How to Provide Comments on Public Wildlife Management Plans

by Jan 10, 2021Conservation

Winter is the season when hunting and angling conservation-based organizations may be asked by a fish and wildlife agency to review and provide comments on a draft management plan the agency is working on. In some cases, this kind of public referral / opportunity for public comment may be mandated by provincial or territorial legislation. So, how should you review and comment on a public fish, wildlife, or habitat management plan? Where do you even start?

For starters, a fish, wildlife, or habitat management plan is a document that must spell out the objectives for the management of a species or its habitat. So, management plans must have objectives. But what is an objective? The Merriam-Webster Dictionary defines an objective as, something toward which effort is directed: an aim, goal, or end of action.

To be useful in the context of setting objectives for fish and wildlife management, the objectives must be S.M.A.R.T objectives. S.M.A.R.T is an acronym that defines the elements of a measurable objective. In fish and wildlife management, if the objective for a species is not something that can be measured then the species cannot be managed properly.

S.M.A.R.T Objectives Defined

S – Specific

An objective must be specific. The objective needs to explicitly state what is going to be done and how. In other words, it must describe an outcome and the action designed to achieve the outcome. There should be no room for different interpretations if the objective is specific.

M – Measurable

The objective must be measurable. Everyone needs to be able to know when the outcome is realized so there must be some way to measure, quantify or evaluate the outcome.

A – Achievable

The outcome must be achievable. The outcome must be something that can be done within the target time frame. Sometimes “A” can stand for “Agreed” meaning the objective has an outcome that stakeholders have agreed to, but the outcome must still be achievable even when a group agrees to it.

R – Relevant

The outcome that is being sought must be something that should be done. The outcome must be something important enough to invest resources in and if applicable, should be an outcome mandated in legislation or by an approved higher-level strategic plan.  It must be obvious to the stakeholders / public “why” this objective is being put forward at this time.

T – Time Bound

The outcome must be time bound meaning the objective must specify when the outcome will be achieved by. You can think of “T” as the endpoint or due date for the outcome.

S.M.A.R.T objectives in fish and wildlife management should be structured around a formula that looks like this:

X goes to Y by time Z by <employing ___ action>

For example,

Objective A: Increase the bighorn sheep population in zone 12 from 50 to 100 animals by the year 2030 by removing 50% of the female cougars in zone 12 each year.

Let us assess Objective A against the facets of a S.M.A.R.T objective.

Is Objective A:

Specific? The objective is specific to bighorn sheep in zone 12, the outcome is specific (i.e., 100 sheep) and the action to be implemented is specific. There should be no uncertainty what this objective is about.

Measurable? The outcome is quantifiable because the number of sheep in the population can measured with a wildlife inventory count.

Achievable? One would have to ask if this sheep herd could increase by 50 sheep by year 2030. Is that doable? Does this sheep herd have the capability to increase this much over the time period.  One must also ask if cougar predation is the cause of the low numbers in this sheep herd.

Relevant? Next, one must ask if this objective is relevant? Why is this objective being proposed right now? Is the current size of the herd in zone 12 a conservation concern? Does the zone 12 sheep herd warrant the resources needed to increase the population at this point in time relative to other sheep herds in need? Is the current herd size of the zone 12 sheep herd in contradiction with a legislated mandate or higher-level strategy that the sheep herd warrants this specific management objective? Should this sheep herd be increased from 50 to 100 animals? What other factors must be considered to assess the relevance of this outcome? Can the sheep habitat feed 50 more sheep?

Time Bound? The objective provides a specific due date for the outcome – the year 2030.

Using the S.M.A.R.T objective approach, members of the public can effectively review and comment on a fish, wildlife, or habitat management plan or at least ask specific rational questions about the adequacy of the plan.

To have the best chance of achieving the outcome, a fish, wildlife, or habitat objective must satisfy all the elements of a S.M.A.R.T objective. Uncertainty in any one element of a S.M.A.R.T objective increases risk of failure in achieving the outcome.

Management plans that lack S.M.A.R.T objectives all together will have a very high likelihood of failing to conserve or responsibly manage public fish and wildlife. So, it is incumbent on the public to be savvy detectives and gritty watchdogs when reviewing fish and wildlife management plans.

The other key factors to consider when reviewing a draft version of a public fish or wildlife management plan include:

  • Finding out if the management plan is being prepared under a specific section of a statute, regulation, policy or approved strategic-level plan. Fish and wildlife management plans that are not being prepared under some legal mechanism that has teeth are more likely to be under funded, not adequately resourced or not given a sufficient level of priority. If the management plan is not being approved for implementation by someone with authority to allocate resources and have accountability under a legal mandate, the objectives may not be actioned at all because no one can be held accountable for the plan’s implementation.
  • Being wary of draft management plans that are prepared by consultants. Public agencies have a duty to prepare management plans for fish and wildlife and they are the only ones accountable to the public for the outcomes. A document prepared by a consultant is often only a recommendations report which the public agency can later decide not to act on. Consulting reports can be important pieces of a management plan if they contain analyses, data, or other vital information that a decision maker needs when preparing the management plan. Consulting reports might be in the appendices of a public management plan, but a consultant’s report should not be the actual management plan. So, when it comes to the official fish, wildlife, or habitat plan, ask for the real deal – a public fish or wildlife management plan prepared by and approved for implementation by the public agency in charge.
  • Being wary of fish and wildlife objectives in sheep’s clothing. Wildlife management can get tangled up in political games especially when the conservation of public fish, wildlife or habitat will affect a natural resource industry. Objectives can be written so that they are vague, non-committal, un-measurable, and without specific due dates to avoid political backlash. This nebulous style of writing objectives can also be done so that there is the appearance that a particular fish and wildlife population is being managed without having to allocate additional funds or resources to their management. The reality of a vaguely written objective is that no one in charge can be held to accountable for a specific outcome. Objectives written in this vague non-committal way often look like motherhood statements, visions statements or something a committee or your dog wrote.

For example,

Objective B: To maintain moose populations consistent with ecological conditions, local and regional biodiversity principles as well as other relevant factors that may change from time to time due to the social, economic, or environmental needs of commercial and non-commercial interests.  

Huh? WTF does that even mean? Whoda gonna duda whata? There is a reason why public fish, wildlife and habitat objectives get written like this.

Fish, wildlife, and habitat on crown land in Canada are managed under the public trust doctrine. The public has a right to ensure objectives proposed by public agencies in fish, wildlife and habitat management plans are S.M.A.R.T.


Cover Image: © Cats / Adobe Stock



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