January 10, 2015 Dear Hunters, Recent changes to Wildlife Allocation Policy have ignited an uproar in the hunting community. I cannot tell you how excited I am about this ‐ to see hunters energized over this issue gives me great hope. It is long overdue. The policy has been flawed for decades and it’s time to get it right. I am a passionate hunter myself, born and raised with it like I am sure many of you were. My folks bought a hunting resort in 1975 in the Vanderhoof area, though for my father it was just a hobby. When I was old enough I became an outfitter and operated the resort for almost 15 years until a horse crushed my leg while on a moose retrieval and put me out of commission. I’ve since recovered from the broken leg, and I haven’t by any means given up on hunting, but I can’t outfit anymore. A sadness weighs in my heart over this because I love hunting (particularly moose hunting – oh the sweet sound of bulls grunting in the fog) and guiding gave me the opportunity to share my passion with others. In 2011 the BC Liberals introduced “the Matrix” as the solution to Wildlife Allocation. The formula was so complex and convoluted it was hard to wade through the bureaucratic lingo. Myself, I lost about 40% of my business with the Matrix. I poured my soul into the subject to find out what had happened and discovered how awful the policy was for everyone, not just me – plain and simple the Matrix was a terrible idea. I tried talking to my MLA and to bureaucrats to enact change, but I quickly discovered that because I wasn’t a member of the outfitters association GOABC I really had no influence. I tried to help create a sportsman’s organization which could better represent both outfitters and resident hunters because I strongly disagreed with the GOABC position on the subject and didn’t feel very welcome in the BCWF as an outfitter. I went to Victoria to speak with government about the issue but came away so disheartened by the lack of regard for hunters that as I was on the ferry back to the mainland I called the BC Conservative Party and asked what I could do to help stop the BC Liberals. This was my start in politics, which eventually led to me become leader of the BC Conservative Party in April 2014. Upon returning home, I wrote a report titled the Balance Allocation Plan: Solving the Wildlife Allocation Crisis in British Columbia. I called for a whole new approach to wildlife allocation which I called 70/20 +10. The concept was that residents were guaranteed 70%, outfitters 20%, and the remaining 10% was determined based on local circumstances and not decided in Victoria. Because outfitters stood to lose the most in my plan I also advocated for remedies to help alleviate losses. The Balanced Allocation Plan is mostly redundant now that the Matrix no longer exists, which was much of what I was criticizing in the report. However, the concept of 70/20 +10 still has merit. Some hunters have questioned my current motives as leader of the BC Conservative Party in criticizing the BC Liberals because I was an outfitter before I was a politician. I wrote the Balanced Allocation Plan long before I became leader of the BC Conservative Party, and you can judge my motives from its contents. My motive in criticizing the BC Liberals is because the policy is wrong, wrong, wrong. It lacks the elements I was seeking when I wrote the Balanced Allocation plan – a balanced approach that respected resident hunter priority and outfitter businesses, a policy that had regional flexibility and was not dictated by lobbyists with influence in Victoria. I have since come to the conclusion that the Balanced Allocation Plan does not go far enough, that allocation should have an additional aspect I call Targeted Allocation whereby residents and outfitters set reasonable and biologically possible targets for actual wildlife tags they would like allocated in an area, and then government takes measures to better manage wildlife in those regions to achieve those targets. This concept is intended to achieve real results, and not philosophical arguments what percentage either user group should receive. I still cringe when I think of GOABC claims that resident priority only meant 51%. I can also tell you I’ve heard hunters say outfitters should only get 5%. Both are wrong in my opinion, these are the extremes and we should all avoid them. The truth is resident hunters and outfitters need each other. For too long the two groups have been at odds, but the reality is one cannot survive without the other. I believe the worst possible thing hunters could do is to destroy the outfitting industry, the results would be catastrophic to their political influence in an era where hunting is under constant attack from the anti‐hunting lobby in Victoria. Likewise, it would be equally catastrophic for outfitters to reduce resident hunting opportunity which would reduce the number of hunters in BC ‐ an important factor in maintaining our political influence. We must work together to keep both sides strong and vibrant, we need a balanced approach to Wildlife Allocation. I invite you to contact me to talk about Wildlife Allocation, it is a subject I believe in passionately and hope that the energy and enthusiasm which has recently exploded give this issue the attention it deserves in the public media. If you share my views I invite you to join with me and the BC Conservative Party. We will champion this cause, but we need your support. Good hunting, and I truly hope to share a campfire with you one day. Your friend, Dan Brooks BC Conservative Leader The Balanced
Allocation Plan
Solving the Wildlife Allocation
Crisis in British Columbia
Daniel Brooks
March 2012
Contents
About the Author
vii
Executive Summary
ix
A Brief History of Allocation
The Outsteader Era
The Neofitter Era
1
1
2
The New Allocation Policy
4
Two Approaches to Allocation
The Human Approach: Managerial Tools
The Mathematical Approach: The Matrix
5
5
7
An Unbalanced Equation
Problems with the Fluctuating Matrix
Amendments to the policy
7
8
14
Pragmatic Examination of the Matrix
14
The Balanced Allocation Plan:
Rebalancing the Equation
18
The Mathematical Formula:
Fixed Range of Allocation Flexibility
The Math Behind 70/20+10
20
20
The Human Formula: Managerial Tools
Inevitable Loss: Remedies
24
24
Conclusion
26
Appendix A: Trumpy Report
“Harvest Allocation Policy Review”
29
iii
List of Tables
Table 1: Maximum possible allocation loss (%) for residents and outfitters.
10
Table 2: Changes in allocation caused by implementation of the Matrix.
14
Table 3: Actual changes to moose quota in two areas: Pre-Matrix, amended Matrix,
unamended Matrix.
17
Table 4: Capture and maximum loss rates for various minimum share values and
ranges of flexibility.
21
Table 5: Resident allocations that are forcibly reduced compared to pre-Matrix allocations.
22
Table 6: Outfitter allocations that are forcibly reduced compared to pre-Matrix allocations.
22
v
About the Author
Daniel Brooks is a second-generation outfitter whose family has guided in British Columbia since
1975. He began guiding in 1994 and took over Crystal Lake Resort from his father in 1999. He is a
licensed outfitter, trapper, and resident hunter. He has been involved extensively in land-use planning
through the Land and Resource Management Plan (LRMP) and the Public Advisory Group (PAG).
He founded and has chaired the Upper Nechako Wilderness Council (UNWC) since 2005, a coalition
of tourism operators in Vanderhoof dedicated to tourism resource planning and marketing. He has a
BA (Hon.) in Classical Studies from the University of Waterloo.
vii
Executive Summary
The implementation of the new wildlife allocation policy has created a crisis in the outfitting industry. The complex history of outfitting has led to inconsistent allocations
across British Columbia. Forcing a one-size-fits-all policy on this diverse industry is
proving catastrophic. The lack of flexibility in the new matrix calculations and the removal of managerial tools have unbalanced the equation of allocation and turned it into
a rigid mathematical formula—a formula that is fundamentally flawed. There is no single mathematical model that can be unilaterally applied. The policy must be replaced.
The Balanced Allocation Plan described herein addresses the problems with the existing allocation policy. Its core proposal is a Fixed Range of Allocation Flexibility
between 70–80% for residents and 20–30% for outfitters for all species province wide
(notated as 70/20+10). Within that range of flexibility, regional managers will be able
to adjust allocation based on transparent managerial tools. Unfortunately, outfitter losses are inevitable. We can’t go back to the previous allocation policy, but the new one is
also untenable. Regional managers will require the authority and tools necessary to address these immediate losses.
For resident hunters, the biggest concern is hunting opportunity and the perception
that outfitters are depriving them of it. The reality is that allocation policy is the wrong
tool for improving hunting opportunity. Because residents already enjoy a greater share
of the allocation, any such gains will always be marginal and at the expense of outfitters.
The key to increasing resident hunter opportunity is increasing the Annual Allowable
Harvest (AAH). The Balanced Allocation Plan addresses all the reasons government
rightly decided to review allocation policy in the first place and frees us to focus on the
real issue of better wildlife management and growing the AAH.
ix
A Brief History of Allocation
Allocation is the process that divides available wildlife harvest
between outfitters (quota) and resident hunters (LEH—Limited
Entry Hunting). Technically, this allocation process has existed
since the first LEH and quota systems were implemented, though
it is doubtful that any initial consideration was actually given to
dividing percentages of wildlife between the two user groups; it
is more likely that allocation was based on whether a population
could sustain levels of harvest requested by hunters or outfitters.
Each region in BC has a different allocation history, and within
each region, each territory has a different allocation story. The
history of allocation across the province is incredibly diverse;
this is the main reason why allocation policy has not been an easy
matter to resolve. In general, though, outfitting in BC has passed
through two different eras of progress, which are labelled here as
the Outsteader Era and the Neofitter Era.
Each region in BC has a different
allocation story
The Outsteader Era
Much like the early homesteaders that colonized and expanded
the farmland of BC, outfitting was once a type of homesteading
that went through a similar process of expansion. During this
Outsteader Era, starting as early as the 1880s and continuing
until the 1970s, an outfitter would explore a potential hunting
area, apply to government for tenure on the land, develop and
improve the area for outfitting, and then raise their family on
this land. Incredible works of infrastructure were built to accommodate these outfitting businesses, including lodges and cabins,
roads and bridges, airstrips and docks, fences and corrals, and
trail networks and corridors. These accomplishments are all that
more incredible when you consider the remote and rugged situation of the outfitters that built them. Today, many of the wilderness lodges and resorts were built during this Outsteader Era by
the initiative of these early outfitters. Over time, some of these
lodges have been sold, separated from their hunting quota, and
turned into different tourism businesses, but they exist in the first
place because of the outfitting industry. Because of this, many
outfitters feel strongly that outfitting is the father of tourism in
BC, and their contribution to the tourism industry is often taken
for granted.
This is relevant to the matter at hand because it demonstrates
how government, through the allocation of areas and quota to
outfitters, was able to promote and grow the outfitting industry
that created the backbone for modern tourism in BC, which is
Like homesteaders, early outfitters
would explore a potential hunting
area, apply to government for tenure, then develop and improve the
area for outfitting.
This process of allocation promoted strong growth in the outfitting
industry.
1
Allocations were decided on an
outfitter-by-outfitter basis in a
one-on-one process between outfitter and regional manager.
currently the largest industry in the province. It also explains
why the previous allocation policy existed as it did. A potential
outfitter would approach the government, tell them they wanted
to start an outfitting business, draw the boundary on a map, tell
them how much quota they needed to support their business,
and they were issued a certificate and given a license. This may
perhaps be oversimplifying the process somewhat, but the point
is that allocations were decided on an outfitter-by-outfitter basis
in a one-on-one process between them and the government representative (the regional manager), driven by the business needs
of the outfitter. There was no formal allocation policy. Regional
managers had great leeway in making these decisions, and there
was a certain amount of arbitrariness in the process. Regional
managers did, however, rely on a number of guidelines and tools
when making these decisions, including:
▶▶
▶▶
▶▶
▶▶
▶▶
▶▶
The unfortunate result was an
opaque process and inconsistent
allocations.
Inflating allocation based on success factors
Shifting vacant area allocations
Shifting unused quota from one outfitter to another
Remote area multipliers & hunting pressure factors
Business model needs
Historical precedent
These methods of arriving at territory boundaries and quotas
led to tremendous growth in the outfitting industry and the eventual triumph of tourism in BC. As the land base across the province began to fill with outfitting territories, however, the number
of new territories dwindled, and the Outsteader Era came to a
close. By the 1980s, the allocation decisions made in this era (the
status quo) were simply adopted as policy. This resulted in an
opaque and inconsistent process.
The Neofitter Era
Today, the outfitting industry is
largely composed of second- and
third-generation outfitters.
2
Beginning in the 1980s, accelerating in the 1990s, and continuing until today, a new generation of outfitters evolved. The Outsteader Era was the epoch of the family outfitting business, but
the Neofitter Era was the next generation of outfitters that either
inherited their outfitting territories from the blood, sweat, and
tears of their parents or purchased their territories as a business.
Today, the outfitting industry comprises a mixture of second- and
third-generation families and corporate businesses. During this
era, the rise and triumph of the forestry industry in BC had a dramatic impact on the outfitting industry. Many outfitting businesses that had built and invested heavily in outfitting infrastructure
were swept aside by the logging hegemony. The dramatic increase
in forestry road construction penetrated wilderness areas sacrosanct to outfitters. There were two main problems created for the
outfitting industry during this time: the loss of operating land
base, and the increasing conflict with resident hunters.
Most outfitting businesses had been originally created in remote areas of BC, far away from roads and trains and towns. As
the forest industry swallowed up an increasingly larger portion
of the province, the remote areas available to outfitters to hunt
were reduced further and further. Because of the loss of workable
land, some outfitters were unable to maintain their businesses
and sold their quota to neighbouring outfitters and their lodges
to new tourism businesses. In other circumstances, outfitters vehemently insisted consideration be given them in land-use planning, and efforts were made to control access on forest roads to
protect outfitter livelihoods. And in still other cases, outfitters
adapted to the new reality and joined the resident hunters on the
roads to compete for wildlife harvest directly. The expansion of
the logging industry was the nemesis of outfitters, as they continually lost the operating land base necessary to maintain their
businesses. This remains the case today, particularly after dramatic increases in harvest levels and road construction in reaction to
the mountain pine beetle.
With the increase in road construction came the increase in
conflict with resident hunters. Prior to this time, outfitters enjoyed relative isolation where few if any resident hunters dared
to tread. But the roads brought resident hunters, and to outfitting
families and businesses that had built their livelihoods on their
isolation from hunters, these roads were a threat. Outfitters and
resident hunters very quickly came into direct conflict as roads
pushed further and further into hunting territories previously inaccessible. Given their investment in the land base, outfitters were
protective of their infrastructure and fought to protect their livelihoods and infrastructure investments. At the same time, resident
hunters fought to gain access to what they viewed as miniature
outfitting kingdoms. This conflict continues even today, and the
focus of this conflict is access management. However, the conflict
over access to land also creates a conflict over access to animals—
the two being inseparably connected. Resident hunters resented
what they felt were outfitters controlling public lands, and that resentment spilled over against non-resident hunters for harvesting
animals that many resident hunters felt belonged to them. And
this is the principal argument in the conflict between outfitters
and resident hunters over allocation.
The growth of the forestry industry
posed a problem as it allowed access to wilderness areas sacrosanct
to outfitters.
Outfitters are understandably protective of their investments in infrastructure.
Resident hunters resent the perceived control over public land by
outfitters and begrudge any quota
taken from them.
3
The New Allocation Policy
The previous allocation policy was
fraught with inconsistencies and
difficulties. There were legitimate
reasons to review the policy.
The review of the allocation policy began in late 2003, early 2004.
Most outfitters believe that the review was a direct result of the
lobbying by anti-outfitter forces in the BC Wildlife Federation
(BCWF). However, it is also clear that the hodge podge of status
quo allocation from the Outsteader Era was fraught with inconsistencies and difficulties; there was a legitimate need to review
the policy. Reasons given for the review according to the Ministry
website were the need for:
▶▶ “a consistent and transparent approach for making allocation decisions across the province”
▶▶ “a decision-making process that was more objective, databased, and amicable”
▶▶ “allocation outcomes that are more achievable, efficient,
and reflective of stakeholders’ interests”
The review process quickly resembled a negotiation, with government acting as mediator between
resident hunter and outfitter organizations.
4
The government stated that its “decisions had been made
through long, and sometimes heated, negotiations amongst staff
and stakeholders.” It isn’t difficult to see from these reasons that
resident hunter and outfitter conflict, or “heated negotiations,”
was a primary reason to review the policy. But conversely it isn’t
difficult to see that the status quo wasn’t “consistent and transparent” and needed to be reviewed.
The review of the allocation policy involved four primary stakeholders: the BCWF—who purported to represent the resident
hunters; Guide Outfitter Association of BC (GOABC)—claiming to represent outfitters; BC Trappers Association (BCTA)—
representing trappers; and of course the government. The review
quickly took on the role of a negotiation, with government acting
as mediator between the BCWF and GOABC. Opinions of this
negotiation are controversial at best and conspiratorial at worst.
But whatever the process was, a new policy was created in 2007.
Implementation was to take place over the next allocation period
from 2007–2011 with full implementation in 2012. It became
immediately apparent with even just partial implementation that
the outfitting industry was going to be seriously and negatively
affected. Under pressure from GOABC, government contracted
with Chris Trumpy to review the policy and provide recommendations. Trumpy’s report, released in 2011, contained eleven recommendations that resulted in further amendments to the policy.
(Trumpy’s report is discussed in detail in the appendix.) The
policy with amendments was implemented in early 2012. Currently, given the crisis created by the policy, a one-year quota has
been issued for 2012 while government seeks to address outfitter
concerns.
Two Approaches to Allocation
The allocation review resulted in a dramatically different policy
from what had existed previously. The previous allocation was
based on what can be called the human approach: i.e., managerial tools that look at each circumstance and allow for individualized solutions. The new allocation policy removes the human
factor altogether and is based on what can be called the mathematical approach: i.e., the Matrix. The pendulum has swung, and
whereas too much emphasis on the human approach resulted in
arbitrary and inconsistent allocations, too much emphasis on the
mathematical approach results in an allocation that is too rigid
and unresponsive to regional differences.
Just as too much emphasis on the
“human approach” made the previous policy arbitrary and inconsistent, the exclusive focus on the
“mathematical approach” results
in the current policy (the Matrix)
being too rigid and unresponsive
to regional differences.
The Human Approach: Managerial Tools
The human formula was controlled for the most part by the regional manager who balanced the needs of resident hunters and
outfitters to arrive at what he felt was the best policy for both sides.
The importance of this human formula is greatly diminished under the new policy. Not a single one of the previous managerial
tools continues to exist in its original form, and some cease to
exist entirely.
Inflating allocation based on success factors—Regional
managers very often would give an area a larger allocation than
the Annual Allowable Harvest (AAH) would support based
on outfitter and resident hunter success rate in a given species.
This made it easier to reach the AAH targets. These were applied to both outfitters and residents. This allowed outfitters to
take greater numbers of hunters. The assumption was that only a
percentage of hunters would be successful, and the resulting harvest would be closer to what the regional manager expected. It is
important to note that this was never expressly documented as
part of an outfitter’s certificate or license prior to the new policy,
because success was calculated regionally. Many outfitters built
businesses on harvesting 100% while others harvested much
less. Under the new policy, administrative guidelines now allow
a guide to harvest 30% of a 5-year quota in one year. This allows
an outfitter to take approximately 50% more hunters in one year
than they have quota without exceeding their harvest. If they harvested greater than 20% of their 5 year quota in one year, they
Inflating allocations based on success rates made it easier to reach
AAH targets.
Administrative guidelines allow an
outfitter to harvest 30% of a 5-year
quota in a single year, allowing an
outfitter to sell more hunts while at
the same time managing a clearly
understood and sustainable quota.
5
The practice of shifting allocations
from vacant areas allowed outfitters to maintain their businesses,
with minimal impact on resident
hunters. This practice is done away
with under the new policy.
Allowing the shifting of allocation
between outfitters was another way
to help outfitters grow their businesses. This practice is now a temporary measure.
Taking into account an area’s remoteness and hunting pressure is
another valuable practice removed
under the new policy.
Regional managers no longer have
the discretion to tweak individual
allocations.
The new policy has almost completely removed the human component of wildlife allocation.
6
would have to reduce their harvest later in the 5 year allocation
period to adjust for it.
Shifting vacant area allocations—Quota from vacant territories was assigned to adjacent outfitters, even though they had
no claim to those areas. In some regions, certain areas were deliberately left vacant to allow resident hunters opportunity to hunt
without competition from an outfitter. This was done with the
expectation that outfitters in these regions would receive the allocation from the vacant area. This practice ceases to exist entirely
under the new policy, and all allocation from vacant areas is given
to resident hunters. Under the new policy, the allocation is area
based, meaning your allocation is determined by the size of your
territory and cannot include vacant areas.
Shifting unused quota from one outfitter to another—This
was done on a one-on-one basis where an outfitter could approach the regional manager and make a case for increasing their
quota because another outfitter was not using theirs. These decisions were driven by business needs, and often led to large areas
with small quota and small areas with large quota. The new policy
does away with this practice and all allocations are based on area.
However, quota may be shifted to another outfitter on a temporary basis with the agreement of both outfitters and the regional
manager.
Remote area multipliers & hunting pressure factors—In
remote areas of the province, where resident hunting pressure
was small or non-existent, regional managers could allocate larger
percentages of the harvest to outfitters who, due to their infrastructure and hunting methods, could more easily access these
game animals. These practices cease to exist under the new policy.
Business model needs—Outfitters who built or expanded
their hunting territories could approach the regional manager
and request greater quotas so they could grow their businesses.
Regional managers had the discretion to make agreements, formal or otherwise, to increase an outfitter’s quota to meet his ascribed business needs. This practice ceases to exist under the new
policy.
Historical precedent—Most allocations were inherited from
the Outsteader Era. Managers in many cases took a hands-off approach and did not change allocations unless there were biological reasons to do so.
Under the new allocation policy, the human approach has
been almost entirely removed, and the mathematical approach
has replaced it—the Matrix.
The Mathematical Approach: The Matrix
The Matrix introduced the concept of fluctuating allocations
based on two key principles: utilization—the number of animals
actually harvested; and importance—resident hunting demand/
outfitter hunt values. If residents or outfitters have greater utilization or importance than the other, the allocation then changes to
reflect the degree of difference from the baseline of a 75/25 split.
Residents and outfitters have certain guaranteed minimums:
▶▶ R
esidents are guaranteed 60% for allocated sheep, goat,
and grizzly bear hunts; 98% for allocated antlerless hunts;
and 70% for all other species.
▶▶ Outfitters are guaranteed 20% for sheep, goat, and grizzly;
and 10% for all other species (except antlerless).
The Matrix introduces fluctuating
allocations based on two key principles: “utilization” and “importance.”
The baseline of the Matrix is a
75/25 split between residents and
hunters respectively, with certain
guaranteed minimums.
The Matrix can be broken down into the following formula:
Allocation = 75% + (2 × (RI-OI)) + (2 × (RU-OU))
▶▶ R
I = Resident Importance—A number from 1 to 10 (10
being the most important) based on the number of successful LEH applicants who purchased a species license.
▶▶ OI = Outfitter Importance—Also a number from 1 to 10
(10 being the most important) based on the total economic contribution of an allocated species in a region,
calculated using the number of hunters and the hunt price.
▶▶ RU = Resident Utilization—A number from 1 to 4 representing the actual harvest compared to allocation (4 being
75–100% of actual harvest).
▶▶ OU = Outfitter Utilization—Also a number from 1 to 4
representing the actual harvest compared to allocation (4
being 75–100% of actual harvest).
An Unbalanced Equation
The allocation process has perhaps never been “balanced” per se.
In the past, it was too easily manipulated by regional managers.
Simply replacing them with a mathematical matrix does not balance the allocation process either. On the contrary, the process
has now become encumbered with the inflexible rules of algebra.
And so the allocation has gone from being too flexible to being
too inflexible. Whereas on the one hand residents previously felt
cheated by the outfitter influence on the allocation process, now
The allocation process has gone
from being too flexible to being
too inflexible. A more balanced approach is called for.
7
outfitters feel cheated by the mathematical inflexibility of the new
policy. And so the conflict between outfitters and resident hunters continues with increased ferocity and without resolution. The
Matrix also makes the Environmental Appeal Board irrelevant
to the allocation process. If an outfitter has a problem with their
allocation, on what grounds can they appeal? The fundamental
laws of mathematics are not at issue, and the Board doesn’t have
the authority to change the policy itself.
Problems with the Fluctuating Matrix
The Matrix is fundamentally flawed
and is an unfair tool to allocate
wildlife harvest.
Whoever developed the allocation matrix deserves credit for an
elegant idea, but the Matrix is fundamentally flawed, and by its
very mathematical nature it is an unfair tool to allocate wildlife
harvest.
The mathematical flaw begins with the baseline. The baseline from which to begin the allocation calculation is 75/25. For
each point of difference between the RI and OI or RU and OU
the Matrix moves by 2 percentage points.
Example 1: RI = 8, OI = 7, RU = 4, and OU = 2. The difference
between RI and OI is 1, and the difference between RU and OU
is 2, for a total of 3. This moves the Matrix 3 × 2% = +6% from the
baseline. 75% + 6% = 81% for an allocation of 81% to residents
and 19% to outfitters.
Example 2 (the inverse of example 1): RI = 7, OI = 8, RU =
2, and OU = 4. The difference between RI and OI is -1, and the
difference between RU and OU is -2, for a total of -3. This moves
the Matrix -3 × 2% = -6% from the baseline. 75% - 6% = 69% for
an allocation of 69% to residents and 31% to outfitters.
Because of the baseline, outfitter allocation will always be three
times more volatile than resident
allocation.
While this appears to be a fair calculation, it is actually heavily weighted against the outfitters. In terms of real effects, a 2%
change in the Matrix for residents only means a 2.67% change
in allocation because they start with the larger baseline assumption of 75%. But to outfitters, starting at 25%, a 2% change in the
Matrix means an 8% change in allocation. In fact, the outfitter allocation will always be three times more volatile than the resident
allocation.
Example: There are 100 tags to be allotted. The allocation is
determined to be 81/19, a +6% move off the baseline of 75/25.
Residents receive 81 tags and outfitters receive 19 tags. To resi-
8
dent hunters, going from 75 tags to 81 tags is an 8% increase. To
an outfitter, going from 25 tags to 19 tags is a 24% loss.
While real hunting opportunities for residents will only ever
see a marginal increase or decrease, outfitters face extreme volatility. It is impossible to rectify this problem in the Matrix unless
the baseline is moved to 50/50. So long as outfitters have the
smaller share, the Matrix will always produce an unfair allocation
to outfitters. All things being considered, moving the Matrix to
a 50/50 baseline is out of the question, so the Matrix is permanently flawed by where it begins.
The next obvious flaw in the Matrix is the inequality of the
minimum share values.
Real hunting opportunities for residents will only ever see a marginal
change, whereas outfitters face extreme volatility.
Another flaw in the Matrix is the
inequality of the minimum share
values.
▶▶ R
esidents are guaranteed 60% for allocated sheep, goat,
and grizzly bear hunts; 98% for allocated antlerless hunts;
and 70% for all other species .
▶▶ Outfitters are guaranteed 20% for sheep, goat, and grizzly;
and 10% for all other species (except antlerless).
The most astonishing part of the minimum shares is the 98%
antlerless for residents. In this case, the minimum share value will
always be enacted, because the OI and OU would have to be at
the maximum matrix deviation of 24% (resulting in a 99/1 allocation) in order for residents to get more than the 98% minimum
shares. This is clearly not a fair allocation process for outfitters.
It should be noted that there are only two regions of BC which
have antlerless on allocation: Region 7A cow moose, and Region
7B antlerless elk. Why this minimum share value exists at such a
level is not explained in the policy, but clearly fairness to outfitters was not considered.
Minimum shares have an additional negative effect on the
Matrix. In the process of calculating importance, each of the 36
allocated species in BC is assigned a number from 1 to 10 based
on their percentile within the total guided hunt value. The two
antlerless categories both score an 8 for importance, even though
they cannot possibly benefit from these scores because the minimum share value will always be assigned. Therefore, including
the antlerless in the Matrix deflates the importance values of the
remaining species, hurting outfitters a second time. In the most
recent allocation, minimum share values were invoked to protect
resident hunter allocations five times and only once for outfitters
(and the one for outfitters only applied because of the temporary
“10 percent rule” amendment).
Including the antlerless in the Matrix deflates the importance values
of the remaining species, hurting
outfitters a second time.
9
Why should one species be guaranteed more than another?
The Matrix is clearly not balanced
when deviation from the baseline
can only go 5% one way but 15%
the other.
Giving different minimum shares to different species makes
it even more difficult to view the Matrix as fair. Why should one
species be guaranteed more than another? Again, this is not explained in the policy but appears to have been a negotiated point.
Combining minimum share values with the unequal Matrix baseline causes even larger problems to emerge. The maximum deviation off the baseline shifts unequally. In the case of sheep, goat,
and grizzly, the most residents can gain off the baseline is 5%,
going from 75% to 80%, because the outfitter minimum is 20%.
But at the same time they can lose 15%, going from 75% to 60%,
because their minimum for sheep goat and grizzly is 60%. The
inverse applies to outfitters for the other species; they can only
gain 5% for moose, elk, and caribou, but can lose 15%. The math
is clearly not balanced when deviation from the baseline can only
go 5% one way but 15% the other.
This may appear to be some sort of equal trade off, with one
Table 1: Maximum possible allocation loss (%) for residents and outfitters.
Resident
Min Share
Sheep, Goat, Grizzly 60
Moose, Elk, Caribou 70
Outfitter
Min Share
20
10
Resident
Max % Loss
25
22
Outfitter
Max % Loss
50
67
species possibly going up 5% and down 15% and the other going up 15% and down 5%, but the problem for outfitters is that
not all species are available to all outfitters. If an outfitter doesn’t
have sheep, goat, or grizzly (which many outfitters don’t) then
the trade-off is not fair to them. This sort of trade-off only serves
outfitters with sheep, goat, and grizzly allocations. This results in
preferential treatment of some outfitters over others rather than
a clear and transparent rationale that is fair to all outfitters alike.
Using relative importance as a variable in the Matrix formula creates class distinctions among outfitters and diminishes the importance of local species to local outfitters. Relative importance for outfitters is calculated by taking the hunt
value for a particular species and multiplying it by the average
number of hunters per year. The result is the total hunt value per
species per region. Each allocated species for each region is then
ranked from 1 to 10 based on what percentile the total hunt value
for each species in each region falls into. The end result of this
process is a relative importance number used to rank outfitters.
10
Example 1 (taken directly from the Matrix): Bull Moose in
region 7A—Hunt Value = $8300, Average # hunters = 493.25,
Hunt Value = $8300 × 493.25 = $4,093,975. This falls into the
top 10% of hunt values and is therefore given a relative importance of 10.
Example 2 (taken directly from the Matrix): Bull Moose in
region 4—Hunt Value = $7000, Average # hunters = 58.5, Hunt
Value = $7000 × 58.5 = $409,500. This falls into the 60–70 percentile of hunt values and is therefore given a relative importance
of 7.
This method of calculating importance ignores some key
components. First, outfitters have defined boundaries. If those
boundaries do not include a species ranked at a 10, there is nothing the outfitter can do to change that. Second, each species on
allocation to an outfitter is most important to that outfitter: i.e.,
if an outfitter only has moose quota, then moose have an importance of 10 to that outfitter.
Because outfitters cannot guide anywhere except their defined
territory boundaries, placing the importance of one outfitter in
one region as greater or less than another outfitter in another
region is unfair. Even if the calculation were done on a regional
basis, it would still result in unfair outcomes since, within regions,
not all species are available to all outfitters. The result is that many
species with high rankings are unavailable to most other outfitters, and in some cases entire regions don’t have a single species
ranked greater than a 6. Why should these outfitters be penalized?
To them, those species are of critical importance to the success
of their businesses. If all outfitters could guide in all areas of BC,
then using this method of calculating relative importance might
be tenable, but this is not the case (nor should it be).
In addition, fluctuating the Matrix based on importance gives
distinct Matrix advantages to those outfitters in BC who rank
higher, thus creating a vicious cycle of loss. Because the hunt value is calculated using the average number of hunters, and the average number of hunters is determined by the possible allocation to
an outfitter, those outfitters with higher relative importance will
continue to receive higher numbers of hunters than those with
lower rankings. The result is that lower ranked outfitters receive
less allocation, so they cannot take as many hunters as they did
previously. Their total hunt value will continue to decrease and
they can never recover importance rankings: the vicious cycle of
loss. On the other hand, outfitters with greater rankings will continue to receive higher relative importance rankings because they
If an outfitter only has moose quota, then moose have an importance
of 10 to that outfitter.
Because outfitters cannot guide
anywhere except their defined territory boundaries, this method of
calculating “importance” is unfair.
11
Ultimately, this system ranks outfitters, not regions or species, and
thus creates class distinctions.
The result of categorized importance rankings is class distinctions
between have and have-not outfitters.
“Utilization” penalizes one outfitter for the lack of performance of
another, and it promotes dubious
wildlife management practices.
“Utilization” creates a “use it or
lose it” philosophy and encourages
harvesting without regard to biology and wildlife management.
12
maintain or improve their hunter numbers, which increases their
percentage of allocation, which increases hunter numbers, and
thereby increases relative importance for species those outfitters
have.
The end results of all this ranking from region to region and
species to species is not that regions or species are ranked so
much as each outfitter is ranked, and this creates class distinctions.
Essentially outfitters are ranked on their economic contribution,
and those with lower rankings are deemed less important than
those with higher rankings. This method is extremely unfair to
the individual outfitter and marginalizes outfitters ranked lower.
Telling one business they cannot sell as much as another business because the other business contributes more economically
moves the market towards monopolization. It shifts available
product from lower ranked businesses to higher ranked ones. The
result of categorized importance rankings is an unequal distribution of product, wealth, and influence, creating class distinctions
between have and have-not outfitters. Such disparity is appalling
and not in the best interest of the outfitting industry as a whole.
Using utilization to calculate allocation is also fraught
with problems. Utilization is another variable that penalizes
one outfitter for the lack of performance of another, and it promotes dubious wildlife management practices for both residents
and outfitters. Utilization is calculated based on the number of
animals harvested in a region. For residents, the lack of utilization is muted because of the number of hunters; if one fails to
perform, the loss in utilization is marginal. But for outfitters, of
which there are fewer, and one outfitter has many tags, if an outfitter fails to harvest their quota, all outfitters in the region could see
a Matrix loss and a resulting loss in quota allocation. The utilization of one outfitter affects the entire region, and other outfitters
are punished by circumstances beyond their control.
The concept behind utilization is to transfer allocation from
either residents or outfitters to the other because they aren’t using it and the other group possibly could. This creates a “use it or
lose it” philosophy and encourages harvesting without regard to
biology and wildlife management. Utilization puts pressure on
outfitters and residents alike to harvest at unsustainable levels
simply to maintain future opportunity. Such a utilization policy
reduces the incentive for outfitters and residents to make harvest
decisions based on ecological responsibility. It encourages outfitting businesses to put their immediate financial well-being ahead
of ecological viability, and it also encourages resident hunters to
put their immediate hunting opportunities ahead of longer term
ecological considerations. This is particularly true of species like
goat and grizzly bear where the harvest of females is possible
but not preferable from an ecological stand point. Both resident
hunters and outfitters will be under greater pressure to harvest
females to maintain utilization in the Matrix rather than face
the possibility of opportunity or business losses resulting from
under-utilization. This is also true of quality game management.
Under a utilization regime, there is no incentive to allow animals
to reach a greater age class—quite the opposite.
Mitigating this problem would require a much larger financial
commitment from government in the area of wildlife management. As the incentive to hunters for ecological conservation decreases through utilization, the responsibility for government to
more closely manage wildlife increases. While in the past many
outfitters and resident hunters would refrain from harvesting if
they perceived a problem with populations or quality, outfitters
and resident hunters are now penalized for such a failure to harvest. In order to prevent the ecological problems associated with
“use it or lose it,” the responsibility falls on government to exercise
greater diligence in wildlife management through more frequent
inventories and increased regulation. The majority of sportsmen
and outfitters strongly support responsible and sustainable wildlife management, but utilization undermines these principles and
encourages a culture of killing, not a culture of conservation.
Utilization is strongly tied to economics. If outfitters cannot
sell hunts due to an economic downturn, utilization naturally
decreases. The outfitter is then penalized with a loss of allocation, which means they no longer have a product to sell when the
economy finally rebounds.
But utilization also produces volatile results in the Matrix. Assuming outfitters don’t use their entire allocation, they would
lose allocation, and the resulting allocation would be closer to the
actual harvest rate. But when harvest rates and allocation come
closer together, utilization goes up, and the allocation would increase in the next allocation period. This creates a bounce and
spike effect where utilization never actually stabilizes at a consistent harvest level. This volatility is problematic.
Utilization also ignores infrastructure issues. Harvesting
more animals generally requires more infrastructure (more hunters requires more cabins, ATVs, boats, and guides). If the outfitter doesn’t have the cash to invest in new infrastructure, the increased allocation will go under-utilized.
The overall effects of using a fluctuating matrix based on utilization and importance and bounded by minimum shares is industry volatility, business uncertainty, and barriers to investment
and industry growth. It creates a great deal of instability in the
Because “utilization” reduces the
incentive for hunters to harvest
responsibly, the government’s role
in wildlife management must increase.
The principle of “utilization” encourages a culture of killing, not a
culture of conservation.
“Utilization” also creates a bounce
and spike effect in allocations and
never stabilizes at a consistent harvest level, creating problematic
volatility for outfitters.
13
The Matrix is inflexible from a
managerial point of view and extremely volatile from a mathematical point of view, rendering the
policy untenable.
outfitting industry. So while the Matrix is inflexible from a managerial point of view, it is also extremely volatile from a mathematical point of view. The idea may have been well intentioned and
good, but it is so profoundly flawed that its failure is inevitable.
For outfitters, resident hunters, and the wildlife affected by these
policies, it is far better to admit failure and begin again than to
attempt to force a flawed policy to work. The fluctuating matrix
must be eliminated and replaced.
Amendments to the policy
There have been several amendments made to try to mitigate and
address deficiencies in this policy. These amendments include:
▶▶
▶▶
▶▶
▶▶
▶▶
▶▶
20% hardship rule (2007–2011)
30% hardship rule (2012 only)
10% cap on change to outfitters matrix allocation
Thinhorn sheep removed from matrix
Dampening utilization from 1–10 to 1–4
Quota variance principle
None of these amendments succeed to address the fundamental problems with the Matrix itself and the removal of managerial
tools.
Pragmatic Examination of the Matrix
The current allocation policy has created a crisis in the outfitting
industry, as the following table shows.
Table 2: Changes in allocation caused by implementation of the Matrix.
Region
1
1
1
2
3
3
3
3
14
Species
Grizzly Bear
Elk (bull)
Elk (archery)
Elk (bull)
Grizzly Bear
Moose (bull)
Goat
Bighorn Sheep
Outfitter Allocation
Pre-Matrix Matrix
53
31
10
17
50
17
20
19
10
25
5
11
26
29
30
23
% Change
-42
70
-66
-5
150
120
12
-23
Region
4
4
4
4
5
5
5
5
6North
6North
6North
6North
6North
6South
6South
6South
7A
7A
7A
7B
7B
7B
7B
7B
7B
8
8
8
8
Species
Grizzly Bear
Moose (bull)
Goat
Bighorn Sheep
Grizzly Bear
Caribou (bull)
Moose (bull)
Goat
Moose (bull)
Caribou (bull)
Goat
Thinhorn
Sheep (dall)
Grizzly Bear
Moose (bull)
Goat
Grizzly Bear
Grizzly Bear
Moose (bull)
Moose (cow)
Grizzly Bear
Thinhorn Sheep
Elk (antlerless)
Elk (either sex)
Bison
Goat
Grizzly Bear
Moose (bull)
Goat
Bighorn Sheep
Outfitter Allocation
Pre-Matrix Matrix
30
27
29
19
26
31
25
33
38
21
20
29
22
23
43
27
na
30
47
25
37
35
40
21
% Change
-10
-34
19
32
-45
45
5
-37
na
-47
-5
-48
50
19
25
50
50
15
22
50
23
10
na
20
25
na
19
39
35
-34
32
16
-38
-30
53
-91
-46
na
-80
na
15
-8
na
0
-36
-17
33
25
29
31
35
23
2
27
na
2
22
23
23
25
19
25
29
As you can see, the volatility is significant. For outfitters, 20
of 36 species are reduced (15 of those are reduced by more than
20%). Only 1 remains static, leaving a gain in 12 species, 7 of
which are more than 20%. These data, however, don’t capture
additional losses created by the removal of the managerial tools,
which can only be determined on an outfitter-by-outfitter basis.
Let’s examine Region 4, for example. The Matrix shows a 19%
increase in goat allocation and a 32% increase in big horn sheep
allocation. However, after taking into consideration the loss of
The Matrix does not capture additional losses created by the removal of the managerial tools. The
full extent of the damage can only
be determined on an outfitter-byoutfitter basis.
15
This example shows how while the
Matrix shows the allocation for a
particular outfitter increasing, the
removal of managerial tools results
in a dramatic decrease in quota.
16
managerial tools, here are the actual numbers. The goat allocation
actually went from 502 to 264, a 47% loss. The sheep allocation
likewise went from 147 to 68, a 54% loss. Moose and grizzly also
suffered greater losses than the Matrix alone predicted. Moose
went from 342 to 199, a 42% loss instead of the 34% the Matrix
calculated. Grizzly allocation went from 184 to 42, a 77% loss, a
far cry from the 10% loss calculated by the Matrix. Clearly the
Matrix alone does not tell the whole story, and managerial tools
are a significant part of the process. The removal of managerial
tools does not affect all outfitters within a region equally. Some
are affected positively, whereas others negatively.
Understanding how the Matrix and loss of managerial tools
affects allocation is best described by an example. The following
describes an outfitter from region 7A.
Prior to 2007, the allocation was 85/15 for the region. Outfitters and residents both had access to immature bulls in a general
open season (GOS). Resident allocation included a 50% inflation due to success factors and outfitters had a 65% success factor
inflation. In this example, one outfitter had two territories. The
allocation for these territories had been set many decades earlier
based primarily on business needs.
The outfitter had one territory (Area A) with 10 bull moose
tags and 4 cow moose tags on a territory about 80,000 ha. He
had also recently purchased a second territory (Area B) about
160,000 ha with 8 bull moose and 2 cow moose tags. Between the
two areas, the outfitter was harvesting an average of 17 bulls per
year (including immature on GOS), and 3 cows, with the majority coming from Area A because of the infrastructure.
In 2007, the new allocation policy was partially implemented.
Allocations were changed to an area-based calculation, outfitters
were no longer allowed to harvest immature bulls under GOS
(residents retained the immature GOS), and a new allocation of
82/18 from the Matrix was implemented. This allocation kept
the success factor inflations. See Table 3 for the changes to the
outfitter’s actual quota.
Area A saw a decrease in bull moose quota of about 14% and
a decrease of 25% in cow moose. Area B saw an increase of 115%
for bulls and 67% for cows. The primary reason for the large
change was the shift to area-based allocation, because Area A was
half the size of Area B but had the larger quota. It should also
be remembered that the GOS for immature bulls was lost during
this time as well, which accounted for 2 or 3 bulls harvested each
year as well. Cow quota would have been reduced much further
(to 2%) except a 20% hardship rule was temporarily enacted to
prevent the total collapse of antlerless quota for this outfitter.
The change in allocation was problematic, although it appears
to be beneficial overall. Area A had the majority of infrastructure,
while Area B had the majority of quota. The loss of allocation and
immature bull GOS for Area A was a problem for this outfitter,
and while the allocation increase for Area B was welcomed, the
outfitter was never able to capitalize on this, lacking the ability to
invest more money into infrastructure in that area. The end result
was under-utilization: the outfitter harvested 100% of the quota
in Area A, while only harvesting about 60% of the quota in Area B.
This under-utilization later contributed to a regional utilization of
3 on the Matrix.
Table 3: Actual changes to moose quota in two areas: Pre-Matrix, amended Matrix, unamended Matrix.
Area A
Pre-2007
Bulls Allocation % 15
Quota
10
Cows Allocation % 22
Quota
4
2007–11
18
8.6
2
3*
2012–16
20
6.4
2
0.2
Area B
Pre-2007
15
8
22
3
2007–11
18
17.2
2
5*
2012–16
20
12.6
2
0.4
* The quota did not drop as much as it should have because of a temporary hardship rule.
In 2012, the Matrix produced an allocation of 77/23 (outfitters lost 2% because of under-utilization). The 10% rule amendment, however, meant the allocation could only increase by 10%
of 18% = 1.8%. So, rounded up, the allocation was actually set
to 80/20. Inflation due to success factors was also taken out of
the equation. With the expiration of the 20% “hardship rule,” the
minimum shares allocation of 98/2 was applied to the antlerless
cows. The following table demonstrates the flow of quota over
the three time periods.
Apart from the catastrophic loss of cow allocation, from the
point of view of the Matrix, the allocation for these two areas
steadily climbed from 15% to 18% to 20%, and will continue to
climb to 23% once the 10% rule expires. However, this clearly
does not coincide with the actual changes in quota. Area A saw
a steady decrease for each time period while Area B had a sharp
jump and then a sharp drop. So the Matrix is not the sole problem;
the loss of managerial tools has a huge impact. This example also
helps explain why there is such a wide variety of circumstances
across the province, within each region and from outfitter to outfitter. Between the two areas, this outfitter technically had a total
of 18 bulls before 2007, and he had a total of 19 bulls after 2012,
which appears to be a small increase. The intervening 5 years be-
The Matrix is not the sole problem,
nor does it tell the whole story. The
loss of managerial tools is an essential part of the crisis.
17
Quota changes due to the loss of
managerial tools does not affect
outfitters equally. Some few experience increases, but most suffer
serious losses. This new allocation
policy fails to respond to the individual circumstances of outfitters,
and the amendments designed
to alleviate hardships in fact increased them.
tween 2007 and 2012 should not be ignored here, though. This
outfitter was planning on a larger quota and had begun to make
more infrastructure investments to utilize that quota, which came
to a screaming halt in 2012 once he realized this was now impossible. Keep in mind, if this had been two separate outfitters, one
would be in crisis and the other panicking to find a way to use the
new quota. The quota change due to the loss of managerial tools
by no means affected outfitters equally, with very few experiencing increases and most suffering losses. This new allocation policy
fails completely to respond to the individual circumstances of
outfitters, and the amendments (such as the 10% rule) designed
to alleviate hardships across the province in fact increased them
in region 7A. In fact, in 2012 (now delayed to 2013), every outfitter in Region 7A saw a 30% loss in allocation when compared to
the 2007–2011 time period, and this loss would have only been
about 20% had the 10% hardship rule not been implemented.
Many similar examples like this exist across the province. A
few outfitters are experiencing marginal gains while others suffer
catastrophic losses. As a direct result of the Matrix, outfitters lose
allocation for 20 out of 36 species, or 56%. It is difficult to tell
how many lose as a direct result of the loss of managerial tools,
because this can only be assessed for outfitters one at a time;
however, the losses are anecdotally very high. Many outfitters
are losing huge percentages of allocation because of the move to
area-based allocation, loss of vacant area allocations, and the removal of success factor inflation all being done at the same time.
The Balanced Allocation Plan:
Rebalancing the Equation
The existing allocation policy will
decimate the outfitting industry,
but reverting to the previous policy fails to acknowledge its deficiencies.
We need to balance the opaque but
flexible human component with
the transparent but rigid mathematical component.
18
Allocation needs to be calculated differently. The existing allocation process will decimate the outfitting industry, but reverting
to the previous policy fails to acknowledge its deficiencies. The
old policy created an inconsistent allocation situation due to the
overly liberal use of managerial tools, but the new allocation has
created a structured formula based on dubious variables with no
managerial flexibility. The way forward is to balance the equation:
we need to balance the opaque but flexible human component
with the transparent but rigid mathematical component. The Balanced Allocation Plan proposes the following:
The allocation would be set provincially for all species at 70%
minimum for resident hunters and 20% minimum for outfitters,
creating a 10% range of flexibility between 70–80% for residents
and 20–30% for outfitters (notated as 70/20+10). Within this
range of flexibility, regional managers have the discretion to make
additional allocations to outfitters based on managerial tools and
considerations, including:
▶▶
▶▶
▶▶
▶▶
▶▶
▶▶
▶▶
The answer is the mathematical
baseline (70/20+10) consistent
across all species and the reinstatement of important managerial
tools.
Previous allocations
Business needs
Remote area multipliers
Vacant area allocation
Hunting pressure factors
Harvest levels
Economic considerations
Allocations would continue to be based on habitat area.
Administrative guidelines allowing a 30% harvest of a 5 year
allocation within 1 year would remain as the replacement for success rate inflation for outfitters.
All species under GOS for residents would be GOS for outfitters as well.
Since any new plan will result in loss somewhere, the Balanced Allocation Plan gives the regional managers the authority
and tools necessary to address outfitter losses caused by implementation by doing the following:
Area-based and administrative
guidelines are retained.
GOS is equal for outfitters and residents.
Regional managers are given authority and tools to mitigate outfitter losses due to implementation.
▶▶ Assess impact of the policy on each individual outfitter
▶▶ Set the initial allocation for each individual outfitter within the range of flexibility after considering the impacts on
the outfitter and their historical allocations.
▶▶ W here there is deemed to be a hardship to the outfitter,
the regional manager may:
▷▷ Amalgamate the outfitter’s territory with an adjacent
vacant area.
▷▷ Facilitate the changing of several outfitter territory
boundaries to incorporate allocating vacant areas
equally across each region.
▷▷ Facilitate the purchase of smaller areas to amalgamate
with another outfitter’s territory.
▷▷ Offer other solutions deemed necessary to minimize
impact to outfitters.
▶▶ Make changes to wildlife management unit boundaries
and hunting regulations where these are considered an
obstacle to implementation and minimizing impacts on
outfitters.
19
The Mathematical Formula:
Fixed Range of Allocation Flexibility
70/20+10 means a 70% minimum
share for resident hunters, 20%
minimum share for outfitters, and
a 10% range of flexibility, allocated
by regional managers.
The allocation would be set provincially for all species at 70%
minimum for resident hunters and 20% minimum for outfitters,
creating a 10% range of flexibility between 70–80% for residents
and 20–30% for outfitters. This range was carefully calculated,
as described later in this submission. This new formula would
replace the fluctuating matrix. Regional managers would be responsible for allocating the remaining 10% as appropriate. Preferential treatment for certain species is removed. This method
is simple, clear, and easy to understand. Eliminating the Matrix
eliminates the total mathematical control over allocation, but the
new method doesn’t return total control back to regional managers, either. The fixed range of allocation flexibility is the balance
between the two approaches.
The Math Behind 70/20+10
It is desirable to provide a range
within which a human manager
can operate, while providing a degree of stability and structure that
allows participants to reasonably
predict outcomes.
“Capture rate” represents the
number of allocated species whose
allocation would not be forcibly reduced by the Balanced Allocation
Plan.
“Maximum % loss” represents the
absolute most an outfitter could
possibly lose in an allocation period under the Balanced Allocation
Plan.
20
The goal of the Balanced Allocation Plan is to find the balance
between the opaque but flexible system that existed before the
Matrix, and the transparent but rigid system that the Matrix introduced. In order to balance these, it is desirable to provide a
range within which a human manager can operate, while providing a degree of stability and structure that allows the participants
to reasonably predict outcomes.
To determine the optimal range of flexibility, we need to examine the concepts of “capture rate” and “maximum % loss.” Capture rate is calculated by comparing previous allocation numbers
(pre-Matrix and Matrix) to the maximum possible share under
the Balanced Allocation Plan. The capture rate represents the
number of allocated species whose allocation would not be forcibly reduced by the Balanced Allocation Plan (the higher the rate
the better). Maximum % loss represents the most an outfitter
could possibly lose per allocation period under the Balanced Allocation Plan (the lower the number the better).
From a mathematical perspective, there is no optimal tradeoff between maximum % loss and capture rate. This must be determined intuitively. Intuition, however, should be informed by
hard data, which is presented and discussed below.
Table 4 examines a reasonable range of possible splits and
ranges of flexibility. The first 4 rows of each table list the capture
rates for residents and outfitters for the pre-Matrix and Matrix
time periods. Taking the average between resident and outfitter
capture rates allows one to determine the optimal split—the one
that captures the most for both residents and outfitters. The maximum % loss is also included for each split.
One immediately sees that the optimal split for each table falls
at the 70% point for resident allocation. What is left to be determined is the ideal range of flexibility: 5, 10, or 15%. The maximum % loss ranges from 17% to 50%. Clearly, a 50% loss is unacceptable from a business perspective, but the narrow range of
flexibility (5%) for a maximum loss of 17% is clearly insufficient
Table 4: Capture and maximum loss rates for various minimum share values and ranges of flexibility.
60/30+10
Resident Pre-Matrix
44
Capture % Matrix
22
Outfitter Pre-Matrix
78
Capture % Matrix
100
Pre-Matrix Avg.
61
Matrix Avg.
61
Total Avg.
61
% Max Outfitter Loss 25
65/25+10
67
56
67
100
67
78
72.5
29
70/20+10
81
75
64
81
72.5
78
75.25
33
75/15+10
89
89
47
58
68
73.5
70.75
40
80/10+10
97
92
28
25
62.5
58.5
60.5
50
60/25+15
R-Capture Pre-Matrix
67
Rate (%) Matrix
56
O-Capture Pre-Matrix
78
Rate (%) Matrix
100
Pre-Matrix Avg.
72.5
Matrix Avg.
78
Total Avg.
75.25
% Max Outfitter Loss 38
65/20+15
81
75
67
100
74
87.5
80.75
43
70/15+15
89
89
64
81
76.5
85
80.75
50
75/10+15
97
92
47
58
72
75
73.5
60
80/5+15
100
92
28
25
64
58.5
61.25
75
60/35+5
R-Capture Pre-Matrix
36
Rate (%) Matrix
6
O-Capture Pre-Matrix
78
Rate (%) Matrix
100
Pre-Matrix Avg.
57
Matrix Avg.
53
Total Avg.
55
% Max Outfitter Loss 13
65/30+5
44
22
67
100
55.5
61
58.25
14
70/25+5
67
56
64
81
65.5
68.5
67
17
75/20+5
81
75
47
58
64
66.5
65.25
20
80/15+5
89
89
28
25
58.5
57
57.75
25
21
A 10% range of flexibility and a
maximum percent loss of 33% is
a reasonable balance between the
various extremes.
to make allocation decisions by regional managers meaningful
and effective. This leaves us with a 10% range of flexibility and a
maximum % loss of 33%, which is a reasonable balance given that
the maximum % loss under the pre-Matrix policy was essentially
0% and the maximum % loss under the Matrix is a catastrophic
67% (see Table 1). It is critically important to understand the
difference between the Matrix and the Balanced Allocation Plan.
The reimplementation of managerial tools means that allocations
don’t always have to change because the math says so. There is a
certain leeway. So while the maximum loss is 33%, it is in no way
an expected loss, and such a loss would be accompanied with a
justifiable rationale from the regional manager.
This is how the 70/20+10 split put forward by the Balanced
Allocation Plan was determined. Coincidentally, that range of
flexibility matches with the maximum minimum share values
for residents of 70% and outfitters of 20% that was determined
through negotiation.
Now that the optimum range for both residents and outfitters
has been established, let’s examine exactly what species in what
regions are not captured by the range of flexibility introduced by
the Balanced Allocation Plan.
Table 5: Resident allocations that are forcibly reduced compared to preMatrix allocations.
Region
1
3
3
6South
7A
7B
8
Species
Elk (bull)
Grizzly bear
Moose (bull)
Moose (bull)
Moose (bull)
Elk (anterless)
Moose (bull)
% Allocation Loss
10
10
15
1
5
10
1
Table 6: Outfitter allocations that are forcibly reduced compared to preMatrix allocations.
Region
1
1
5
5
22
Species
Grizzly bear
Elk (archery)
Grizzly bear
Goat
% Allocation Loss
23
20
8
13
Region
6North
6North
6North
6North
6South
7A
7B
8
8
Species
Caribou (bull)
Goat
Thinhorn
Sheep (Dall)
Grizzly bear
Grizzly bear
Grizzly bear
Grizzly bear
Goat
Bighorn sheep
% Allocation Loss
17
7
10
20
20
20
20
9
5
When comparing the Balanced Allocation Plan to the pre-Matrix allocations, 13 species are forcibly reduced for outfitters and
7 for residents. This is a clear improvement over the Matrix policy
which forcibly reduced the allocations for 20 species for outfitters and 12 for residents. It should be noted that the Balanced
Allocation Plan does not prescribe allocations like the Matrix
does. Regional managers have discretionary authority within the
range of flexibility. There are 10 additional outfitter species and
11 resident species that could conceivably be reduced by regional
managers under the Balanced Allocation Plan if they deemed it
appropriate.
Regional managers have discretionary authority to adjust allocations within the range of flexibility.
Number of Species Affected by the Balanced Allocation Plan
Outfitters
13 Species
Static or Improved
10 Species
Flexible Allocation
13 Species
Forcibly Reduced
Residents
18 Species
Static or Improved
11 Species
Flexible Allocation
7 Species
Forcibly Reduced
23
The Human Formula: Managerial Tools
The 10% window would be managed by the regional manager using the managerial tools already available to them including:
▶▶
▶▶
▶▶
▶▶
▶▶
▶▶
▶▶
Regional managers will have access
to many tools and can consider
many factors when determining allocations.
These decisions would be accompanied by a clear rationale and
would be constrained by the fixed
10% range of flexibility.
Previous allocations
Business needs
Remote area multipliers
Vacant area allocation
Hunting pressure factors
Harvest levels
Other economic factors
Issues of “utilization” (harvest levels) and “relative importance” (economic factors) still exist, but they are only part of
what a regional manager would consider when making decisions,
and these variables would only have influence over the narrow
10% window of flexibility. Under the new model, regional managers can look at individual guide harvest levels and the importance
of each species to each guide in order to set allocations. In addition, the new model is not limited to those factors alone: regional
managers may consider other factors that are relevant or specific
to their region.
Under the new method, regional managers would have the
discretion to choose what the best allocation for residents and
outfitters is within this range of flexibility. Regional managers
would be expected to provide a clear and transparent rationale
for why they set the allocation where they did, and they could
make changes within their regions from outfitter to outfitter if
necessary. But all these decisions would be constrained by the
fixed 10% range of flexibility, and residents and outfitters would
still have access to the Environmental Appeal Board if a manager’s rationale was erroneous or inappropriate. This is the balance
between the human and the mathematical approaches.
Inevitable Loss: Remedies
There is no “impact neutral” way to
proceed. Losses are inevitable.
24
Neither the Balanced Allocation Plan, the Matrix, nor any other
solution can be impact neutral. There must be changes to correct
the deficiencies of the past, but these changes do not necessarily
mean there must be absolute losses to outfitters. There are ways
to mitigate the impacts.
There are some good ideas coming out of the previous policy
that should be retained because they create a stronger industry
and better ecological management: administrative guidelines
and area-based allocations, to name the two most prominent. But
these cannot be implemented without some loss to the outfitting
industry, since outfitters lose the inflation based on success factors, and their quota changes to reflect their actual habitat. There
are ways to minimize these losses, however, and the Balanced Allocation Plan extends to regional managers the authority to examine and address the negative effects of these changes. Possible
remedies include:
There are, however, ways to minimize these losses.
▶▶ S etting the initial allocation for each individual outfitter
within the range of flexibility after considering the impacts on the outfitter and their historical allocations.
This gives the regional managers the ability to ensure a fair
share to each outfitter based on their historical share if negatively
impacted. This alone may solve the impact problems for many
outfitters, but if the outfitter share was greater than the 30%, additional remedies will be needed. For some outfitters, the most
recent allocation policy was a boon and they made business
plans on those new numbers. This should also be taken into consideration by the regional manager when making his decisions.
However, it is entirely possible that a regional manager deems an
outfitter’s allocation to be unjustified, and he could conceivably
reduce allocations within the range of flexibility. Regional managers would be required to provide a clear, written rationale for
such a decision. If outfitters felt the decision was unjustified or
erroneous in some way, they would have recourse to the Environmental Appeal Board.
Regional managers could conceivably reduce allocations within the
range of flexibility, if warranted.
▶▶ W
here there is deemed to be a hardship to the outfitter,
the regional manager may:
▷▷ Amalgamate the outfitter’s territory with an adjacent
vacant area.
▷▷ Facilitate the changing of several outfitter territory
boundaries to incorporate allocating vacant areas
equally across each region.
▷▷ Facilitate the purchase of smaller areas to amalgamate
with another outfitter’s territory.
There exists many vacant areas throughout BC, and it makes
rational sense to amalgamate adjacent vacant areas with affected
outfitters in order to offset losses. However, the actual vacant area
may not be immediately adjacent to an affected outfitter. In this
case the regional manager would act as a facilitator to bring outfitters together to discuss possible territory boundary changes
There exists many vacant areas
throughout BC, and it makes sense
to be able to amalgamate adjacent
vacant areas with affected outfitters in order to offset losses.
25
Regional managers will need to
work with outfitters on a consensus basis.
to allow these vacant areas to be divided up equally among all
outfitters. In conjunction with this, there may exist opportunities
to amalgamate smaller territories into larger ones, if outfitters are
willing to sell their territories. The regional manager would not
have authority to force the changes upon an unwilling outfitter,
and so he will need to work on a consensus basis with outfitters
to find solutions. This will be a complicated process, but if all parties act in good faith, a consensus-based solution is the best way
to mitigate losses.
▶▶ M
ake changes to wildlife management unit boundaries
and hunting regulations where these are considered an
obstacle to implementation and minimizing impacts on
outfitters.
It may very well be that it is not territorial boundaries that are
the obstacle to implementation but WMU boundaries. The regional manager should examine changes to these boundaries and
regulations as a potential option.
Conclusion
The fixed range of allocation flexibility, coupled with managerial
tools, removes most of the uncertainty and volatility from the allocation process.
We can promote greater tourism
opportunity through outfitting and
greater outfitting through tourism.
26
There can be no doubt that if the current allocation policy (the
Matrix) remains in place, the future of outfitting will begin a longterm decline. The policy will result in massive quota losses to outfitters across the province, a reduction in the number of viable
outfitters, a withdrawal of investment from BC, and the end of
the family outfitter, to name a few.
The Balanced Allocation Plan aims to redirect this course. It
is imperative to repair the damage done by the new policy by immediately implementing the Balanced Allocation Plan. The fixed
range of allocation flexibility, coupled with managerial tools, removes most of the uncertainty and volatility from the allocation
process. The Balanced Allocation Plan addresses most of the negative effects of the current policy and allows for a viable industry
to thrive.
In the past, the Outsteading era led to tremendous growth in
outfitting, but the industry has stagnated and perhaps even contracted somewhat with the Neofitter era. Most of the provincial
tourism machine has divorced itself from outfitting, in spite of
the close historical connection between the two. With concerted
effort and bold action, there is the potential to remarry the two
and promote greater tourism opportunity through outfitting and
greater outfitting through tourism. Outfitters are hopeful that the
future of outfitting will lead us into an era of prosperity, but that
can only be made possible with bold leadership and new ideas.
For resident hunters, the real issue has always been hunting
opportunity and the fear that outfitters are reducing this opportunity. Any honest examination of the allocation process, whether
pre-Matrix, Matrix, or Balanced Allocation Plan, must conclude
that real hunting opportunity is not controlled by the allocation
process so much as by the Annual Allowable Harvest (AAH).
The hunting industry is unique among natural resource industries, such as mining and logging, in that businesses (outfitters)
compete directly with residents. Fortunately it is also unique in
that it is a resource that renews quickly (10-year cycles, as opposed to 100 years for logging, for example) and so with proper
management can be increased. Allocation policy is the wrong
tool for increasing resident hunter opportunities. Gains due to
allocation are always limited by the AAH, and gains will always
be marginal because residents already enjoy a much larger share
of the allocation. However, if you can increase the AAH, this will
always result in increased opportunity for resident hunters, and
that opportunity always grows at a greater rate than for outfitters,
again because residents enjoy a larger portion of allocation. Imagine, if you will, a species allocated at 70/30 with 100 animals to
allocate under the AAH. Residents get 70, and outfitters get 30.
Residents could potentially improve their allocation by a small
amount from 70 to 80, but this would be at the expense of outfitters. But consider that if government focused effort and resources
on improving the game population and succeeded in increasing
the AAH for that species from 100 to 200, resident don’t go from
70 to 80, but from 70 to 140. And that means real new opportunity for resident hunters.
The government rightly decided that the old allocation policy
needed to be changed. They wanted a policy that was “consistent
and transparent,” “objective and data-based,” and, most importantly, “reflective of stakeholders’ interests.” The Matrix might
satisfy the first two objectives, but it clearly fails to meet the third.
The Balanced Allocation Plan addresses all these needs, and its
implementation would make it possible to begin making real improvement to resident hunting opportunity through increasing
the AAH. The argument needs to move from how to divide the
pie to how to make the pie bigger. There are already more species
to hunt in BC than any other single jurisdiction in North America. It’s tough to improve on that sort of hunting opportunity, so
the focus needs to be on better wildlife management and growing wildlife populations to improve the AAH.
Any honest examination of the allocation process must conclude
that real hunting opportunity is
not controlled by the allocation
process so much as by the Annual
Allowable Harvest (AAH).
Allocation policy is the wrong tool
for increasing resident hunter opportunities.
The old allocation policy needed to
be changed, but change is possible
without putting outfitters out of
business.
The argument needs to move from
how to divide the pie to how to
make the pie bigger.
27
Appendix A: Trumpy Report
“Harvest Allocation Policy Review”
Overall, the Trumpy Report “Harvest Allocation Policy Review”
is quite critical of the policy. It identifies several specific impacts
of implementing the policy (pp. 19–20):
▶▶ O
verall the number of animals guides have access to will
fall, in some cases dramatically, but there are a few cases
where guides will have small increases
▶▶ The value of guide outfitting territories will fall where
there is a reduction in the number of animals available.
▶▶ Some guide outfitters will fail.
▶▶ The incentive to “use or lose” allocation share will result
in behaviours inconsistent with good wildlife stewardship.
▶▶ Successful guides will be negatively affected when other
guides in their region fail to harvest animals.
Like the Balanced Allocation Plan, the Trumpy Report identifies
the historical and present problems with the allocation policy as
being in the past, too inconsistent, but in the present, too inflexible.
Although the new policy is transparent and consistent,
it is too inflexible to deal with the diversity of circumstances that exist throughout the province. (p. 4)
Trumpy identifies the challenges inherent in the discretion of regional managers:
When government regulation provides regulators
with little discretion there are inevitably unfair results.
Where regulators have too much discretion the result
is that decisions are described as inconsistent. (p. 16)
Prefacing his recommendations, Trumpy offers this opinion:
The Harvest Allocation Policy is intended to bring consistency, fairness, equity and transparency to a system
which was inconsistent, inequitable and not very transparent. In doing so it has failed to be fair because it does
not take into account temporary circumstances, access
differences, or the impact of individual guide behaviour
on other guides. (p. 20)
29
The Balanced Allocation Plan identifies the same problems in the
policy that Trumpy does but goes one step further to examine
the mathematical flaws that Trumpy failed to recognize. But more
importantly, the Balanced Allocation Plan encompasses the core
recommendations of the Trumpy Report, though the Balanced
Allocation Plan was not written with the intention of accommodating Trumpy. Of the eleven recommendations from Trumpy,
seven fall within the Balanced Allocation Plan, three are neutral
and don’t affect the Balanced Allocation Plan either way, and one
is contrary. Below I have examined the recommendations from
Trumpy and how the Balanced Allocation Plan affects these recommendations:
Recommendation from Trumpy that are
encompassed by the Balanced Allocation Plan
Recommendation 1—The split between resident and
guided hunters should not be set by species at the regional level using the new allocation model. While the
model should inform the decision, the Ministry should
also consider actual splits using data available for the
last 10 years and circumstances unique to each region.
A base level of guided hunter split should be available
to every guide but regional managers should have some
discretion to allocate individual guide share above the
base level up to a regional split determined by the Ministry
What Trumpy is essentially calling for here is the return of powers to the regional manager to determine allocations from a baseline. While not exactly what the Balanced Allocation Plan proposes, this does fall within the Balanced Allocation Plan concept
of a 70/20+10 split, where the baseline is 70/20 and the regional
managers determine where within this range the allocation falls
based on whatever factors they find relevant.
Recommendation 3—Allocation within a region to
individual guides should consider access, level of resident hunter activity and be determined by the regional
manager. The reasons for variances from the base level
of regional splits should be disclosed.
Again, this is returning discretional powers to the regional manager, which is central to the Balanced Allocation Plan, allowing
the regional managers a 10% window of flexibility.
30
Recommendation 5—All of the allocation in areas
where there are no guide territories should be allocated
to resident hunters.
This is consistent with an area based allocation, which the Balanced Allocation Plan advocates.
Recommendation 6—Species of GOS for residents
should not be on quota for guides.
This is also called for directly by the Balanced Allocation Plan.
Recommendation 8—Regional managers should
have access to a wide range of tools to support the industry achievement of its split, at both the regional and
individual guide level. Tools dropped in the new policy
should be reconsidered and new options explored provided they are consistent with good wildlife stewardship.
Here is another recommendation which returns discretionary
powers to the regional manager, as is also advocated by the Balanced Allocation Plan.
Recommendation 10—The Ministry needs to clarify
its policy for vacant guide territories to provide certainty for the industry. Fractional sales which provide
marginal additions to strengthen existing operations
should proceed.
The Balanced Allocation Plan advocates using vacant areas to offset losses to outfitters in the implementation process.
Recommendation 11—The Ministry should consider
facilitating the consolidation of guide territories in regions where small territories are the norm to encourage
more viable operations.
The Balanced Allocation Plan advocates the regional manager
acting as a non-binding facilitator to amalgamate smaller territories as part of the implementation process.
31
Recommendation from Trumpy that are neutral
in regards to the Balanced Allocation Plan
Recommendation 2—The splits should be set, beginning in 2012, for a minimum of 10 years.
The Balanced Allocation Plan does not expressly call for this.
Whether this recommendation is implemented or not does not
affect the core concept of the Balanced Allocation Plan. It should
be noted here though that a 10 year allocation as opposed to a 5
year allocation limits the degree of flexibility regional managers
have to respond to changing circumstances. On the other hand, it
provides for longer term security for outfitters.
Recommendation 4—Individual guides with smal­ler
allocations (less than 5 animals over a 5 year period)
should be permitted to harvest all their allocation in a
single year provided there is no impact on population
sustainability.
This works within the Balanced Allocation Plan, but is not necessary for Balanced Allocation Plan to work. I believe government
has already implemented this recommendation.
Recommendation 9—Guides not utilizing their allocation should be encouraged or required to transfer it
to guides in adjacent territories provided there are no
negative impacts on population sustainability.
This recommendation is made irrelevant with the Balanced Allocation Plan, because utilization no longer exists as a controlling
factor in the process. However, a temporary transferal of allocation from outfitter to outfitter is certainly one tool that could be
used by regional managers if they felt it necessary, though this
concept is problematic with an area based allocation. It would
have to be temporary to work with express agreement between
both outfitters or else the policy would run the risk of falling into
previous allocation problems of unfairness.
Recommendation from Trumpy that are
contrary to the Balanced Allocation Plan
Recommendation 7—If a guide in a region fail to use
their allocation over a two or three year period then
it should be made available on a temporary basis to
32
residents through a one or two year increase in LEH
authorizations where such actions have no impact on
population sustainability. There would be no possibility
for reduction to guide split until the end of the 10 year
period.
This is anathema to the Balanced Allocation Plan, and in particular administrative guidelines. Administrative guidelines allow for
outfitters to harvest 30% of a 5 year allocation in 1 year, so an
outfitter could technically harvest 5% in year 1, 5% in year 2, and
then 30% in years 3–5 and still meet their allocation. This would
not be possible if regional managers were constantly shifting allocations from outfitters to residents based on underutilization,
as would happen in this example in the first two years. Allocation
must be fixed, and how and when a regional manager changes allocation must be determined in a predictable fashion. If underutilization were a consistent concern of the regional manager, the
proper time to correct that is in conjunction with all the other
consideration at the end of each allocation period, not in the interim.
The core idea of returning power to the regional managers
with variance from a base level as brought forward by Trumpy
in his recommendations is addressed in the Balanced Allocation
Plan. The Balanced Allocation Plan improves this concept greatly
by establishing mathematically where the baseline should be for
residents and outfitters, and how much flexibility should be given
to regional managers.
Financial Impact
Beyond the recommendations from Trumpy, what is obviously
missing from his report is a more concrete assessment of the financial impact on outfitters. This would take a very thorough examination of the industry, outfitter by outfitter, because while the
matrix changes can easily be calculated and given a value, the impact of the loss of managerial tools is not so easily calculated as it
affects outfitters in the same region very differently. Trumpy readily admits that “At the individual guide level the impact of this
revenue reduction combined with the elimination of tools used
by regional managers could prove catastrophic” (p. 17). There is a
void in available financial data here which will require joint effort
from industry and government to fill by properly assessing the affect policy on an individual basis. If and when these numbers are
forthcoming, the real effects on the industry could then be accurately assessed. In the meantime, using Trumpy’s vague estimate
33
that the “impact on the industry is more than a 10% decline in
revenues” (p. 17) (the actual math calculation is 13–19%) must
also be considered with statements like “The gross industry impact probably understates the impact for a number of individual
guides who will likely fail in the coming years if the new policy is
fully implemented in 2012” (p. 19). These losses are indeterminate without better information.
34