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Opinion: It seems MNR uses imaginary moose to set harvest target

Ontario’s moose population continues to decline, but the Ministry of Natural Resources and Forestry has not adjusted its management practices to encourage the population to grow. Instead, says retired moose biologist Alan Bisset, planners plow ahead using methodologies that just aren’t working
060522_denise kitchin moose
A moose spotted in Chelmsford by reader Denise Kitchin.

When I criticized Ontario’s moose management last October, I did not have access to the information in the data sets I created. The article was based more on management principles, experience and publicly available information, than on current factual harvest planning information. 

I recently received the planning information through a Freedom of Information request and finally had a chance to investigate it more thoroughly. The data sets have been changed substantially from what I developed (“modernized” I guess?) and from what I’ve seen, are less useful for analysis and decision-making. 

It appears the harvest planning data set is used only to record the harvest planning process, but not to develop the plan or to analyze how the hunt went. Important information like how much the harvest deviated from the plan (by unit, tag type, etc.) and what percentage of the actual harvest was taken through tourist outfitters was stripped out. So were the zones I used to include historical information prior to 1983 when harvest assessment was done by districts.

There was nothing at all for the 2021 hunt, although I received the file months after the planning phase was completed. Obviously, it could not have been used for planning last year. 

There appear errors in the database. 

For example, the planned bull harvest in 2019 is 1,880, yet the actual harvest is reported to be 1,927 and one presentation of resident calf harvest is zero in all units. Harvest estimates for 2020 have fractional numbers like “10.6 cows harvested”. There is no reason good reason for this, unless they are computer-simulated results. 

It suggests the information is created, but not carefully reviewed. Such errors, although small and apparently insignificant, might indicate larger issues and carry forward. They should be investigated and corrected. 

Where are all the moose?

For this evaluation, I looked at information from 2017 to 2020. As noted, information from 2021 was not included. Generally, I present the estimates for each year so the reader can see the variation or trends. Initially I thought it was going to be a short, sweet piece, but the more I investigated, the more explanation was required.

There are management units in the far north (1A, 1C, 1D, 24 and 25) open to hunting. They have relatively high population estimates (6,717 moose) based on poor and infrequent surveys. They are also largely inaccessible. The planned harvest averages 592, with 1,677 tags allocated, 1,284 tags issued and an average total harvest of 263 moose. Only 77 per cent of tags were issued, and the harvest was only 44 per cent of planned.

These units are so different from those in the core range that they can mask what is really happening to the larger population.

For example, in 1999, the planned harvest exceeded the plan by eight per cent when these units were included, but by 17 per cent when they were excluded (Footnote 1, p8). Far north zones should be treated as a separate “zone” for harvest assessment purposes. This concept, too, was removed from my database. Information from these units was not included in the following assessment. 

Note that the actual harvest in the far north (262) was much lower than the planned harvest (592). These units are a perfect example of how you can have an apparent “underharvest”. The animals simply weren’t wanted by hunters or were not accessible to harvest. In this instance underharvest as a concept is meaningless.

Southern, accessible units with high hunter numbers may also be “underharvested”, not because of lack of demand, but because the harvest plan is excessive and cannot possibly be achieved. 

Harvests in some units are at 15 to 20 per cent of the population. Those are absurd rates because moose do not have that reproductive potential. 

I expect the province is planning on harvesting moose that move out of Algonquin Park, completely violating the intent of parks protecting wildlife. Another reason (although it’s kind of the same thing) is that the moose simply don’t exist to be harvested, possibly the result of inaccurate population estimates or computer models. Ya just can’t kill something what ain’t there. 

The essence of my management philosophy has been that tag numbers have not controlled the harvest. That should become evident below. Consequently, the kill has been excessive, resulting in the population decline (Footnote 2, p16) I’ve previously noted. For that reason, only one tag should be issued for each animal in the planned harvest to ensure predictable and effective control of the harvest. This gives complete control yet lets everyone hunt.

To make that point clear, I have selected what I consider to be the most basic information to understand the problem at the provincial level. There are still a lot of numbers. The provincial values represent an average of what has been done at the unit level, with some WMUs being better and others worse. 

By the numbers

Following are values from 2017 to 2020 respectively, with my interpretation of their meaning. 

The population available to hunters in the core range WMUs was: 75,132, 73,559, 75,256, and 70,683. 

These are not the aerial population estimates. They are the sum of what management staff believe the population to be in each unit. Individual WMU estimates may be above or below the survey estimate depending on how staff feel about the quality of the last survey and the population trend. These values are considerably lower than the 90,000 used publicly (Footnote 2, p19). 

The drop of 4,600 moose between 2019 and 2020 may be real or just an artifact of the planning process. It does imply that managers believe the population is declining. There is a management principle that if an error is to be made, err on the side of conservation. Therefore, the drop should be thought of as a real decline and plan accordingly — that did not appear to have happened. 

Although the planned harvest decreased, tag numbers remained the same.  

The total planned harvest was: 4,455, 3,932, 3,993, and 3,696. This does not include subsistence harvest. That is a separate and different allocation within the management process and hitherto ignored. It does reflect recognition of a declining population, but still exceeds the recommended harvest for growth. 

I was told (Footnote 3) that four per cent is what is currently recommended. The planned harvest is 5.5 per cent. This exceeds the recommendation by 37 per cent. A harvest planned for growth with the estimated population would be about 2,900 moose.

The planned harvest of bulls was: 1,658, 1,597, 1,585, and 1,613; and of cows: 1,293, 1,206, 1,256, and 1,202. The planned calf harvest was 1,504, 1,147, 1,152, and 881, or 29 per cent of the total harvest. Bulls constitute only 40 per cent and cows, 31 per cent of the harvest.

These ratios differ considerably from the original harvest planning guidelines (Footnote 4) and from the fundamentals of successful harvest planning in Fennoscandia (Footnotes 5,6), that is the hunting system used in Fennoscandia or Fenno-Scandinavia, the region including the Scandinavian Peninsula, Finland, Karelia, and the Kola Peninsula.

During this period, the harvest of calves was reduced from 33 to 23 per cent, while the bull harvest was increased from 37 to 43 per cent and the cow harvest from 29 to 32 per cent. This makes little sense from either game management or animal husbandry perspectives. It also appears to reflect a philosophy that by protecting calves the herd will grow. 

If, as is believed, the calf component of the population is low, then protecting cows, which are more abundant in the population and bear nearly two calves on average each year, is a better solution than trying to protect calves with a high likelihood of “infant mortality”. 

So, within a total harvest that has been decreasing over this period, shifting harvest to more cows and fewer calves simply defies logic. It is not going to help the calf situation and will accelerate a decline because fewer calves will be born. 

I’m not sure what information Ontario biologists possess to lead them to so arrogantly believe they can ignore common sense and what has been proven in other jurisdictions. It most certainly cannot be their glowing record of success.

The number of bull tags allocated (offered to hunters) were: 4,700, 4,478, 4,583, and 4,484.  The number of cow tags allocated were: 5,804, 5,177, 5,537, and 5,641. There were 21 per cent more cow tags than bull tags. The difference, even though the cow harvest is lower, is because it is assumed that cow hunters have less success at filling tags. This will be discussed later as it relates to the evidence that tag numbers do not control kill. 
Although the planned harvest decreased from 4,500 to 3,700 (18 per cent), total tags allocated remained constant at about 10,100 and tags provided to hunters averaged 9,714. Bull and cow tags remained relatively constant at 4,500 and 5,300 respectively. In 2021, 16,826 tags were offered (17,635 in 2022). 

The difference was to provide a controlled number of tags to hitherto uncontrolled calf hunters. 

I asked for the numbers of tags that remained at the end of the new allocation process for 2021 and was directed to a “data catalog” with a Moose Tag Allocation Results file

In 2019, an “open data” policy was implemented. As I allude to below, they really need an open “information” policy. 

The file contains 17,055 records, one for every step in the process, by unit, tag type, choice, hunter points and more. It took a lot of work to get the information I wanted, and If my numbers are to be believed, only 12,286 of the 16,826 tags were claimed, leaving 4,540 (27 per cent) in the pot. Most bull tags (87 per cent) were claimed. That compares with 73 per cent for cows and 54 per cent for calves. 

The numbers appear to reflect demand, but considering the number of hunters, I’m surprised that all tags were not claimed. Perhaps the allocation process didn’t do what they expected?

I think, and recommended, that the group application be retained should my proposal be adopted. 

It would only be required by the highest-point holders in a group because others wouldn’t get tags anyhow. One allocation, no crap about declining to buy allocated tags because someone else in the group got one and you know what your party has on May 15 not Aug. 1. 

On a related note, I don’t understand why hunters getting tags as a second choice do not lose points. They got to hunt with a tag, will probably get a tag in another year or so (because they have high points), and are depriving another hunter with perhaps one less point from an opportunity to get a tag. 

It is an example of the ministry ignoring the fundamental principles of the point system for some unexplained (perhaps to avoid angering hunters) reason.

If my calculations regarding unused tags are wrong, it represents one of the perils and lessons the ministry might learn. 

Giving the public almost entirely useless data and expecting them to turn it into useful information can result in incorrect results and a poor reflection on the ministry’s actions. If they actually cared about misinformation, they would have to write a rebuttal.

I believe it is better to provide the best “information” possible. If that demonstrates you are doing a bad job, then learn from it. There is a chance (apparently slight thought it may be in the minds of MNRF staff) that there is someone out there who is smarter than you, or has a different perspective that you may learn from. The government never subscribed to this philosophy.

Tags issued versus harvest numbers

Unfortunately, there is a tendency to hide unpleasant information and hope nobody notices. Every year that I was inventory program leader, I published an aerial inventory plan, and results of the aerial surveys and harvest assessment (Footnote 1, as an example). I don’t believe this was done by anyone else, before or since. 

The actual harvest was: 3,378, 3,085, 3,592 and 3,054. That averages 18.3 per cent less than planned. The bull harvest was 1,545, 1,376, 1,735, and 1,550, while the cow harvest was 949, 863,1,068 and 912. The calf harvest was 877, 859, 783 and 593.   

Interestingly, but not unexpectedly, the bull harvest was 3.7 per cent below planned, while the cow harvest 23.4 per cent below and the calf harvest 32.3 per cent below. 

The large difference and decline in the calf harvest suggests to me the strategy to build the population by protecting calves isn’t working. 

Tag filling rates — the multiplier from planned harvest to tags — is steady at about 3.8 for bulls, but for cows it has been increasing from 6.6 to 9.5, supporting the belief that more cows need to be killed.

The first thing to note is that there is no predicable correlation between tags and harvest. The three sexes have very different harvest rates. Although the planned cow harvest was constant at 1,200 moose, and tags relatively constant at 5,200, the harvest ranges from 861 to 1,068, roughly a 25 per cent difference, without an apparent pattern. You can’t possibly expect to achieve predicted results when you don’t have effective control of the situation.

The high bull harvest is to be expected. This level of harvest, in combination with a plan that exceeds current recommendations, would be expected to contribute to further population decline. 

The low harvest of calves is also to be expected because calves are not in demand. MNRF concerns about few calves in the population suggests they just aren’t there to be harvested. The low cow harvest should not be expected because they are in demand and supposedly abundant enough to support a kill of 1,200 animals. 

All three of the age/sex classes are pursued by the same 90,000 hunters. Why are they not being killed at the same level as predicted by the plan?

I believe it is because they do not exist in the population as anticipated by plans because of excessive harvest levels and tag allocations. 

The population trend graph presented in the review (Footnote 2, p16) shows a decline from 2003, but a small increase since 2015. I don’t know how that graph was created, and I have not been provided with corroborating evidence (like moose seen or days to harvest a moose), but I am skeptical that it is accurate. 

What I see tells me that the population continues to decline. I would bet that if all the information were presented effectively, it would show a pattern of general overharvest (relative to the plan) (as is reported in Footnote 1) to one equalling the plan, to one of general underharvest.

The underharvest in the face of increasing tag fill rate again suggest cows just aren’t there to kill. That alone should be a wake-up call. In combination with an increasing proportion of the harvest and an excessive overall harvest plan, it will spell disaster for Ontario’s moose population.

If tag numbers did control the harvest, it should be almost identical to that planned in every unit, every year. With the historic pattern of issuing way more tags than the planned harvest, they would vary (presumably slightly), but average out over time (Footnote 1), while still be essentially identical. The fact that they do not is proof positive that tag numbers, as being provided, are not an effective harvest control tool.

The total harvest at about 3,500 exceeds the recommended 2,900 by 17 per cent. What appears to be a significant underharvest in the plan is more likely a significant overharvest in the population.

Planners refer to the “Six Ps” – Poor Planning Precedes P–s Poor Performance. That is my assessment of MNRF’s planning. Plans that fail year over year, whether harvest is above or below, are poor and ineffective plans, yet MNRF staff continue to follow the same failed playbook, but worse are deviating further from it in a more destructive way. 

I appreciate that what I have written is a huge amount to assimilate. To summarize the situation without rehashing it, there are five essential questions: 

  1. Is the total planned harvest at a level that would allow for population growth? Being at 5.5 per cent of the population when the recommendation is four per cent. The answer must be no.
  2. Is the age/sex ratio of the harvest expected to permit growth? Based on the successful programs in other jurisdictions (Footnotes 4, 5), the ratios observed above and 40 years of failure in Ontario, the answer is no.
  3. Does the allocation of tags predictably and effective control the harvest? Again, using the harvest information cited above, the answer is no. 
  4. Is the MNRF using adaptive management to learn and improve management actions? Based on what I have seen in this review, and my career, I would most definitely say not. The problem of overharvest was identified in 2002 (Footnote 1) yet has continued. 
  5. Finally, has MNRF, the Big Game Management Committee or Minister Greg Rickford, learned anything from my experience and the evidence I have presented. Judging from the increased tags this year (again likely due to “underharvest”), I would say not.

I thought I read somewhere that MNRF wants to plan and leave it unchanged for five years. This is to better assess results without being complicated by changes. That is not an unreasonable approach if it is within an effective plan and populations are increasing. 

It strikes me as foolhardy (I’m being polite) to do that when the population is declining, with a plan that deviates substantially from known best practices and replicates the same errors made for the past 20 years or more. 

I was taught that the only thing worse than making a stupid decision, was sticking with it. It seems MNRF staff, and the Big Management Advisory Committee missed that class. 

I would hope for the sake of moose that before I pass on, I will be willing to write a sincere apology stating that I was wrong. In all honesty, I doubt that will happen.

Note to Mr. DAoust: I won’t give up. Thanks for your vote of confidence.

Alan Bisset is a retired regional moose biologist and wildlife inventory program leader with the former Ministry of Natural Resources. He has written and published many papers on moose management, both Internally and in scientific journals. Bisset lives in Strathroy, west of London, Ontario.


1:  Alan R. Bisset. 1990 – 2000 Moose Harvest in Ontario. Ont. Min. Natur. Resour. Northwest Sci & Info. Thunder Bay, Ont. NWSI Technical Report TR-131. 27 pp.

2:  Moose Management Review, 2019. Big Game Management Committee,

3: The current recommended harvest is four per cent for population growth. Personal communication with Phillip DeWitt, Provincial Wildlife Monitoring Program Leader, MNR. 

4: Guidelines for Moose Harvest planning. 1994, Alan R. Bisset. OMNR. Internal document. It is based on, and includes the work done by Craig Greenwood, Dave Euler, and Ken Morrison. 1983. OMNR internal document.

5: A Comparison of Moose Management between Alaska and Scandinavia. 2011. S. Brainerd and D. James. Sportsman’s Voice,

6: Status of the Moose Population and Challenges of Managing Moose in Fennoscandia. 2003. S. Lasvund, T. Nygren and E. J. Solberg.