Background work of Mona Benge: (Letter to Govt and Comments posted on Webpage)

1) http://www.env.gov.bc.ca/fw/wildlifeactreview/discussion

Link to Ministry where you can read the proposal changes to the wildlife act and make public comment.

I was surprised to find that the Ministry seemingly 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 "confusing" and ensure it to be a quality "cool" experience.

2) http://www.env.gov.bc.ca/fw/ds/docs/070607_HunterRecruitment-RetentionStrategy.pdf

After reading this report, one is left with the conclusion that the wildlife act proposed changes are mostly based on the report and therefore will, if implemented, be used for the express purpose of recruiting hunters and promoting hunting as "a cool thing to do" to the young people of our province.

This report opens with the statement that "The 2006/07 - 2008/09 Service Plan for the Ministry of Environment lists sustainable use of environmental resources, optimized public and commercial opportunities from wildlife and providing outstanding hunting among its goals and objectives. The plan goes on to set a performance measure of increasing the number of basic resident hunting licenses sold annually to 100K by 2014/15.

3) WildlifeActReview@gov.bc.ca

Email address to which comments can be sent.

My Comments on proposed changes to the Wildlife Act.

Letter to Gov’t in General Comments Section:

I have now read and commented on the review to the email above 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 dwindling segment that thinks animals exist to be "harvested". 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.

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 accept that hunting is a part of some peoples' lives and do not ask that it be stopped. It is, however, 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.

Sincerely

Mona Benge

Specific comments on proposed changes that are being considered:

1) Under Wildlife/Human Interactions.

You propose: Modify the hunting license system to facilitate hunting on agricultural lands to control problem wildlife.

My Comment: I do not agree with this because it amounts to unregulated hunting. It should not be up to the farmer or rancher to decide what is a nuisance animal worthy of death. That should fall to the CO who then considers whether there is mitigation possible. For example: with bears going into the urban setting or agricultural land: in New Hampshire it has proven to be effective when they are needing food to provide diversionary feeding for a short time. I would like to see the wildlife authorities try that method here. It would be cheaper and more effective than relocation and it would put a humane face on supernatural British Columbia and the government that boasts to the world about our wonderful wildlife. If we change the wildlife act to basically open season without supervision then it will soon have an impact on tourism as the world discovers that we are reverting to the past.

You propose: Enable measure to ensure that members of the public that respond to wildlife conflicts (eg trappers & hunters) are qualified to assess conflicts and properly remove, capture and handle wildlife.

My Comment: Again I do not agree. I think this would amount to a transfer of responsibility to people who have the sole purpose of killing wildlife. It's a total conflict of interest. And further, who is going to assess their level of expertise in the field of assessing the wildlife. It's a proposal meant to make it easier for hunters and trappers to take animals.

2)Under Possession of Live Wildlife:

You mention: the need to amend the Act to fill any existing legislative gaps relating to the humane treatment of captive wildlife.

My Comment: I think this is absolutely overdue. It should hold true for all animals, whether wild or domestic. I think the Animal Abuse laws are way behind the times that we are living in. Government has a responsibility to keep up with changing moral attitudes of the people.

You mention: explicit reference to captive-bred wildlife in the definition of "wildlife" should be in the Act

My Comment: I am not familiar with what you consider captive bred or what the permits are. I would not like to see an increase in species that can be allowed to be captive bred. It makes sense to me though to have a clear definition.

3) As for Zoos: I think there should be strong standards to ensure that animals are well kept in large and environmentally friendly spaces. VHS and BCSPCA standards should be met and if they are not then the zoos should be shut down.

4) Under Wildlife Rehabilitators:

You mention: you want to include enabling provisions in the Act to permit the establishment of a licensing system for rehabilitators.

My Comment: I thought they had to be licensed but if not then I think that is a very good thing. People who take animals into care must know what they are doing and be inspected to ensure they are doing it well.

5) Under Ownership of Dead Animals or parts

You mention: stronger controls and penalties for illegal taking and trafficking in wildlife and wildlife parts.

My Comment: I agree with this. It is time people who kill animals and take their parts to sell must be strongly dealt with in order to send a message to the public that it is an unacceptable practice. I think the government should hire more Conservation Officers so this can be more meaningful than words on paper. So that true oversight and enforcement can be practiced. And when caught, these people should be prosecuted.

You mention: Allow ownership of dead wildlife caught by nuisance animal trappers and those protecting their property.

My Comment: This is just a replay of the other proposal that will lead to a conflict of interest. It would be so easy then to say the animal killed was a nuisance animal and then sell it. Many would do that I am sure. And there are not enough CO's to oversee. I strongly disagree with this.

6) Management of recreational Use of Wildlife

My Comment: Right off the top I find it offensive to talk about the "use of wildlife" or the "harvesting" of wildlife as if they are simply crops to be cut down.

I was unaware that the Ministry has a Hunter Recruitment and Retention Project. I accept that hunting exists as a sport but I do not think it should be the mandate of the government to "recruit" hunters. It is the role, it seems to me, of government to be the caretaker of our provincial habitat and the wildlife within it and to license hunters. To actual recruit them is another story altogether.

You Mention: The ministry has set a target to increase the numbers of hunters by 20K over the next 10 years.

My Comment: Ah yes, the old restructuring and streamlining of regulations. What's next. Canned hunting? like they have in the states. Special rates on motel rooms...maybe throw in the odd hunt in BC hat and a box of ammo. I am absolutely disgusted that the Ministry is embarking on such a project. I would venture to say the public is blissfully unaware it is going on.

You mention: "quality hunting opportunities and being responsive to changing social norms"

My Comment: what does that really mean? What are quality hunting opportunities. Are you going to ensure they bag the biggest and the best? There is that awful word "harvest" again. We are not living in the 1950's.

You mention: Limited entry hunting also leads to better hunter distribution and better selection of animals of specific age and sex.

My Comment: The bear spring hunt does nothing of the kind. One cannot distinguish between male and female. This hunt allows females with young cubs that cannot survive without their mothers to be shot. It is barbaric and I am ashamed that my government allows it. The Ontario government was humane enough to stop the spring bear hunt and it has not impacted the numbers of bears in that province even though that was predicted by the hunter lobby. BC is behind the curve this one and should stop the spring hunt.

You propose: to amend the act and regulations so that they reflect new methods of hunting and new hunting tools.

My Comment: what does that mean exactly? Allow hunting from ATV's and snowmobiles perhaps. Please do not make it any easier for them to kill animals. Make them work for it and face a challenge just like the pioneers did? Isn't that the manly hunting experience they seek? And I don't think they should be able to hunt with highpowered weapons used from long distances either.

You propose: to clarify the limited exceptions that might apply to all forms of wildlife harassment.

My Comment: I don't what that means either. What are the limited exceptions? Streamlining for the hunters again?

You propose: to modify the hunting licensing system for junior hunters.

My Comment: I think 10 years is far too young to be put in a position to kill an animal. At an older age, he or she may be able to say no to a parent wishing to include him or her in the hunting experience.

You propose: To lower the price of species licenses

My Comment: Everything else in the world is going up in price and you want to lower the price. If hunters want to hunt then they should pay the price. I don't think it is for the Ministry of Environment to lower prices in order to entice people to kill our wildlife. If they come they come. If they don't, they don't.That's the market as our Premier likes to say.

You propose: one-time-only hunters to hunt without having to take the CORE exam.

My Comment: First of all, how do you know they will only hunt one time? I don't agree with this. They should be fully versed before they go out with a gun.

You propose: special open seasons for people under 19 so they can kill mule deer and white-tailed deer.

My comment: I don't agree with this kind of special treatment. If they want to hunt, it should be within the same rules as anyone else.

You propose: a successful limited entry hunting applicant can share his hunt with a partner

My comment: What this? A two for one? I don't agree with it. Who will police what they do?

You propose: To simplify regulations where feasible in order to achieve greater standardization of hunting requirement in different regions of the Province.

My comment: Again, I have no way of knowing what that would really mean. I have to think there is a reason why there are different requirements in different regions. When I hear simplify, I think you are talking about standardising down to the lowest common demoninator. It is not possible to give a reasonable comment when I have no idea what you really mean to do.

You propose: the hunter recruitment and retention project with its target of 20K more hunters over 10 years.

My Comment: I commented above about this but will do so again. I think for the government to follow up on the Hunter Recruitment and Retention Project report would be a huge mistake. It does not reflect the way society as a whole is moving and just the fact that you have a report like this and feel that you need to almost beg people to hunt suggests that the dwindling number of hunters is reflective of that change. This project should not be a part of this wildlife act review. It is the tourism department that entices people to come to BC so perhaps they should look at it and see how it fits into their "green" supernatural BC promotion. It should be the mandate of the Ministry of Environment to protect habitat and wildlife within it, enforce the regulations to do with hunting, habitat and wildlife protection. Eco tourism is a growing economic benefit that draws on that mandate.

7. Management of Commericial 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. This could provide:

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

I move on to the proposals for change: I would say that we need more monitoring of outfitter activities that should be conducted by the CO's and certainly not by a colleague in an association. This would lead to a flawed system with personal interests involved.

Then it would lead to bad stories surfacing and pressure being put on the government to step in. Privatization of responsibility in this area would be as effective as we have seen it in other ministries. You would be foolish to go down that road.

8. Guide Outfitters

You propose: The Ministry amend allocated quota to respond to new scientific data about conservation concerns

My Comment: That makes sense. I would add that I feel very strongly that BC should follow the lead of Ontario where the spring bear hunt was cancelled as it is the appropriate humane thing to do. Hunters cannot tell the difference between a male and female bear. The females come out of hibernation with newborn cubs that are unable to survive on their own. It is cruel and unacceptable.

You propose: have guides provide and adhere to an operating plan for a specified period so they could move away from prescriptive regulation and towards an outcome-based model.

My comment: What is the appropriate outcome? For the time that someone is a guide, there should be strict regulations he or she adheres to that are carefully monitored by CO's. That is the only way to ensure that good guides run a good business and those outfitters who do not adhere appropriately to the regulations have their permits removed.

9. Fur Traders

You propose: to Change administrative requirements for exporting so that fur-traders can export using their licence number without the need for separate, individual export permits.

My Comment: One blanket permit. How would you know how many pelts or what kinds of pelts they are exporting then? I don't think that is workable and leaves it too open for abuse. I would go further to suggest that there should be a total ban on the leg hold traps. They are so cruel and have been banned in many other areas. BC should not be party to this kind of cruelty.

10. Wildlife Viewing

You propose: to extract a surcharge on wildlife viewing.

My comment: I would agree because this puts a positive value on keeping animals alive and protected. It could also provide an opportunity to experiment with diversionary feeding in order to follow the New Hampshire success in dealing with nuisance bears before they become a nuisance because they are hungry and need to put on body fat before hibernation. This seems however, to be in conflict with your hunter strategy which of course I disagree with strongly. We are moving into an era where more people want to protect the wildlife we have left, enjoy knowing they are protected and enjoy viewing them if possible. This is a growing field of eco-tourism which will put BC in the lead if we just choose to go that way. You have to choose. You don't have to stop hunting but you can't have the "green glow" of supernatural BC with all its wildlife and "how we love it so" while finding ways to entice hunters to kill that very wildlife.

You propose: to establish provisions to manage high-value areas for wildlife viewing etc.

My Comment: I think this is a very good idea.

11. Taxidermists and Exporters

You propose: to 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.

My Comment: I think this again is meant to make it easy for trophy hunters but I don't agree. Keep strict controls in order to avoid poaching of animals.

You propose: allow ownership of animal remains involved in wildlife/human conflicts and vehicle collisions.

My Comment: I disagree. You will just open up the door for illegal hunting that will be passed off as unavoidable conflicts Leave the carcasses for predators. They need to eat as well.

You propose: to expand the circumstances in which ownership in dead wildlife and parts of wildlife worth over $200. may be transferred from the government to an individual.

My comment: I disagree again. This opens another door to abuse. You don't have the manpower to monitor whether people will then go out and hunt animals in order to sell them. It would again be in direct conflict with the present marketing position taken by the Premier: we love our wildlife. Please come and see it. I think it would be entirely unethical and that would not be missed by the people of our province and of other nations.