt should be required to take the exam. No ifs, ands, or buts. IF it is that important to them then they will take it.

"a successful limited entry hunting applicant can share his hunt with a partner." 
No way. So, not only are you lowering the license price but now you are allowing TWO people to hunt on one low cost license?! Absolutely not!

Why are you pleading on your knees for people to hunt? What the heck is going on out there! BC is the symbol of beauty, the wild, flourishing habitat and somehow you seem to want to destroy this. Surely you can gain finances through photography, tours and so forth in this day and age when people are finally realizing how precious our lands are and the wonderful experiences it can give us. Why are you reverting back in time?  

"provide for a taxidermist licensing system that includes the ability to export without the need for specific export permits and requires taxidermists to maintain detailed records concerning ownership of all wildlife handles."
No, this is an open invitation to poaching again.

There is an awful lot of emphasis in the hunting issue. This is definitely NOT the reason I visit your area, quite the contrary. Please know, that as an "outsider" I cannot tell you enough how beautiful I think your country and especially the BC area is. I look forward to my trips out every year and have always thought that BC respected and protected its animals and habitat. I am appalled that there is a "committee" that focuses on the recruitment of hunters! I can't get over that. I had no idea. I can win my bets that no one else I know who visits the region knew this either. Please reconsider some of the changes and make them lean towards the positive side of BC's land. I have only the highest regard for BC and wish for it to remain that way. Simple revision can be made to ensure that predators can become less of a nuisance and more of a magnet to drawing in people who have finally realized outdoors. More community education, regulation and respect for wildlife should ensure that these animals will remain a constant symbol of BC's pristine lands. Please don't ruin this for the outsiders by turning this into a battle field of paranoid farmers and "itchin' at the trigger" hunters. That is not my vision OR my experience of BC.

My name is Randi Olson and I live in Squamish, BC.  I am also a volunteer with a local Bear group. 

There is no such thing in my opinion as a nuisance animal, man is the nuisance which needs to be controlled!

As an animal lover it sickens me to know that hunters can kill black bears in the spring when sows are out with new cubs, and could possibly kill the mother leaving cub or cubs to die a horrible death!   That is not the way mother nature intended it too be.

I have no problem with people that hunt for food and use all of the animal they have killed but when it is for certain parts of the animal for trophy purposes that is sick!  Wild animals need and deserve respect, not a bullet in the head!  

If changes are made to the Wildlife Act will the Government provide more CO's?   Our community only has a few and they are spread very thin, spend money on more Conservation Officers.  The CO's are essential in protecting our wildlife from poachers etc, but with only a "few good men" how are they supposed to keep tabs on the new changes?

The government needs to take more time to re-think and re-work the review of this important document.  Before the Environment Ministry staff take their proposals to the MLA’s for approval many sectors of our society should be heard from and proposals should reflect current attitudes and values of as many British Columbians as possible.

At present the Discussion Paper and the Hunter Recruitment and Retention Report are heavily biased toward one or two special interest groups”.

Placing a gun in the hands of a 10 year-old is a blatant grasp for revenue by the government.  We no longer hunt for sustenance but only for entertainment. Consider this quote from Rudyard Kipling:  “The reason for killing an animal is only either having to eat or keep from being eaten”.  This is a simple, timeless statement concerning the respect for animal life.

The review and change to the Wildlife Act may take our society's values to an unprecedented low by placing lethal weapons in the hands of children. It is hoped that saner minds may prevail and not facilitate the killing of more wildlife in a shorter period of time only to increase government revenue.

I believe more conservation officers must be hired, the number of officers we have now is woefully inadequate. What is the use of new wildlife Act without people on the ground to
enforce it?

Regarding the Wildlife Review Act This Report seems to suggest that the Ministry of Environment has a mandate to set a goal of "recruiting" 20,000 hunters to BC over the next decade and to do so by streamlining regulations across the province along with many other suggested proposals found in the following "Hunter Recruitment-Retention Report".  The purpose is to make hunting cheaper, less restrictive and ensure it to be a quality "cool" experience. It is inappropriate in the extreme that the Environment Ministry has a strategic project in mind to "recruit" and increase the number of hunters to this province by 20,000 over the next decade while speaking about conservation at the same time.

Who wrote this report and where is the input from interest groups like the conservationists, eco-tour operators, animal welfare groups, wildlife rehabilitators, first nations and rod and gun clubs etc…to review the current Wildlife Act so that when changes are made they are well thought out and bring out opinions from all sectors. At present the proposals in the discussion paper are heavily biased toward the hunting outfitters and toward self regulation and increasing the numbers of animals killed.

I am also concerned about the lack of SARA-species at risk protection, habitat protection, self-regulation by hunting outfitters, and self management of nuisance animals.

The proposed expansion of the Spring Bear Hunt puts British Columbia back into the dark ages of resource Management and leaves us sadly lacking on the International scale of habitat protection, eco tourism.  The world is watching us and any spring bear hunt should be cancelled not increased.

Re: lowering age for hunting licences and plan to increase numbers of hunters
a) Animals are not just a resource that can be harvested like trees or wheat.
b) They are living, breathing, intelligent mammals who can experience pain, fear and joy.
c) Polls confirm that 57% of Canadians oppose big game hunting.
d) Hunting is a carry over from our days as stone age primitives when we needed meat for sustenance.
e) Now hunting is for the most part a Hunt Cult. Man's aggressive instincts lead him to this “sport”.
f) The few families that require hunting for food is small. The others would be wiser to invest the money saved by not purchasing firearms, licenses , hunting clothing, travel etc. in sports  and activities that do not have as their endpoint, the taking of  life.
f) The percentage of deer that are wounded and escape to die without being recovered is unacceptably high.

WE DON'T NEED YOUNGER HUNTERS AND WE PEACEFUL LOVERS OF B.C. NATURE DON'T NEED MORE PEOPLE IN OUR NATURE TRAILS, ARMED AND READY TO SHOOT ANYTHING THAT MOVES.DON'T AMEND THE AGE REQUIREMENTS FOR HUNTING

2) Temporary permit without CORE certification to try out the sport.
a) You are not just encouraging youngsters and others to become interested in a non violent sport like bowling, golf, tennis, rock climbing, hiking.
b)You are giving people permission to carry firearms and to terminate the lives or seriously wound our animals by firing a projectile through their body
c)They have their own troubles and their own natural predators.  Nature doesn't need our help in regulating the ecosystems.

THIS IS A WRONG MOVE. KEEP THE STANDARDS AND REQUIREMENTS HIGH. YOU ARE NOT JUST INTRODUCING INDIVIDUALS TO A SPORT LIKE TENNIS, GOLF, BASEBALL. YOU ARE GIVING THEM PERMISSION TO END THE LIFE OF A LIVING CREATURE AND TO CARRY A WEAPON THAT CAN KILL INNOCENT HIKERS AS WELL AS WILDLIFE.I DON'T OBJECT TO SUSTENANCE HUNTING BY NATIVE PEOPLES BUT I THINK TRYING TO ENCOURAGE MORE INDIVIDUALS TO END THE LIVES OF MORE ANIMALS IS MORALLY WRONG

3) Trapping
a) Although  you want to amend the Act to allow more information from trappers re: type of trap etc.  I see no mention of the trappers being required to attend courses on the humane trapping of fur bearing animals. That is, if a moral human can call trapping a beaver underwater and letting him drown, “HUMANE”. The American Veterinary Medical Association states that drowning is an unacceptable and cruel means of killing an animal.

ENSURE THAT THE TRAPPER HAS PASSED A COURSE IN THE HUMANE TRAPPING AND KILLING OF FUR BEARING ANIMALS

4. Viewing of wildlife.
a) You say that you are committed to protecting wildlife from the “dangers” caused by observing them. I find it hard to imagine these dangers. Whales and West Coast harbour seals and other marine mammals are covered by Federal Legislation
b) This appears to be an oxymoron. That’s like the Federal government, which kills 300,000 seals cruelly each year, telling us the regulations governing the slaughter are called the Marine Mammal “Protection” Act. Who is “protecting” them from the killers.
c)  Wildlife will be less disturbed by observers with cameras then with firearms.

SUMMARY: Yes the fur trade helped our nation grow. However we don't need natural fur now. Where are all the Sea Otters in my Otter Bay? They have been wiped out by fur trappers. I don't object to sustenance hunting by native peoples but I believe that trying to promote the killing of more animals for sport to be morally wrong.

As a member of the general public, I feel that that the Review was not inclusive enough of the voices that need to be heard. The present Discussion Paper and the Hunter Recruitment and Retention Report are, in my opinion, heavily biased towards a couple of interest groups.

In the interest of long term vision and inspired leadership, it is worth rethinking, reworking and reflecting on the proposed suggestions. It could be much better. In the pursuit of excellence this current document should be considered a starting point.

I would like to ask that the government take more time to re-think and re-work their review of the Wildlife Act.  Before the Environment Ministry staff take their proposals to the MLAs for approval many sectors of our society should be heard from and proposals should reflect current attitudes and values of as many British Columbians as possible. At present the Discussion Paper and the Hunter Recruitment and Retention Report are heavily biased toward one or two special interest groups. 
Please respect our wildlife and wilderness spaces.

This review is timely and contains elements that smack of common sense.  Increasingly,  urban communities are losing touch with the fact that the hunter/fisherman is the most cost-effective wildlife management tool available to the MOE.

The necessity and the economics of wildlife management needs to be more effectively communicated to urban areas as their ignorance of the issues is alarming.

GO's have recently been perceived as refusing to fly resident LEH draw holders into areas within their territory. This can take the path of being the airlines principal customer and suggesting certain lakes are not flown into.

In the Spatsizi, for example, this can create a virtual no access situation for residents trying to hunt Crown Land. I recognize the GO's desire to protect their investment for high paying non-resident hunters but have difficulty with the concept that a resident can be blocked out. GO's should not have an effective monopoly on public land.

As Gandhi aptly said, “The moral greatness of a nation can be determined by how its animals are treated”.

Hunting is inhumane, further endangers we humans when orphaned bear cubs wander into our neighbourhoods looking for food. Killing mother bears creates a vicious cycle and the government needs to think of the long term, not quick, reactionary, bowing to whatever pressure current hunters may be placing.

Be strong and simply say no.

I am unsurprised, but again, disappointed, in this government's perspective on the world. Although you have tried to present your philosophy and world view differently in the last couple of years, your current world view, dating back some time, is essentially the same as it has been for many years:  our forests, oceans, rivers, and wildlife are primarily commodities. In your collective perspective, every cent helps you build more highways ... For the benefit of .. let's see what sector of the population ?

 Must everything boil down absolutely to revenue for this Government?  I am positive that if you gave the revenue generation issue  focused thought, you would come up with an eminently defensible position other than advocating more trophy hunting, the latter which will,  quite frankly, embarrass you in the long run. It may surprise you to know that many people simply do not believe that wildlife and nature exist to be exploited as thoroughly as possible by a Government endeavoring to collect as much money as possible for the Provincial coffers. Guess what? It may be that the decline in sports/trophy hunting popularity is explainable by the simple fact that people feel uncomfortable with the thought of  killing beautiful living creatures of God  for sport, or for trophy.

I love B.C: I was born and raised here, and will live here for the duration of my life. I am exceedingly proud of the extraordinary natural beauty in this Province, and the beauty of the wildlife. However, I am embarrassed that people  trophy hunt here, and I am embarrassed that my Government advocates trophy/sport hunting as a means of revenue generation, particularly when there are so many other avenues available in a place as richly blessed with natural resources.

First, we don't have nearly enough Conservation Officers in the field to enforce the regulations we do have, and relaxing the rules will only make their job more difficult than it already is; To ensure the sustainability of wild animal populations, you would have to spend considerable money to improve the training provided to Conservation Officers, and to increase the number of Conservation Officers out there.  What are your plans, if any, in regard to the latter two concerns should you increase the number of hunters, particularly inexperienced ones,  in the field? In my view, the Conversation Officers in the field right now need more training than they display currently in the laws of the land so that we can be assured successful prosecutions of offenders. Increasing the number of hunters out in the field without increasing both the number of CO's and improving the legal quality of the work they do will result in the overall decline in our wildlife populations without penalty

Second, our wildlife are in decline; there is simply not enough wildlife out there to allow for increased hunting; Development in areas formally inhabited by wildlife has caused wildlife habitat to be endangered. We should be doing whatever we can to preserve populations and territories inhabited by significant numbers of wild animals, and to decrease human contact with wildlife.

Third, there are many other ways to develop revenue generation besides something as controversial as advocating trophy hunting as a source of revenue: Why on earth are you not looking to find ways to attract clean and green industry to this province which will provide jobs, generate revenue, and contribute to the development of B.C.'s positive national and global  image. ...

Fourth, I simply cannot believe that you are actually contemplating encouraging more youngsters, 10 -18 years, to be in possession of guns for the purposes of trophy hunting. First, there are other, more intellectually stimulating ways for children to spend their time than killing animals for sport.
Second, Deadly violence perpetrated by youth against youth, or youth against adult, is rampant enough. Facilitating the use of firearms by inexperienced youth may increase the likelihood of accidental and intentional violence by youth against others.

There is more to governing than money gathering, which, while extremely important, is not, without limits: This fact seems, perennially, to be  lost on  this Government...
Don't get carried away by the lure of easy money earned in this manner. There are other ways to improve revenues. Following this path will come back to bite you, as it were.

Yours Truly,
A long time Resident of B.C. who loves nature and spends as much time as possible enjoying the beauty of B.C.

When is the government going to wake up and understand that the natural beauty of British Columbia - you know - Super Natural British Columbia - is what appeals to everyone worldwide?  Killing off the wildlife, and making our forests unsafe to hike or camp in for fear of being shot (I know people who have had their dogs shot when out for a walk) isn't going to help tourism at all.  It also makes British Columbia a less desirable place to live.  Why even consider such a primitive concept - forward thinking governments all over the planet are promoting ways to live in peace with the other inhabitants of their lands - and here we are in BC talking about increasing hunting.  We criticize third world nations for killing off their elephants and tigers, yet here we are no better.  Do you really think the rest of the world doesn't see that?  Aside from all of that, are you aware of how the psyche of a hunter is twisted to deal in death?  I don't want people comfortable with killing sentient beings around my family or my children, and I am not the only one.  You teach a child this and what comes next?  We have enough problems with the youth in this province.

I am highly opposed to the government’s proposal to increase the amount of hunting in BC.  There are good reasons for the decline in hunting over the last few decades.  Many people have become more compassionate and do not wish to incorporate violence towards animals in their recreational lives.  Their compassion is totally indifferent to the economic considerations of the government.  Whereas the government views wildlife as a resource from which to profit financially, those who refuse to destroy it tend to see wildlife as intrinsically valuable, something that humans should be trying to sustain without causing suffering and fear to individual animals that make up wildlife populations.

What would it be like to live in fear all the time?  People sometimes experience fear, but this disturbing emotion is not usually based on direct physical threat.  Conversely, animals in the wild live in truly perilous conditions, mainly because of human activity.  Animals that are hunted face the possibility of dying at any time, either quickly or slowly, if the shot does not kill them right away.  Some targeted animals are not killed and have to endure the agony of  major wounds.  These wounds would bring about much concern were they inflicted on humans, but since wild animals are the ones that suffer them, there is no compassion to be found.  Wounded animals suffer their plight alone.  On top of these considerations, young animals are at risk of losing their mothers, a tragedy that leaves them helpless and full of sorrow. 

Instead of trying to increase the amount of hunting in BC, we should be rejoicing in the knowledge that many people are too compassionate to destroy wild animals.  We should work on reducing the number of hunters even more so that future generations of wildlife do not have to live in quite as much fear as their ancestors faced.

I have been reading of your proposed changes to the Wildlife Act that would, essentially, allow and encourage more hunters to take up the "sport" in British Columbia.
Frankly, I am appalled, that in this day and age, a progressive province like BC would actually consider taking such a huge step backwards in terms of animal rights.
It seems like your primary motivation is to increase revenue, but that alone doesn't sound like a good enough excuse, so you throw words around like "conservation" and "wildlife infringement on human areas".  The bottom line here is this:  If humans weren't so selfish, careless, and reckless when it comes to our stewardship of this planet, the animals wouldn't need "culling" and "conservation measures" to control their populations or their infringement into human areas. 
Leave the animals alone.  Stop the killing.  Discourage hunting.  Let nature take care of itself.

“B.C. wants to see more hunter gatherers”/ “Easier rules, roadkill ownership are under consideration”
Larry Pynn, Vancouver sun, Published: Wednesday, July 04, 2007


Not sure whether this is a sick joke, a joke, or just sick.  “. . . the government hopes to reverse a trend against hunting.”

A reduction in hunting may mean that we succeeded in educating our population to regard animals a part of this earth, to live and let live, not as a commodity to be killed for fun and maximum profit.  Along comes the Provincial Government, wanting to reverse the trend.  From preservation to exploitation.  For profit.

“The government is looking at initiatives that would make it cheaper and easier for young and new hunters to get into the sport”

One has to be desensitized to violence to some degree to derive joy, or an ego boost, from killing animals as a “sport”.  It seems to me our young are desensitized enough to violence in this brutal world.  Along comes the Provincial Government, wanting to desensitize them more.  For profit.

“. . . the sport encourages people to care about the outdoors” -by tearing through the wilderness on trucks, snowmobiles, ATVs

As to the “sport” of hunting with bow and arrow: miss half the time, and leave the animal to die a painful slow death with an arrow stuck in it.

As to road kill: tear through the wilderness on trucks, snowmobiles and ATVs, night-vision equipped, blind the animals, run them down, and claim road kill.

It seems this Provincial Government cannot tolerate a natural resource without wanting to ravage and exploit it to the maximum.  For profit.  We could cite enough examples.  Wildlife viewing, eco-tourism is not good enough.  The wildlife has to be killed.  For profit.

If the ideas presented in this article are a joke, then I apologize for my letter.  If they are for real, then they are really SICK.

As a concerned citizen for the environment and biodiversity, I agree that the Wildlife Act needs to be revisited and updated.  However, I strongly disagree with the Hunter Recruitment Retention Strategy that advocates for a massive increase to the number hunting permits. I believe that increasing the number of permits to 20,000 in 10 years is unsustainable.  With the continual loss of the environment through urban sprawl, primary resource extraction, and natural disasters such as forest fires and infestations this action would devastate and severely impact the existing and future animal stocks. Maintaining a healthy ecosystem and eco-based economies relies on sustainable environmental practices.  I implore that the government reconsider more conservation based policies and advocate for the restoration of biodiversity instead of destroying it.

As a former classroom teacher of 10-year-olds, and as a registered nurse, I implore you to reconsider this foolishness! Children that young are barely out of the “eating glue” stage! Are you totally serious???? Why would you allow them legally taking a killing instrument in their hands?

Please, don't let your common sense be subterfuged by politics. Guns by any terms are meant to kill. Call them what you may, and I know there is much wrangling, but they are what they are -instruments of deaths. Would you trust your 10-year-old offspring to make a decision like that? If it was a decision involving a flash of color, etc. in the brush? Would you, personally, want to be out there at the far end of that scope?

Let's please, all be reasonable!

According to a recent newspaper article  in the Vancouver Sun, the ministry for the environment is encouraging more hunters in BC. Hunting is a barbaric and despicable form of “sport” and instead of encouraging it , it should be banned outright.  People in general no longer need to hunt in order to survive so it is now merely a form of recreation.  One would hope that our government members, who presumably are relatively well-educated, would realize that the majority of people now regard our remaining live animals as a resource to be treasured.  Wildlife viewing is becoming more and more what people seek and are willing to pay for.  If, as it seems evident, the almighty dollar is what is motivating the ministry in it's latest move toward hunting, why not take the road to encouraging preservation/conservation?  Be “ethical and humane” and let the living live.

More Hunters in BC!!

The number of hunters has declined not so much for a negative attitude from the public but much more because bad wildlife management.

Our governments, during the last two to three decades, have done very little to control our predators. The animal rights activists seem to be in full control of our government agencies responsible. The situation on Vancouver Island where the mule deer population has been reduced to about 50,000 from the previous 250,000 is a good example. However, unfortunately, this is the situation in several other areas of BC. Leave the predator populations to explode, the ungulate populations will decline, and over time, the predator population will decline as well.

When the hunting opportunities decline, the hunters stay home. The BC hunting statistics clearly show this trend. If the government wants to create more active hunters, it has to concentrate on predator control. The number of predators, wolves, bears and cougars, has to be reduced so that the survival rate of the young ungulates gets up to above the 50%. At the present, the survival rate may be below the 30% to 25%.

For sure, the government has some PR to do. However, if it does not outperform the activists here, and have the guts to do it, we will continue to see a decline in hunter numbers.

The hunting opponents and the media seen to believe that leaving our wildlife alone will give more opportunity for wildlife watching. They do not understand that sustainable use of our wild resources will benefit the wildlife watchers as well as the hunters.

We hunters have been told that “it is not acceptable to kill an animal of one species to the benefit of an animal from another species, and it is completely unacceptable to kill just one wolf so that the hunter can get more deer to kill”. This is the basis for wildlife management in Beautiful British Columbia.

It is not only in BC that there are big problems. It has been interesting to follow what is going on in the far north. There they about 15 years ago had a caribou herd counting about 400,000 heads. At the same time they had a wolf population of 15,000. Each year, the hunters and trappers used to take about 1,500 wolves. This was sustainable hunting which just maintained the balance of the species. Then, the last year when the wolf hunters had taken about 900 wolves, the animal rights activists found out. They heralded this “wolf kill” as the biggest in the world. What did the politicians do? The run for cover and banned the wolf hunting.

During the last few years, we have seen articles in the Vancouver Sun and in some magazines, where the columnists are writing about this herd of caribou which has now declined to about 200,000. They claim the “scientists” cannot explain why, but they think it is because of “Global Warming”. Not a word has been mentioned about the wolf population. Having not been hunted for 15 years, the number of wolves in the area may now be in the order of 60,000 to 70,000.
Try to call the wildlife manager for the area, and he will hang up on you.

I do not expect our government has the guts to do the right thing, and I do not expect that our BCWF will be of much help. For sure, just avoid to talk about the wolf problem will not solve anything.

We are now living in the 21st Century.  There is absolutely no need for untrained people to go out hunting and this is certainly not something children need to partake.  If the only reason that the wilderness and forest is there is for people to go and kill animals then there is no need for it.  Kill every animal, flatten the land and build car parks and condos on it.  If the lands are there for the animals to live in peace and for people to experience the glory of nature then let the only shooting be done with a camera.  If people have a desperate urge to kill animals then let them work in a slaughter house.  If people need to
shoot then let them go to a firing range.  If culls of wild animals need to happen then let them be carried out by highly trained, efficient marksmen.

I would be very concerned at a society that allows 10 year olds to shoot animals. Cruelty to animals in a minor is often a route to domestic abuse as an adult in the future.  Once that line between what is right and what is wrong is blurred then it is usually a downward spiral for that individual.

Have no fear for your great and beautiful wild lands.  People will always want them.  Even if they don't visit them they will have a great sense of pride just knowing they are there.

Let these animals live their lives in peace and harmony with man.  We can appreciate them without having to shoot and kill them.

Very respectfully yours,
On behalf of the voiceless and the innocent

I’d like to see very stiff fines and loss of licenses for illegal hunting and fishing activities.
I’d also like to see where a person can be hired on as an Conservation Officer Helper, with all the boomers retiring and looking for part time work, its a great place to find people who want to work in the outdoors, myself included, I'm 61, I want to retire from my boring job, a part time job concerning wildlife would be perfect.

I wish to comment on the issue of ramping up the numbers of hunters and allowing ownership rights to roadkill. I do not believe in these recommendations contained in a Wildlife Act review. I believe there is no validation to increasing the numbers of hunters, thereby increasing the numbers of animals shot. Your statistics show there was more revenue generated by wilderness tourism, etc.
The idea of making hunting cheaper and easier for young and new hunters is absurd. First, the Western Canada Wilderness Committee states there is "simply not enough game in the province to support the growing number of urbanites. For them, wildlife viewing is the better option. Second, why can't you consider roadkill going to food banks for the poor instead of individuals who have run over the animal. Third, extending the age range for junior licenses and allowing one time only without the requirement to take the Conservation Outdoor Recreation Education exam is ridiculous and dangerous to other hunters.

If we didn't have enough killing of defenseless animals, now the Liberal government is making it easier for hunters to kill even more. This is such a disgrace and another blight on our beautiful province.  It disgusts me that everything boils down to the almighty dollar.
If you really want to make British Columbia the Beautiful, then ban all hunting and let those miscreant hunters use their time to help the needy.

This document, while appearing to be yet another step forward towards improving the wildlife environment, is a biased effort to give certain humans who profit from the exploitation of habitat and habitants, an easier time in doing so. It is clearly fuelled by these exploitative groups and has little interest in doing anything other than using wildlife to serve their interests.

It is obvious that this government is not capable of addressing the concerns of its constituents in a fair fashion.

While I’m in full support of introducing regulations around the keeping of exotic animals -that's something that's long overdue- I am flabbergasted by the ministry's idea to make hunting in the province easier.  Have you checked your calendars lately?  This is 2007, not 1807.  Instead of considering ways to making killing wildlife easier, the ministry should be thinking of ways of protecting them- of introducing more legislation to protect endangered species and their habitats.  Not to blast them to oblivion.  And to suggest that hunting somehow fits into a green ethic because it's “organic” is, frankly, downright insulting.  We may be prepared to fall for some things, but not that.  So do your jobs.  Recognize that hunting is no way to accomplish anything (except perhaps to help a few old guys get off their tired rocks) and work out ways to protect our wildlife by protecting their habitats from roads, industry and, yes, hunters.  In other words, cut the insanity and get a grip.

I applaud stricter and immediate enforcement of penalties for those that blatantly and knowingly break the laws and hunting regulations.

As a member of a group that spend a lot of after tax dollars on hunting, and enjoyment of the trip, we are losing our enthusiasm as year after year, our chance of a moose diminishes.....out of 15 people putting in for a limited entry moose, 7 new hunters who had never had a draw, not one of us got one.  (as a group, 3 moose would provide us all with enough meat, and we would have shared.  This year no one will go, and probably won't plan to go again......setting aside holidays, budgeting the trip costs, making cabin reservations, buying the equipment needed   etc., and then having to cancel is just not worth the effort.

Our discouragement keeps us from introducing my son or grandchildren to the entire experience, the hunt, the study of animals, and the outdoors.  You can not learn to be a skilled and respectful hunter from books or courses, you need to experience a few years with someone.......all the field dressing courses and manuals do not accurately depict the amount of work once you have a moose on the ground.  Hunting is like driving, you need to put some time in with experienced people, not just classroom. Make it more likely that new hunters with an experienced hunter to teach them has the opportunity to hunt.

I also have a daughter that has begged us to come with bow or shotgun and take the deer that eat her crops (her income).  We said not without legal permission, she has been refused. The deer would have been shared again.

Keep BC and BC wildlife and wild lands for BC residents first, it is the main reason that many of us live here.

Some of the proposed changes make great sense, I hope these are a starting point.

Please allow non-residents to hunt without using an outfitter. I have friends in BC and I could hunt with them, but as a US citizen I am not allowed. I can hunt if I engage a very expensive outfitter, but that is a non-starter.

I have several concerns which I will outline in sections below.

I believe as many do in south-eastern BC that the allocation favours the guides over the residents and this has to be addressed. There is no question of which group is the largest and spends the most on this sport. Our local MLA had a private members bill pass in which it was proclaimed that hunting was a heritage right, if that is true our heritage has been constantly eroded by those that derive a living from this sport and who lobby the government.

Further it is apparent that the guides target certain areas and then try to exclude other hunters from this area. Last fall I was hunting in the Bull River area and spoke to some hunters who came from Kamloops to hunt for Elk. They had been given a location to hunt from friends and when they arrived at the location the guides suggested strongly that they (the guides) would be hunting the area and they (Kamloops hunters) should go another location. This was a large group of guides and they intimidated the other hunters, this is a not uncommon practice. The hunters stated they will not be returning to this area.  To me this targeting of areas in mass and the conception by the outfitters that they have the right to exclude other is harassment. Further this type of targeting has to deplete the area of any of the larger animals that would have been available to others and then the area has to recover. This type of targeting affects what is left for the general hunting population and affects their success rate.

With the limited availability of some draws a hunter may have very little chance to hunt a certain species while the outfitters always have an allotment then the outfitters either try to exclude other hunters or simply take over an area in mass. There has been much said about some tags not been filled by locals. Given the above if a hunter draws in an area as noted above what chance does he have to fill the tag. Outfitters must be good hunters or they would not be in business therefore it stands to reason that they can greatly affect an area when in it. This speaks again to less allocation for the residents and more for profit. Why should out of province/country hunters have a better chance at antlered animals with this system than do the locals. Locals pay everyday for living in this province and contribute more overall to the province than does a single user group. So why has the allocation to the residents been declining over the years.

Another issue that must be addressed is that of people with disabilities. It seems strange to me that one who is over 65 or one with disabilities can buy a fishing licence at a discounted rate but not a hunting licence or tag. Why does one policy discriminate and the other not. I had occasion to apply for a disability permit under the act and soon found out that it was open to interpretation and when I called Victoria for clarification they even admitted that there was “grey” areas in the permits. One local CO even read the permit wrong. A simple straightforward policy without and language in it should be enacted. By the very nature of being disabled one is severely limited in one manner or another. Yet when I applied for the permit I was given areas that required a lot a travel (which can affect the disabilities) or an area that was previously closed and then with no warning opened to the general public after my son and I spent all our time in the areas spotting. Because of my disabilities I could not be there on opening day nor could my son be there on opening day because he had to come in from out of province to help and could not get that day of work. When he did arrive we went to the area and found it had been shot out by other hunters. I do not begrudge the other hunters by issue a permit to a location were there is not chance of success. A second instance that I am aware of is a fellow with no legs was not allowed to shoot from a vehicle (quad/truck etc.) to get an animal, how then can he hunt, this is absurd.

In south-eastern BC tourism is out of control with the influx of mud boggers/quads and motor bikes from Alberta. Alberta has limited areas of access for these groups for good reason. Earlier this spring I was in an area that I have hunted and have always found animals there. What I found this year was the area torn up from the above and not one animal. With all species getting ready to give birth what must be the mortality rate of the unborn when constantly harassed by these groups. This mass miss use of crown land has to end before the land becomes useless or uninhabitable for animals. There should be severe limitations as to areas of use and times of use. If access is limited during calving or hunting seasons many problems would be avoided. Locals hunters or not are being pushed out of the very areas they choose to live yet no action has been taken and tempers are getting shorter.

Overall I think the amendment and simplification of the act is a good idea. I have been greatly saddened over the years by the decline in the numbers of hunters.

I do not see how the amendments recommended will provide the increases in hunters predicted.

The Hunting Regulations and LEH get more complex each year. Ensuring that you are hunting legally and correctly requires continual checking. Surely there is a way to greatly simplify the regulations.

I do not agree that Aboriginal people should be given higher priority or special privileges over other citizens. I believe all citizens should be treated equally. I realize this goes against current laws and treaties, but I feel that these doing more harm than good.

I do not understand why we continue to deactivate good logging roads. Soon we will be faced with massive fires due to the pine beetle problems. We could better use those roads to help fight fires. We should be strip logging wide corridors in the infected areas to act as fire breaks.

A suggestion worthy of consideration would be a return to handgun hunting. Many hunters, myself included, would enjoy carrying a .22 pistol for grouse and rabbit. A hunter pursuing big game with a large centerfire rifle could harvest some small game as well with the smaller firearm.

In addition, the sport of large bore handgun hunting has had a very successful attraction in the US. It would add a new layer of sport that archery and rifle hunting has held exclusively. Many humane and accurate big game shots have been documented using handguns.

The safety aspect of having a handgun while hunting against predators would also be a net benefit.

Thanks to the Ministry for taking the initiative to look for suggestions. It is appreciated.

I commend you for this morning’s article in the newspaper.

A few random comments.

I like the idea of game fences around ranch and farm alfalfa fields. Then there is no conflict between wild game and ranching. Certainly this change in the Kootenays is for the better.

If farmers or ranchers complain about game and don't have game fences around their land, then they should allow hunters access without the payment of fees. The hunters should be signed in to make sure they are responsible and do not damage domestic animals or equipment.

The Federal gun control Act, Bill C-68 is the worst detriment to hunting. Why did they have to put it under the Criminal code? If it could be swept away then people would feel less uptight about shooting.

I would like to see easing of regulations for shooting ranges. Most municipalities make the regulations very difficult and all government agencies are trying to get rid of shooting ranges. New hunters have to learn at a range before they start hunting.

The inspection stations such as the old one at Cache Creek served to publicize hunting and was a good thing. However the enforcement in the last 10 years has emphasized whether you cut your tag properly, not whether you were a good hunter. Minor errors in paper work have been the big thing at inspections and it has appeared to me that the inspectors were actively looking for these paper errors to charge people. As though they were there to harass us hunters, not to help us.

I do not like to see the actions of some of the native hunters. Anybody driving a new 4X4 Dodge pick up with deluxe fittings, carrying a new Weatherby rifle with a fancy scope is definitely NOT a sustenance hunter! Why can't he be subject to the same rules that I abide by?

Some new hunters are put off from hunting because they did not handle the animal properly after shooting it. Then the meat soured or tasted strong. Please add a section in the regs on the importance of quickly gutting the animal and most importantly COOLING the meat to keep it sweet. If the hide is left on the meat keeps warm and goes off taste quickly.

I would like to see later hunting season dates. I prefer to hunt after the snow comes so a late November hunt makes tracking more fun and keeps the meat clean when the animal is cleaned on the snow. The meat cools quicker.

There are lots of Moose in Wells Grey Park. Anyone who applies for a limited entry there is sure to get it. However very few hunters actually collect a Moose there because of extremely limited access rules put in by the park. Why can't hunters use all the roads for vehicles including ATV's and snowmobiles for hunting? The road should be kept plowed so hunters don't have to worry if after the next snowfall the Parks have not plowed and they are stuck there.

To maintain winter wildlife foraging areas I would like to see more of them created instead of more parks. These areas should be free of cattle grazing ALL year long to leave some food for the game. The game need forage in low snow areas during the winter. This is land that is often now held privately and needs to bought back by the govt and reserved for wildlife.

In certain areas I would like controlled burns to make good forage for game. Years ago the "Big Burn" on the west side of Clearwater Lake was a hunters paradise with Moose everywhere. But when it grew up there was little forage and the Moose died out. The Moose moved south from the Yukon as man's logging opened up the country for good forage. It was 1921 before the Moose got to Clinton.

I would like to see logging in Tweedsmuir Park. The logging roads would give access to this wonderful area which is now restricted to rich fly in visitors. Logging and controlled burns would develop forage for game and access for people to visit, fish, and hunt. 99% of people in BC don’t even know there is a park there. I am the only one I know of who has been there. What a waste of a fabulous area!

Thank you for this opportunity to "vent". If I can be of any assistance please contact me.

I refer to the discussion involving the encouragement of more hunting in the province.

Having observed the behaviour of the BC Liberals since they took over management of our province, it is clear to me that the motivating factors for expanding hunting in the province have little to do with responsible wildlife management and much more to do with increased revenue from hunting fees and increased revenue for their political contributors in the hunting guide and firearm sales business. This governments cancellation of the Griizzly Bear moratorium, for one, has permanently damaged their credibility as responsible managers of the wildlife that belong to each one of us, not just hunters and the governing political party.

Briefly, in summary, let me make these points:
1. Since you have drastically reduced the number of conservation officers to ensure hunting is done in a humane way, you will be facilitating the expansion of more pain and suffering of wildlife caused by many more unsupervised, perhaps drugged or drunken, juvenile, or just cruel hunters torturing and killing more wildlife. I have personally seen this kind of behaviour and it is out there, believe me. If you would like to hear some horror stories, like of ducks being blown to bits by as many as 8 shotgun blasts, just let me know. I'll be happy to try to open your eyes conveniently closed to what goes on out there when humans with high-powered weapons are turned loose on helpless wildlife.

2. You are supposedly wanting to increase the number of young people (kids?) out there killing wildlife? Why, so more kids can get a picture taken and posted in the paper holding a rifle with a foot up on the animals body as if to say “look what I did, I'm so proud”. That's just plain sickening. This kind of disdain for the God-given life of any living mammal is despicable.

Please add my name to the list of those disgusted by your irresponsible encouragement of more people to hunt and kill. Instead of what you're doing, hire back those conservation officers you fired and let them decide and deal with animal over-population (if there really is any). At least, if properly controlled, they will do so by minimizing the pain and suffering of other mammals we share the planet with.

I read with dismay in this morning's Vancouver Sun the recommendations contained in the discussion paper on the Wildlife Act of British Columbia.  One would have thought the decline of hunters and the corresponding increase in wildlife might be considered a triumph but, alas, not in “Beautiful British Columbia”.   Having recently visited Jasper National Park, I was enchanted by its natural beauty and wildlife.  Hundreds of tourists from many parts of Canada, Australia, Germany, Holland, Britain, etc. shared this unparalleled experience. 
As pointed out by the B.C.Wilderness Tourism Association, the value of ecotourism far exceeds that of hunting.  Isn't that a good thing for the B.C. economy?  Or does it come down to whether a big horn sheep is worth more dead than alive?  (By the way, the Vancouver Sun photo of the hunter proudly displaying the head of a big horn sheep was disgusting.) 

The argument that hunting is good because the flesh of wildlife is organic is rather “precious”.  I know hunters who have freezers full of moose meat left for years uneaten while they devour beef purchased at supermarkets. 

Just as I started having positive thoughts about the B.C. Liberal government's becoming more enlightened about the environment, these retrograde, Neanderthal proposals regarding our wildlife just sent them all up in smoke.

I greatly appreciate this opportunity to participate in the public forum regarding revision to the current Wildlife Act.  I understand that many of my opinions are contrary to many ideas expressed within the proposals, however, I hope that my perspective will be considered. 

Another great concern I have is regarding the statement that there needs to be a balance between the needs of animals and humans.  While this sounds ideal, the discussion clearly does not operate on these assumptions.  The basic needs of wildlife are not being met.  For example, hundreds of deer are killed on highways each year, simply because they are attempting to reach the lake for water.  Bears are shot each spring and summer for coming into city limits, even though they are searching for food, as their habitat has been encroached upon by human development.  Food, shelter and water, are three very basic needs for all living creatures that are clearly not being met.  When considering these few examples alone, I believe it is understandable my shock and dismay to read the extensive section of the paper dedicated to recreational hunting, a human want.

I am writing this letter with suggestions to the wildlife act and how it affects wildlife collisions here in BC.  The Robson Valley Corridor where I live is teeming with diverse wildlife.  Moose, bear, deer, wolves, coyotes, lynx, and even the occasional elk and bighorn sheep make their range in the valley alongside the many people who choose to call the valley home.  Sadly, with Highway 16 and the railway running straight through here, collisions with wildlife have become inevitable.  Since moving here three years ago I have seen a decrease in the amount of moose on my daily drive.  This area has designated wildlife corridors which don't allow for development and yet it is around these corridors (i.e. Baker Creek) that I believe sees the highest vehicle-moose collisions in the valley.  This is a serious problem that needs serious review as we also have a high number of limited entry hunts in the area.  How do we know exactly what the numbers of our moose population is, and if collisions between vehicles/trains and moose are not accounted for, then how do we know what a sustainable moose population is in the Valley?  Signage is an important part of letting drivers know where high collision areas are, and holding drivers accountable for the reporting of collisions should be the primary focus of wildlife collision management.  I would like to see fines imposed on commercial drivers and drivers in general who do not report collisions with wildlife.  Also, the use of a toll-free number in which wildlife collisions can be reported to makes the reporting in remote areas such as this a simpler task.  I also believe that all people involved in a collision with an animal have a responsibility to stop and either ensure that the animal has died or get help by reporting the collision, also to remove if possible the deceased animal from the roadway to ensure safety for other motorists.  We are going to be seeing an increase of train traffic as well in the coming years because of the new port in Prince Rupert.  The news is reporting that the large percentage of freight will be transported by train and not by truck; we can assume that there will be an increase in collisions with wildlife due to this fact.  What is going to happen to accountability with companies like CN?  Companies such as CN should be held financially accountable in compensating the crown for the loss of wildlife and perhaps money could be directed into funding that supports train/wildlife mitigation research.  Ownership of dead wildlife due to collision is another matter that needs to be addressed.  Currently, people must be licensed to possess road-killed animals.  Animals that are taken as road kill should be recorded and not removed without thought to the importance of accuracy of the reporting of ALL dead animals.  Again, wildlife collisions are part I believe of a bigger problem and needs to be addressed immediately with accurate recording and accountability by all of us who drive, witness collisions, or are involved in an animal collision ourselves.  With accurate recording I believe that scientists will begin to have a better understanding of real numbers of wildlife throughout BC.  Maybe then we will start to see the push for better regulations of development in rural municipalities and changes to hunting regulations that create sustainability of animal populations such as the complete removal of  cow/calf moose hunts when the level of the moose population is not healthy due to the large amount of vehicle collisions that are not being reported.

Coast Forest Products Association (CFPA) appreciates the opportunity to provide comments on the BC Wildlife Act Discussion Paper. We understand the Discussion Paper is the first step in the process of assessing overall statutory jurisdiction over wildlife habitat with the objective of improving the current Wildlife Act. Coast Forest supports the goal of modernizing and streamlining legislation as long as proposed changes contemplate and address environmental, social and economic considerations. Unfortunately, recent land-use planning initiatives including draft orders for the Central Coast have failed to consider and exclude economic objectives. In managing resources such as wildlife, it is imperative legislation and attendant regulations are developed with the underpinning of an appropriate balance between social, economic and environmental objectives.

The Discussion Paper in some aspects makes specific proposals for change, in others makes generalized suggestions and finally, notes that some areas of the current Act as well as the amended Act will be enabled through regulation being developed (i.e. Species at Risk Regulation). Also it is noted that changes to regulations will be addressed at a later stage of the review process. Because there is not a lot of detail for many of the proposals for change and because we have not had an opportunity to review draft enabling regulations, Coast Forest commentary offers some principles that should be followed to ensure regulatory burden is not increased, and that timber supply and delivered log costs are not unduly impacted.

The Discussion Paper acknowledges that forest sector activity with respect to management of wildlife and habitat is already subject to significant forest and range practices legislation, but the same degree of rigor does not encompass other sectors or agencies. The Ministry of Environment (MOE) should strive to have legislation that is consistent with the results based foundation of the Forest and Range Practices Act (FRPA) and a product that respects and upholds the rights of tenure holders. Any changes to the Wildlife Act and regulations must avoid overlap or duplication with other enactments – this includes consistency in definitions, relevant objectives, and practice requirements. An example of problematic duplication is the listing of specific species in Section 34 of the Wildlife Act and the draft Wildlife Habitat Features (WHF) order being developed by MOE. As acknowledged by MOE the draft WHF order once again only applies to forest tenure agreement holders and precludes any obligations on other resource users.

As a general rule amendments to the Act and content of enabling regulations should strive to:

• address special management on an incremental basis and not duplicate requirements found in the Forest and Range Practices Regulation (FPPR) and other statutes;
• provide clarity rather than confusion;
• not conflict with objectives or requirements found in the FPPR;
• be premised on a results based approach rather than being overly prescriptive; and
• provide exemption opportunities where warranted.

I have looked over the Discussion Paper, and do not see any reference to the sale/barter/trafficking of wildlife parts. The Hunting Regs have specifics about bear parts but I think some avenue needs to be kept open to allow for changes to the list of controlled parts. It is defined that importation of parts of certain species is controlled, but internal trading of non- endangered species and parts is open, and this does nothing to curb poaching of animals. Poaching of any species for trade may need further controls. The animal that comes to mind now is Wild Sheep, and the poaching for sale of Skull/Horns.

Increase fines for hunting related infractions. Example: confiscation of motor vehicle if caught in access management area.

The Association of Professional Biologists (APB) represents 1600 Professional Biologists in the province of British Columbia. The APB sincerely appreciates government’s recognition that wildlife is important, and we strongly support your intention to revise the Wildlife Act (the Act) to better meet current and future needs of the wildlife and of society.

The APB is pleased for the opportunity to provide input to help government create the new Act. This letter contains our recommendations as developed by a committee of experienced Professional Biologists and approved by the APB Board of Directors for your consideration.

Our comments are based on review of the recent Discussion Paper and of the current Act. As well as noting where we agree with proposed changes as shown in the Discussion Paper, we’ve recommended improvements and identified some issues not referenced in the Discussion Paper.

We have confined our comments mainly to issues directly related to conservation of wildlife. Most importantly, we agree strongly with the Discussion Paper that: “The overarching objective of the Wildlife Act is to maintain and restore the rich diversity and abundance of native wildlife species, based on accepted biological and ecological principles”

The Wildlife and Ecosystem Act
Originally the Act was intended primarily to manage species used for fishing, hunting and trapping, although there have always been limited provisions for other species. In recent years several trends in the science and practice of wildlife management have emerged which should be addressed in the new Act:

• Increasing need to provide for conservation of all species native to the province, as well as continued good management of the ga and commercial species, and activities;
• increasing recognition of the importance of managing the ecosystem as a whole;
• recognition the environment is continually changing; therefore, the new Act should seek to maintain the capacity of ecosystems, habitats and species to evolve with environmental changes rather than aim for static preservation.

Recommendation 2: the new Act should be named the Wildlife and Ecosystem Act. This change will facilitate continual improvement of ecosystem level management, and will foster BC’s intent to meet its broad conservation commitments under items such as the Canadian Biodiversity Strategy.

Recommendation 3: the new Act include sections addressing:

• conservation of ecosystems, habitats and species;
• recovery of threatened and endangered species;
• maintaining viability of vulnerable species so they don’t become threatened or endangered;
• recreational and commercial use of wildlife, using the broad wildlife definition proposed by APB;
• control of non-native species posing hazards to the environment;
• first Nations issues consistent with Canadian Law and the Constitution;
• harmonization of all provincial resource legislation so they are all coordinated and contribute to conservation;
• meeting national standards under relevant federal legislation and reduction in overlap with federal legislation;
• coordination with relevant legislation in other provinces and territories.

Effective information on wildlife management
The APB notes the Discussion Paper documents government’s stewardship model of wildlife management. A key component of stewardship management is reporting on the status of the resource and of its uses, so the public, stakeholders and agencies are informed of successes and emerging priorities. The APB appreciates that the Ministry of Forests has prepared a comprehensive and useful on-line ‘State of the Forest’ report.

Recommendation 4: the APB recommends the new Act require the Ministry of Environment to provide ‘Wildlife and Ecosystem Status Reports’ every 3 years. This status report should include comprehensive information on the status, trends and likely future of:

• ecosystems, habitats and species;
• human uses of ecosystems, habitats and species;
• First Nations issues;
• priority items such as the provincial response to the national Species at Risk Act;
• ability of other provincial resource ministries to contribute to conservation;
• consultations with the public and user groups;
• appeals to decisions made under the Act.

Vision for sustainable management
The APB supports the stated principles and objectives in the Discussion Paper (Pages 9 & 10) and suggests they be embodied in the preamble to clearly state the Act’s intent and purpose. The specific inclusion of such a pre-amble will provide guidance for the interpretation of the Act by all parties.

Recommendation 5: the APB recommends the Wildlife and Ecosystem Act include a pre-amble encapsulating the stated principles and objectives found in the Discussion Paper at pages 9 and 10 to help ensure its intent is understood by all using and applying it, including the courts.

The APB recommends that consideration be given to harmonizing the provincial and federal licensing to reduce cost to governments, reduce administration, and to simplify the process for the anglers and hunters.

Responsibility for biological statutory decisions
Currently some decisions are shared between different staff levels, and some biological decisions rest with Cabinet. For example, the current Act (Sec 53 Restrictions on guiding for fish and angling) provides the Lieutenant Governor in Council with authority to set many items that are basically biological in nature, such as determining number of angling guides or angler-days on a body of water. The Discussion Paper states: “For example, the Act provides the following with regard to a limited entry hunt:

• the Lieutenant Governor in Council approves a regulation concerning the season (timing) and the range of authorizations for hunting a species or class of species;
• the Director of Wildlife may vary the authorizations on an annual basis;
• the Regional Manager decides on guide outfitter quota; and
• the Minister may close the season for that hunt.

As will be apparent from this example, decision-making authority under the Wildlife Act can be fragmented or inconsistent and may appear unnecessarily complex.”

Recommendation 16: the APB recommends there be a single delegated authority under the new Act with the statutory decision making power over biological decisions such as:

• determination of total allowable harvest of a fish or wildlife species or population;
• determination of the quota for non-resident hunters, assigned to guide-outfitters;
• determination of the number of authorizations for LEH for resident hunters;
• number of angling guides or angler-days on a body of water, and allowable catch where needed;
• any biological decisions directly affecting angling, hunting, or wildlife populations.

The most logical position to vest such authority would be the Director or designate in consultation with the Regional Manager. This change puts such decisions in hands of professional staff with the responsibility for provincial standards (Director) and those having the most biological knowledge of the resource (Regional Manager) while greatly reducing administration and improving efficiency.

Appeals
The APB is prepared to support the proposed changes to the appeals process, as reduction in unnecessary appeals will free up
resources to apply to conservation. We are also concerned that legitimate appeals not be unduly restricted, so will confirm our support when the Ministry provides more detail in the next stage of the revision process, to provide more certainty to the potentially affected stakeholders.
We also suggest government consider other ways of reducing unnecessary appeals, for example the legislation could require:

• mediation before going to the Environmental Appeal Board;
• a Ministry appeal process for selected ministry decisions;
• a higher fee structure, with partial rebate if the appeal is successful.

View feedback submitted by A. Dionys de Leeuw… [PDF 414KB]

We run the Prince Rupert wildlife Rehab Shelter and have done so for the past 18 years. Our permits come from the Ministry of Environment, and in all these years we not only received our permits, but also advice for the many problems that arise with a wildlife shelter, as well as the physical presence of a Conservation Officer as needed. Example, how to deal with the public re releases, expired eagles etc. paper work. Also dealing with nuisance or dangerous animals. The Conservation Officers are in the front lines and are definitely in the know. What we need are more conservation officers, and office workers, NOT giving the responsibility of paper work or enforcement to any other organization or network. If other ministries in government have increased, why on earth would you want to decrease government powers in the Ministry of Environment??? If you must change, then why not combine Fisheries, and Conservation Officers. You would then keep your credibility and the role of government to govern.

The Oiled Wildlife Society of BC (OWSBC) calls upon the Ministry of Environment (MOE), in cooperation with federal government counterparts, to provide effective oiled wildlife response capacity. This can be accomplished in BC by supporting existing professional response services for wildlife affected by spills, and through the incorporation of oiled wildlife response into the Incident Command System. OWSBC recommends that the MOE enact legislation to require the Responsible Party to pay for all wildlife clean-up costs and require oiled wildlife response to be a part of standard oil spill response activities on land or in water. Finally, the OWSBC recommends that the governments establish a trust fund to provide funding for oiled wildlife spill response when the Responsible Party cannot be identified. The OWSBC supports the MOE Operational Guideline on Wildlife Response in identifying reasonable costs for oiled wildlife response. This is no longer an activity that can be carried out solely by volunteer efforts or existing wildlife rehabilitation centres, due to liability issues, lack of resources, and training limitations.

I wish to commend the B.C. Ministry of Environment, Fish and Wildlife Branch for conducting a thorough review and revision of the B.C. Wildlife Act, and producing an Act that is appropriate for the era that we are living in. Thank you for providing the opportunity to comment on the discussion paper.

Why is wildlife management significant?

This section sets the scene well for B.C., but could be much stronger if the Global concerns about biodiversity are mentioned first. The global demise of biodiversity is one of the most important environmental issues of our times.

Given the high level of species endangerment in B.C., the Ministry of Environment should be working towards a B.C. Endangered Species Act to protect the province’s species richness that is mentioned in the second paragraph.

Paragraph 4 of this section refers to ‘managing wildlife in a sustainable way’. This is a commendable goal, but the evidence regarding the two species of bears in B.C. would suggest that both populations are in decline, and this is not ‘sustainable’ in any sense of this often misused word.

How is wildlife managed in Canada?

This section needs to be updated to include reference to the Federal SARA.

How is wildlife managed in British Columbia?

Wildlife management involves not only control of wildlife, but wildlife protection too.

I am responding to the subject of Exotic Animals in British Columbia. I represent and am one of the founders of Small Exotic Feline Society of BC. We are a non profit society with members in BC; as well we are affiliated with a larger organization in the US. Our group supports the responsible ownership and education of the smaller exotic cats and we support the conservation of all wild cats especially the smaller species. Most of our members have many years experience living with small exotic cats and their cats are pets, just as tame as the “domestic cat”.  In fact a domestic feral cat is much wilder than a house raised small exotic feline.

We oppose a complete ban as these small exotic cats are not in the same league as a tiger, lion, leopard or panther.  Some of them are about the same size or smaller than the average house cat.  And contrary to reports, made mostly by Animal Right Groups, these cats can live quite well in harmony with a family and with other pets too. They do not spread disease and are many, many generations from being born in the wild. None of these cats are endangered and some are experiencing extreme habitat loss in their country of origin.

Before the decision is made to ban all exotic animals, some investigation into the species being banned should be investigated. Who decides which species to ban? The SPCA? The Animal Rights Groups? Many of these groups know very little about exotic animals at all.  The best people that can inform you are the very ones that look after such animals. A complete ban on all exotics is a little like banning every dog because of a particular dangerous breed. In all the years I have lived in British Columbia I have heard very little about “fatal animal attacks” by an exotic animal. More dog attacks or attacks by our own wild life are a fact.

Other questions revolving around banning all exotic animals are: who will regulate this?  The Department of Agriculture? The SPCA?  And what about existing exotic pets, are they to be grandfathered in?  If animals are to be confiscated where do they go?  The SPCA is already over crowded with domestic dogs and cats. And what about hybrids?  Currently there are several hybrid cats that originate from the various small exotic feline species. In fact TICA (The International Cat Association), a breed registry of pure bred cats recognizes such hybrid cats as the Bengal (Asian Leopard Cat x domestic), Savannah (Serval x domestic), Chausie ( Jungle Cat x domestic) Pixi-bob (Bocat x domestic) and others.

Certainly some legislation must be made regarding the keeping of potentially dangerous animals such as the big cats, large reptiles, venomous snakes, spiders and insects. Permits to maintain such animals and specific safe and humane caging requirements should be enforced.

We live in a time when more care has to be taken of the habitat and wildlife that lives within it as we see human encroachment upon both through urban, tourism and resource development.  It is our responsibility as citizens to ensure protection of our wild areas for the future.  People are now in general far more aware of that responsibility and expect their government representatives to reflect this change in attitude.  I hope this review which is a good thing to do will not be a step forward into the past.

I have now read and commented on the review and am happy to have had the opportunity to do so.  I must say however, I am disappointed to see that far more emphasis is placed on the hunting and "harvesting" (I do find that term disgusting when used in connection with living species) of our wildlife than on its protection.  I think that attitude is not reflective of our society as a whole but rather of a small segment that thinks of animals as existing only for their benefit.  When people needed to kill animals for food that of course made sense and it still does where that is the case.  Otherwise, we are merely talking about entertainment.

I accept that hunting is a part of some peoples' lives and do not ask that it be stopped.  I do, however, think it is inappropriate in the extreme that the Environment Ministry has a strategic project in mind to entice and increase the number of hunters to this province by 20,000 while talking about conservation at the same time.

See my specific comments.  I hope you will give them consideration.

Commercial Use of Wildlife
    You propose;  Organizations representing operators want more involvement in the regulation of their members, including assuming some roles and responsibilities that have traditionally belonged to government.
    My Comment:   *providing training and testing for new commercial operators:  this should stay with government.
                             *issuing licenses:  this should stay with government
                             *establishing standards of practice, codes of ethics and other expectations....  :  together with government/monitoring

We make the following recommendations, which encourage a focus on wildlife protection, transparency, accountability, and enforcement.

Summary of Key Recommendations:

• The Wildlife Act Review should be based on how to better address what the Discussion Paper described as the “over-arching objective of the Act” – maintaining and restoring the rich diversity and abundance of native wildlife species. Despite paying lip-service to this objective, the Discussion paper rarely addresses the impacts of its recommendations on this critical objective;
• The Discussion Paper as a whole does not provide enough detail for the public to meaningfully evaluate the proposed changes;
• Species at Risk and Wildlife Habitat are key to the purpose of the Wildlife Act and should have been included in any review of the Act. We provide recommendations on strengthening the Act in respect of both of these issues;
• We oppose the trend towards off-loading government responsibilities without ensuring accountability and appropriate protection of wildlife resources

Recommendations that WCEL supports

Objective of the Wildlife Act and Mandate of the Ministry

Discussion Paper is too Vague for Meaningful Comment

Failure to Address Wildlife Habitat and Species at Risk

Species at Risk

Habitat Protection

Privatizing and off-loading government decisions

“Outcome-based” Regulations

Extend Right of Appeal

References:

Non native species: Grey Squirrels, Opossums & Rabbits

• The Grey Squirrels were introduced by man, a hundred years ago – our point being is that if this animal was introduced here that long ago something should have been done then, not now. This animal is technically a native and it is unrealistic to try and exterminate the species now.
• The rehabilitation of grey squirrels is more of a regional concern than Provincial.
• Rehabilitation centres are not and will never be euthanasia clinics for the Provincial Government. This would cause extreme anger and lack of support from the general public when this is disclosed – and it would be disclosed.  The Ministry would have to pick up these animals and transport them to their own euthanasia clinic.
• I cannot see the SPCA becoming a euthanasia clinic for the Ministry as they would definitely lose support.
• The general public now tend to raise these three species and others (that we know for a fact) themselves and release them where they shouldn’t be and if the rehabilitation centres were no longer allowed to raise & release in proper areas, the number of individuals doing it on their own would increase dramatically and therefore compound the problem even further. As an additional concern the general public, through lack of knowledge, would raise these animals and in some cases inhumanely. (e.g. Animals that have injuries that would prevent them from having a good chance at release would be euthanized whereas the general public, trying to do a good deed would not and these animals would suffer needlessly and in some cases be released with a disability or disease that could spread to other animals.)
• These species, grey squirrel, opossum & rabbits play a key role in natures food chain and to remove these links would cause hardships to birds and other wildlife that rely on them for their food source, such as owls, eagles, hawks etc.
• The opossum migrated up to B.C. over a period of many decades. It is also believed by many scientists that due to global warming it is very likely more species will migrate to different areas. If this happens through this natural environmental change (caused by mankind) would these species as well be considered non-native and face the same fate?

If the Provincial Government were to provide more detail education to the general public about the transportation (i.e. release) of various wildlife species it is reasonable to assume that this sort of issue would not have occurred in the first place. An idea would be for the Government to post information signs and/or brochures at all ferry terminals about the risks and the future outcome that would be caused by their actions – mainly the releasing of animals on islands or areas where they can not be sustained.

Regarding a rehabilitation LICENSE OR PERMIT:

It is our understanding that the Provincial Government wants the WRNBC to monitor and license rehabilitation centres. It also not the mandate of the WRNBC to police or permit wildlife rehabilitators. The ownership of wildlife has been given to the Crown in legislation, how can a Not-For-Profit group , the( WRNBC) be given authority to permit anything, I do not think that the WRNBC membership would agree to this process. As of today, June 12/07, the WRNBC doesn’t even have a President or Vice-President and it appears that they again, have problems within their own organization. The licenses and permits are the responsibility of the Provincial Government and not the WNBC whose organization was started to support the rehabilitators. As well, their responsibility is to provide seminars, symposiums’ and other learning tools to the rehabilitators.

Sections on taxidermy, fur trade, and commercial dealing of wildlife as well as hunting would be of great interest to the general public and the wildlife rehabilitators, and definitely needs more discussion.

Then there is the issue of modifying the hunting licensing age:

We cannot believe the government wants to put guns in the hands of our children. Is there not enough guns out there as it is? What do you think this is teaching our kids. Do you really think our children will not get the message that it is okay for them to go a kill any animal. Whether or not this process is under parent or adult supervision will have no affect whatsoever.

It would be to the benefit of the Provincial Government to talk to physiologists who deal specifically with children’s exposure to guns, knives etc. which in turn leads to violent acts and the result it plays on their future behaviour in society as an adult before any further consideration is made regarding lower the hunting license age.

Sarah DuBois’s ten year study of 10 wildlife rehabilitation centres release rate was only 25%. Rehabilitation Centres are not the problem.

On the positive side: wildlife rehabilitation centres offer facilities to the Ministry of the Environment, caring members of the general public, SPCA and other animal groups a place to drop off injured and orphaned wildlife. Wildlife Rehabilitators probably answer more than 10,000 calls a year, these are calls that the Ministry would have to deal with. CCWS answers sometimes more than 100 call a day during baby season.

In summary: due to the fact that the Grey Squirrels were a gift to Stanley Park just about 100 years ago, the ministry released raccoons on the Queen Charlottes and I also believe that the European starlings were also a gift to Vancouver,  it is the opinion of Critter Care Wildlife Society that the entire process of changing the existing Wildlife Act in the hopes of exterminating “Non-Native” mammals and the other issues mentioned above is unethical, sociably unacceptable and plain morally inhumane. Would it not be more appropriate, considering recent events, that the Provincial Government look at the issue of importing, breeding, owning, and selling of EXOTIC animals. They are the true NON-NATIVES.

There needs to be further discussion on quite a few issues.

Under the Management of Recreational Use of Wildlife Section here are my comments:

Re-assessment of the Limited Entry Hunting lottery program should be done. If this system makes hunters more apt to shoot first and ask for forgiveness later then that is not a good thing.  Also more checks and balances have to be put into the system so that using same tag again and again does not happen and other infractions. When infractions occur then penalties should be severe to hunters/outfitters and convicted persons should be advertised on websites and thru media to discourage others from illegal behaviour.  More enforcement needed not necessarily more opportunity.  It is our 'privilege, not our 'right', to hunt wildlife.

Comment on 'The Hunter Recruitment and Retention Project'. Recommendations in the Hunter Recruitment and Retention Project, the Ministry has set a target of increasing the number of hunters in the province by 20,000 in next 7yrs. Part of this strategy would involve restructuring and streamlining the regulations and looking at changes to the licensing system: I DISAGREE STRONGLY: Do not proceed with the recommendations in this extremely ‘subjective’ Hunter Recruitment and Retention Project Report. I believe this report does not reflect current societal trends, values and morals in BC. In reading thru the recommendations it does not mention the ‘socially unacceptable’ aspect of trophy hunting. If a survey were to be given to British Columbian's and we were asked if our tax dollars should be spent on increasing trophy hunting in BC by resident hunters and outfitters I truly believe the answer would be 'no' If asked should grizzly bears be hunted for trophy in BC? I truly believe the answer would be 'no'. Hunting for meat to eat or for ceremonial rights is quite separate and distinct from hunting for pure recreation, sport and ‘bonding’ between hunters. After conducting a proper objective study it may well be determined that local hunting of sustainable populations of wildlife, for sustenance along with recreation and ceremony, is very acceptable.  But it is important to 'distinguish' between trophy and non-trophy hunting in the year 2007.

It is also important for government to not become involved in 'marketing' hunting licenses like ski passes with tax payer dollars.  If the government proposed 'privatizing' the hunting license issuance system to make it more efficient, profitable and transparent - then 'marketing hunting licenses' may be a good idea but government should not be telling people to hunt, how to do it, supply maps and create new ways to 'hook' people in. This is a conflict of interest.

Our provincial government is here to protect and govern both human and animal resident and make policies accordingly. The Hunter Recruitment and Retention Project should not be a part of the Wildlife Act.-perhaps the Ministry of Tourism should take it over? The report amendments actually state they want to focus on marketing hunting licenses to non-Europeans residents of BC and want to achieve economic thresholds in the sales of licenses by 2014.

The Ministry of the Environment should be positive about the future of our wildlife with the advent of Eco-Tourism and wildlife viewing. This industry has less hazards associated with it than hunting and it makes wildlife into a truly renewable resource given habitat is preserved. As eco tourism/wildlife viewing grows and hunting decline (which is inevitable) economic prosperity will continue grow. Little loss of economic gain for BC would be felt. Of course with less hunters and more wildlife viewing wildlife authorities have to monitor and enforce BC Wildlife laws as they apply to eco-tour companies. Also with less hunting and more people in the woods, illegal hunting will be more conspicuous and more reported by the public therefore would be minimized.

Raptors that are domestic bred and raise young, that have never been in the wildlife and some of these species are non native to B.C.
The government insists that they be in the wildlife act. Go figure.

What a waste of public money and resources?

This review is a welcome change to the Wildlife Act. There is very little protection for the habitat for wildlife – especially buffer areas around nest trees. Nothing prevents cutting down nest trees on privately owned lands and municipalities must adopt tree bylaws in order to provide protection. In our rapidly developing province there must be protection in place now in order to provide for habitat for the future.

I am also concerned about relaxed laws that could allow for those who consider that wildlife is “inconvenient”; and then remove the “problem”. Then it is suggested that they can then “own” or have a right to this wildlife for personal possession. This is wrong. There must be measures taken first to solve the problem wildlife situation without resorting to killing. This is the old method of dealing with issues and it is time to readdress our methods.

1.0  Purpose

1.1  Métis Nation British Columbia Background

2.0 Discussion

2.1 Exclusion of Métis and Inuit in Present Wildlife Act Practices

2.2 Alignment of Provincial and Federal Legislation

2.3 Socio-Economic Impacts

2.4 Financial Discussion

2.5 Conservation and Management

2.6 Stakeholders

3.0 Conclusion

May I invite all provincial ministers of the crown to commit to transparent public disclosure around the proposal to overhaul the Wildlife Act? Acting speedily to amend this legislation without full disclosure and proper consultation benefits only a few. There can be massive public support for initiatives that are properly processed.

Fast tracked and rushed legislation tarnishes the government’s reputation. We need to protect the marbled murrelet at all costs. Long term, tourism will boost our economy and give us reason to protect our environment and prohibit careless, inappropriate logging practices. If there are 1,376 endangered species in B.C. It’s incumbent on us to protect their habitat to reverse this sorry state of affairs.

Page 14 – Alien Species

If redefining non-native as wildlife gives a conservation officer the authority to destroy these species at a wildlife rehabilitation center, the public needs to be made aware when dropping off orphaned or injured birds and mammals. It must also be clear to the public it is not the shelter’s policy. These species should then go directly to the Ministry, saving the wildlife rehabbers certain harassment. There are already documented police reports on a rehabber decisions to euthanize.

Page 15 – Disease

We understand there is some preliminary evidence that gray and red squirrels on Vancouver Island transport a deadly tree fungus.

Page 19 – Wildlife Rehabilitation

If ownership of all wildlife has been given to the Crown in legislation, how can a Not-For Profit group, Wildlife Rehabilitators Network of BC (WRNBC) be given authority to license Wildlife Rehabilitation Facilities, Centers, or Shelters?

Does that not cross Federal jurisdiction?

Accreditation has been presented by the WRNBC Board, to the membership. A motion to incorporate procedure was defeated, pending further discussion.

Membership to the WRNBC has been limited to wildlife Rehabilitators and anyone with wildlife rehab experience. Board members are elected by the membership. If passed, this Act gives the Ministry the right to appoint members of the public to the Board. – Page -- 25

The WRNBC’s mandate does not dictate policing or governing policy on wildlife rehab. Centers. The group was established to provide networking, training seminars, and education to the membership, and act as a united voice to the government, not for the government. Board members volunteer their time and attend meetings at personal expense. There is no discussion regarding funding to the WRNBC for Board insurance or travel.

Approximately 15 permits are given to organizations, individuals, to rehabilitate and release wildfire in BC. Non-profit groups care for roughly 10,000 cases of “native” and “non-native” species each year. Wildlife related calls number around 30,000 yearly, taking the burden from Ministry personal.

More importantly, the majority of these wildlife centers has extensive educational programs, host seminars, internships from all over the world, provides summer employment for students, sponsor jobs for mentally challenged adults, and participate in Ministry research. Unique is an understatement. Wildlife facilities will require a multi-licensing system to cover the categories listed. Local government acknowledges the value of the wildlife rehabilitation facilities and a few have received the Ministry of Environment Award.

All the wildlife rehabilitation shelters operate under the guidance of one or more veterinarians.

The number of “non-native” released perhaps serves to feed a “species at risk”.

A master thesis concluded that 10 centers over a 10 year period collectively had a 25% release rate.

Some solutions ultimately will come from the dedicated volunteers with ministry support. Wildlife Rehabilitators did not release raccoons on the Queen Charlottes that we believe was a ministry decision years ago. Gray squirrels were gifted to Stanley Park 99 years ago, which would give them “native wildlife” status in a year. European starlings, also a gift to the city of Vancouver.

Page 23 --

OWL is not fully informed on the issues facing the falconry association. Some concerns may be the classification of “hybrids” and “non-native”. There are many points in the discussion paper that the ministry can act upon that affect the outcome of these birds. Page 12, 13, 14, 15, 16, 18, and 23. We believe that the falconry association wants these species classed as domestics.

Sections on taxidermy, fur trade, commercial dealing of wildlife, hunting & trapping are of interest to the wildlife rehabilitation’s community and need further discussion.

OWL (Orphaned Wildlife) Rehabilitation Society strongly recommends that further review of this discussion paper is warranted prior to being presented to cabinet.

Self-governance at this time is not appropriate.

We understand you are considering changes to the Wildlife Act , and we would like to make some comments on an area of concern for us. We have been ranching thirty miles south of Quesnel on the west side of the Fraser River since 1965. When we first came there were very few deer in the area, yet there was a three-deer limit, with only one having to have horns. Now we are literally overrun with deer!

No doubt the recent mild winters have had a major influence on the increased deer population, as well as all the hassle with the gun registry and increasingly expensive hunting licenses and complicated regulations.

The deer in our area can no longer be sustained by their natural habitat, besides which they appear to have a distinct preference for tame grasses and alfalfa in the spring and summer and for haystacks and silage in the winter. This puts a considerable financial burden on local ranchers and farmers, especially at a time when increased costs well outstrip any increase in cattle prices. Additionally, the deer on the roads are a very real hazard, costing hundreds of thousands of dollars in vehicle repairs, as well as creating a threat to life and safety.

There needs to be some provision in the Wildlife Act for downsizing animal populations that have gotten out of control in specific areas.
With the introduction of elk into this vicinity, the problems will be greatly exacerbated, as elk are much worse than deer to foul and destroy far more than they actually eat.

We urgently request that you implement some form of effective depopulation measures for species that have gotten out of hand.

Sincerely,

STIRRUP RANCH LTD.

Domestic raptors bought by falconers are private property. If the government owns then they should pay for the food, vet and housing costs.

I believe more conservation officers must be hired, the number of officers we have now is woefully inadequate. What is the use of new wildlife Act without people on the ground to enforce it?

I would like to see meaningful endangered species legislation based on Ontario and more anti-poaching squads.
Thank you

View feedback submitted by June Wood… [PDF 590KB]

Domestic bred raptors are bought and sold by falconers and are private property.
They are not wildlife.
It is a waste of public money and resources to manage domestic bred raptors when it has no benefit to the public.
Use the public money and resources for the WILDLIFE that is in B.C.

After hearing on the media that the government wants to ban all exotic animals, I would like to make a few comments:

I believe that exotic animals should NOT be banned. These are my reasons why:

The term 'exotic animals' encompasses too many different types of animals. Not all exotic animals or species pose a threat to people. There are a lot of hybrid animals, such as the Bengal and Savannah domestic cat, as well as the small exotic felines, which would be affected by an exotic ban.

Safe housing techniques, such as seen in most zoos, provide a safe place for exotic animals and a safe place for people to view such animals.

Many people choose to own an exotic animal for therapeutic reasons that domestic animals can not provide. Exotic animals are safe to own as long as people know proper husbandry (i.e. proper feeding and housing for their particular breed of animal).

If the government wants to do something constructive, then they should concentrate on regulating how exotic animals are housed, so that they are safe for everyone.

I and other responsible owners of exotic pets are deeply concerned about the proposed ban on exotics. We believe that exotics should be treated as other animals, proper care and facilities are needed for any animal, for instance you wouldn't keep a cow or a horse in a back yard. Exotic as with any animal require specific care and knowledge, I firmly believe that people should need to show there knowledge and facility suitability in order to own exotics but to ban them is overkill. Private ownership allows for species diversity, zoos and large licensed facilities don't always provide the diversity needed. Some species small cats for example are used to create new breeds of cat, with the look of an exotic but the temperament of a domestic. These cats are important to breeding programs. All animals were at one time wild, some domesticate better than others but all are still animals and unpredictable. The house cat can and does survive if it goes feral, because it is not far from its roots. Many exotics are considered dangerous; however any animal is dangerous if not given the respect and care it deserves. People have died from being kicked by a cow or a horse, from being thrown from a bull, but no one suggests we ban these animals. We need to make sure that the people handling any animal are knowledgeable and have the proper space and are using common sense. A tiger doesn't belong in a small area, or to be put in the position of dealing with strangers, it is an animal with an unpredictable nature and as such anyone dealing with them runs risks. As a person who deals with exotics you learn to respect the animals nature and minimize the risks, I do not condone the owning of any exotic by just anyone, in BC we have heard of so many instances of people without common sense or the knowledge they need to deal with these animals, we don't hear about the responsible owners, why because we never cause trouble, our animals are well cared for and housed properly. We don't put our animals or people in situations guaranteed to cause problems. We have all heard about the woman in BC who let her baby crawl with large pythons, this is ludicrous as not only do reptiles have bacteria but snakes do not differentiate between food and any small moving thing. This is just a prime example of an irresponsible owner, but we have irresponsible dog and livestock owners also. We need to make the individual owners responsible, not punish the responsible owners. Exotic or any animal ownership is a privilege and should be treated as such.

A number of issues have been identified from the perspective of the BCWF's formal Resolutions process and from a thorough review by the BCWF Wildlife Committee of the current BC Wildlife Act and Ministry of Environment practices. These issues have tentatively been labelled as "principles". These principles are identified below with a short description of each issue. Within each principle, specific suggestions for change are outlined.

1. Purposes of the Act
   The Act should clearly state that it provides for the conservation, effective management and sustainable use of the wildlife resources of the province.

   This may be accomplished through one statute, or possibly 2 statutes. The 2-statute approach would be to have a Wildlife Act and a linked Fish and Wildlife Uses Act.

   The Act must contain specific language and provisions to protect wildlife and its critical habitat from other uses, including ATV uses and other recreational activities. The Act must also recognize the impacts of forestry, mining, agriculture, human habitation and development on wildlife and fish resources, and must provide authority within the Act to reduce and repair the effects of those impacts. The intent is to allow for recognition of other resource and land uses but establish legislation that clearly recognizes wildlife and its habitats as an equally valuable primary resource on that land base. It is suggested that the revised Act:

   1. Include provisions to protect wildlife from harassment by vehicle, vessel or aircraft with linkage to other statutes that regulate these activities. Harassment must be better defined and possibly standards of conduct regarding use of motorized and other equipment should be provided for in the Act and established in regulation.
   2. Provide a provision to allow the enforcement of Wildlife Act Standards by creating a section that makes it an offence to fail to comply with a Standard established under the Act or its Regulations.
   3. Prohibit the farming of any wildlife species that is indigenous in BC, because of the potential for disease and genetic threats to wild populations.
   4. Prohibit the farming of exotic wildlife species whose escape from captivity may pose a threat to BC wildlife populations or their habitats. The onus should be placed on potential farmers to conduct a threat assessment and establish plans to deal with potential escapes before farming permits are issued.
   5. Prohibit the importation or possession of any wildlife whose escape from captivity may pose a threat to BC wildlife populations.
   6. Should have provisions to address wildlife-human conflicts in communities, with other land uses and within transportation corridors. Establishment of standards for reducing conflicts as identified in the Wildlife Conflicts Prevention Strategy should be enacted, along with provisions for failing to comply with those standards. These standards should apply to land and resource users as well as government agencies (local, provincial and federal).
   7. Should provide for the management of critical wildlife habitat by the Ministry of Environment, or at least give MoE senior decision-making authority under other statutes to allow for effective control. This authority should not be limited to "Critical Wildlife Areas" or "Wildlife Sanctuaries", but to all ungulate winter ranges on Crown Land in the province. Again, the concept here is to ensure that wildlife is given the full consideration equal that accorded to other resource and land uses, with impacts to critical habitat minimized.
   8. Should recognize wildlife use of Crown range as one of its priority uses and institute restrictions on the use of Crown ranges for agriculture purposes as well as protect some of that range from other land uses. In other words, the Act should require the Forest and Range Practices Act managers to give wildlife needs full consideration and explicit balancing when range resources are allocated to other uses like agriculture, recreation and forest practices. Establishing wildlife population objectives would help to achieve this objective.
   9. Should establish standards for management of other resources and management of wildlife-human conflicts. These standards should protect wildlife as well as the people of the province and provide for sustainable management of all of our resources. Establishing wildlife population objectives may help achieve this objective also.
   10. Should establish desired sustainable wildlife population objectives, by species, to help achieve the concept of shared resources on the land base as well as shared use of land, and to allow for the harvest of populations above the established level. This provision could be similar to that set out in the Forest and Range Practices Act for other forest and range resources.
2. Priority Access to Wildlife for Residents
   Wildlife and fish in British Columbia are the property of the people of British Columbia and therefore resident British Columbians should have priority access to those resources. However, the needs of conservation should be fully met before any use of the resources is allocated for harvest. Once the needs of conservation are met, then first and sufficient access to use of those resources should belong to BC Residents. After BC residents' full needs are met, priority should be given to other non-BC Canadians, and only the residual after all these allocations should be available to Non- Canadians. The reason BC residents should be given first priority is because they have accepted land use decisions that set land aside for wildlife and by doing so have sacrificed other resource values (to a degree) to protect the wildlife values. Residents also contribute taxes and fees to help sustain our natural resources. In view of the fundamentality of resident harvest priority, the following important considerations must be accepted within the Wildlife Act.
   1. Wildlife-viewing has impacts on wildlife conservation and should be regulated under the Act. Accordingly, the Act must recognize that commercial wildlife viewing and hunting can be mutually exclusive activities and therefore would require separate seasons and separate allocations.
   2. Any non-resident allocation must be returned to residents when a commercial guide operation is suspended or cancelled or where the guide- outfitter declares that he/she will not guide that year.
   3. Ownership of commercial guide territories must remain with Canadians and control should not be allowed to fall into foreign hands. Appropriate foreign-ownership limitations should be applied to the commercial guiding and viewing industries.
   4. The Act should prohibit relocation of wildlife out of BC unless the sustainable population needs of wildlife within BC have been met.
   5. Section 2 "Ownership of Wildlife" of the Act should be amended to make it clear that the ownership is vested in the government of BC for the people of BC.
3. Statutory decision making must be consistent
   The current practice locating decision-making at the regional level has led to inconsistent application of the law and statutory authorities, resulting in inconsistent application of the law. It is strongly suggested that the statutory decision authority be moved to a single entity like the Director or the Deputy Director, as was done prior to the reorganization of the Ministry. This is particularly important for issues surrounding allocations as well as for actions against licence-holders. Accordingly, it is recommended that:
   1. The statutory decision-maker for residents and for non-residents must be the same person or at the same level in the organization.
   2. Permit administration should be established in regulation, thereby removing the need for anyone to have to make a decision regarding issuance or non-issuance. This standardizes decision-making and also reduces the number of appeals that are possible, and that in turn reduces the impact on staff time and resources from those appeals. The authority to cancel or suspend permits should also rest with one person, not the several regional managers in the province.
4. The Right to Hunt and Fish
   The provisions of the Hunting and Fishing Heritage Act should be included as part of the Wildlife Act and those provisions should make it clear that all British Columbians have an inherent right to access wildlife and fish resources for sustenance, ceremonial and cultural purposes.
5. Hunting as an important wildlife management tool
   Again, the provisions of the Hunting and Fishing Heritage Act should be included in the Wildlife Act to help ensure that hunting is never prohibited for political reasons. The Act should state that:
   1. Managing wildlife populations is not only important for conservation reasons, it is also important to address issues of wildlife-human conflicts that come about because of human activities as indicated in item #1-f) above.
   2. Wildlife management processes be recognized within the Act (regional Wildlife Boards with First Nations, regional or provincial wildlife conflict committees, etc.) by establishing standards for their composition and specified limits or requirements on their decision-making authority as it applies to wildlife management.
6. Ensured access to wildlife and fisheries resources
   In order to protect the resident right to hunt and fish, access to those resources must be provided for in law. Access to Crown land must be enshrined in the Act and it must include access across or through land, regardless of ownership (in other words, require easement through private land to reach resources on Crown land beyond that land [trapped lands]).
   1. This right to access should include requiring agriculture operators who are applying for wildlife damage compensation to allow resident hunters, without fees, to hunt on their land for that wildlife as a qualification for inclusion in a compensation program.
   2. Prohibit the use of private lands as hunting preserves where the wildlife being hunted is provincial wildlife. In other words do not allow land owners to use the provincial resource as personal property and certainly not for financial or other gain.
   3. In order to give some protection to private land owners when allowing hunting access to their land or across their land, require all licence- holders to carry liability insurance.
   4. Establish private land "no hunting" signage requirements that include posting the name, address and phone number of the landowner/authorized manager. Create an offence for those who post hunting prohibitions on land where they do not have legal authority to do so.
   5. Clarify the restrictions in section 39(1) (b) regarding grazing leases occupied by livestock. Ensure protection of livestock but also ensure access for hunters and anglers. Make a provision allowing MoE staff to enforce terms of livestock occupancy of grazing leases where other provincial agencies fail to do so and there are negative impacts on hunter access. Allow MoE to cost-recover for these actions from the responsible agency.
7. Recruitment of new participants
   The act should provide specifically for regulations to promote recruitment and retention of hunters, including periodic review to simplify regulations and eliminate regulations that do not address safety, habitat protection, biological or conservation issues. Regulatory reform should:
   1. Prohibit any regulations like road closures, limits on magazine capacity, baiting bears, use of electronic calls and a whole host of others that turn prospective hunters off or create elitist groups.
   2. Prohibit vehicle access restrictions for other than habitat protection and ensure that where these regulations are necessary, they apply throughout all necessary seasons [not just hunting season] and to all vehicle operators, not just hunters and anglers.
   3. Prohibit regulations that prevent transporting hunting camps prior to the season, if there are valid reasons to prohibit them during the hunting season.
   4. Increase the age for junior hunting licences to 19 and allow junior hunters to harvest their own bag limit.
   5. Provide for a one-time first-time hunting licence (for any first-time hunter regardless of age) at a reduced fee and include a deer species licence for that same fee.
8. General Statute Changes
   These include recommendations to improve the operation of the Act that do not fall within the principles stated above.
   1. Establish a connection with other provincial statutes that will allow for the effective collection of outstanding fines for Wildlife Act offences.
   2. Provide a full definition of "Transporter".
   3. Provide a definition of all-terrain or off-road vehicles, but only if those definitions are required for habitat conservation purposes.
   4. Provide for the ministry to collect fees that are "directed funding" for use of the ministry for wildlife management, public education and compliance activities only.
   5. Provide some control on the use of helicopters for angling.
   6. Section 52 must ensure that the issuer of the Angling Guide Licence includes a rod-days allotment as part of the licence.
   7. Section 65 (reassignment of guide area or issuance of new guide area) must include a provision to consult with resident hunters before a decision is made by the statutory decision-maker.
   8. Section 69 (royalties paid by guide-outfitter) must be amended to exclude the requirement of royalties for wildlife taken by resident hunters guided by that guide.
   9. Section 101.1 must be amended to exclude the ability of guide-outfitters to appeal a quota decision to the Environmental Appeal Board.
   10. Establishment of a Guide Board either in the Wildlife Act or in a separate enactment is not opposed, provided that resident hunters are given equal representation on the Board with Guides. In addition if the ministry does wish to proceed with a Guide Board, the BCWF has other comments on that proposed legislation.

Definitions:

1. A definition of Transporter needs to be added.
2. 'Non-resident alien' could be changed to 'Non-Canadian'
3. A definition of snowmobile and ATV may be needed as ATV's are now tracked and can travel on snow.

• 16 (2) Is this accurate considering fees are now directed funding?
• 18 Remove (b), (c), and (d) or have the director approve.
• 21 This section should be strengthened to ban all exotic species. There should be a more direct reference to fish also.
• 24 Should an absolute discharge mean a conviction and loss of privileges?
• 27 (2) The use of helicopters for angling needs to be addressed.
• 39 (2) The Trespass Act was amended and passed third reading on wording that would protect residents rights to enter leased land. The intent was to support 39 (1) (b) as this is being abused by the land owners.
• 52 (1) (c) Number need to be attached
• 58 In light of the Central Coast, this section needs to be revised to ensure any unused quota reverts to the residents
• 65 There needs to be more consultation.
• 69 There should not be royalties for residents that are guided.
• 88.1 How do campers or remote camps fit in to this section?
• 101.1 The ability for guide outfitters to appeal quota must be eliminated.
• 108 Decisions need to be moved away form here.

• The general principle of priority must be added. 1) Conservation, 2) First Nations, 3) Residents of British Columbia, 4) non-residents and 5) Non-Canadians.
• The statutory decision making authority of Regional Managers should be reviewed so it is not so absolute.
• Statutory decision for residents and non-residents must be at the same level.
• The legal age should be changed form the present 19 to 18.
• Cabinet should not be involved in the broad scope of decision they presently are. Most could be moved to a lower level.
• Review the practise of charging a fee to access private land.
• If a guide territory is suspended, any attached quota must revert to the residents until the area is back on good standing.
• Regional Wildlife Processes (Boards with First Nations) need to be recognized.
• There is scrutiny over who holds a guide outfitting licence and certificate but none over who owns the territory. This should be initiated.
• Preference should first be for guides and assistant guides to be residents of British Columbia.
• Address aircraft disturbing wildlife.
• Review the ability to transport goods and gear to a camp prior to the season.