Big Game License Allocation, Pilot Programs

January 11, 2006

Colorado Wildlife Commission
6060 Broadway
Denver, CO. 80216

Re: Big Game License Allocation, Pilot Programs and Conflicts of Interest

Dear Colorado Wildlife Commission Members:

The Colorado Wildlife Federation, in our sixth decade of rational advocacy for wildlife in Colorado, provides these thoughts, appropriate to the January 2006 Colorado Wildlife Commission meeting.

Big Game License Allocation

The Colorado Wildlife Federation supports the "baseline" of 65/35 statewide and 80/20 license allocation between residents and non-residents hunters for units that require five or more preference points. This model of license allocation will decrease license fee revenue by 6,000.  Colorado Wildlife Federation estimates total license fee income will reflect an increase to the Division of Wildlife when one factors in million of new revenue that is projected for 2006 from resident license fee increases and from the Colorado Wildlife Habitat Stamp income.  Based upon the Division's projections that we have, the 80/20 structure would impact only 106 additional licenses for elk and 45 licenses for deer.  The 35 percent maximum allocation of limited licenses that would remain for non-resident hunters is exceedingly generous, and ensures continuation of economic support by out-of-state hunters to our Colorado rural communities.   In addition, Colorado would maintain its traditional profile as the friendliest state to non-resident hunters.  For the foreseeable future, every resident or non-resident who wants to hunt deer and elk in Colorado will still be able to do so.  

In support of higher allocations to residents, the Commission should consider that the population of Colorado has tripled from 1950-2000 (to 4.3 million residents), and new  projections are that Colorado's resident population will increase to approximately 5.3 million by 2020.  Correspondingly, 2000-2004 resident elk hunter numbers increased by 34 percent and resident deer hunter numbers by 29 percent.   We believe the new baseline of 65/35 and 80/20 for units that require five or more preference points will be fair to all stakeholder interests.  Colorado resident hunters deserve this higher allocation in limited big game licenses, and the Division will experience satisfactory revenue.            

 Pilots

Subject to satisfying all requirements of C.R.S. Title 33, the Colorado Wildlife Federation supports the pilot license programs stated below.   We must note that our support is conditioned upon our expectation of full compliance with the legal structure and intent of such pilots as provided in C.R.S 33-4-103 (Wildlife Conservation Landowner Pilot Program).   This statute states that pilots are allowable, (1) "if the game management objectives for the species for which additional licenses are requested are not being met" and (2) "if additional harvest of male or female animals on private lands will facilitate achievement of game management objectives."  Further, we ask that any approval of such pilots clearly states that these are temporary trials, and that the results will be measured with a full public review before any consideration is given to extending any aspects of these pilots into a permanent status.   The pilots also should include a "sunset clause" and a full review in subsequent years.

It should not be dismissed or ignored that from the inception of the discussion, these pilots have appeared to have this central purpose: improvement of landowner relations. While necessary for effective wildlife management, landowner relations do not meet the definition of any unmet game management objective, nor do Colorado hunters have an appetite for higher landowner preferences, even if within the effort to meet game management objectives.  (See 2005 Public Survey on Big Game License Allocation).   Aside from allocation of a total of 10 public bull elk tags in excellent elk units, the balance of gains in the pilots appears weighted more to private landowner than to average hunter interests.  The recipient landowners would enjoy a substantial financial benefit by selling their elk vouchers on the open market for ,000-,000.  Although public hunter access is provided in the pilots, we remind the Commission that the history of landowner preference in Colorado has yielded numerous examples where required public hunter access has been circumvented.  Therefore, the burden of proof lies with landowners to ensure public hunter access in pilots actually occurs, is measurable, and is strictly enforced. 

Make no mistake about it, Colorado wildlife management policy already is exceedingly generous to landowners.  Benefits include the highest payments in the nation to landowners for reimbursement of game damage, estimated at million a year, equating to approximately per big game license issued.  In addition, vouchers sold now command hundreds of thousands, if not millions, of dollars to the landowners who are selling these tags.   Colorado landowner vouchers sell for as much as ,000 for quality unit deer tags and ,000 for quality unit bull elk tags.  This income from Colorado's wildlife is in addition to normal private property access charges hunters pay to hunt private lands or simply to gain access to public lands otherwise landlocked by private lands.            

Is it not ironic how landowner preference, as implemented in the 1980's, was developed to enable a rancher and his designated friends to hunt that rancher's private lands?   Since 2000, landowner preference has become more and more about landowners making large sums of money from Colorado's wildlife.  

We reiterate our conditional support for the 'limited' experimental pilots, presuming they meet the legal, structural, and intent of pilots, as required in C.R.S. 33-4-103. Our support is subject to the following:

A.     With regard to Pronghorn only, there will be a 10 percent increase in landowner preference for eastern plains units.   We support this proposal because these tags are eligible for the ranch's "immediate family only."  The tags are non-transferable and may be used only as private lands tags.  If undersubscribed, none of these tags will revert into the landowner leftover draw.    We expect that the term "non-transferable" will be interpreted literally and without exception, and will not become transformed into a transferable voucher.

B.     As to elk management in the Northwest Region, and the pilot program for Unit 10, we agree to support the addition of Unit 1.  We cannot support the addition of other units for what is intended to be a limited elk pilot.   The reason for our support is that both Units 10 and 1 have high male to female sex ratios in the elk populations, which allows the tags to be issued "above the quota."  Further, both units contain a high percentage of private lands which normally are not easily accessed by average hunters.   It is our understanding that these two elk pilots will have a total of 10 tags issued per unit (total of 20 elk tags combined over both units), and that the tags will be split evenly between public sportsmen and landowners.   The tags issued landowners will be transferable as vouchers, but will be restricted to private lands only.   Moreover, recipient landowners would need to provide public hunting access for the five additional public hunter bull tags in each unit.  Finally, the landowners who receive vouchers must allow a minimum of 10 public cow hunters per voucher received, and the vouchers would be limited to private lands hunting only. 

In summary, we respectfully request that the Colorado Wildlife Commission give continued careful and full consideration to the 2005 Public Survey on Big Game License Allocation which noted that 86 percent of resident hunters and 57 percent of non-resident hunter respondents were opposed to any higher landowner preference than the present 15 percent level, even though its purpose was to support the effort to achieve game management objectives.    Public hunters are finding themselves forced to draw a line in the sand over expansion of landowner preference that, in turn, is driving hunting opportunities to become conditioned upon large amounts of money.  We are confident that for some landowners, the proposed landowner preference will not suffice.  Colorado can ill afford to increasingly subsidize what can aptly be described as an addiction to money sold as hunting opportunity.      

The Colorado Wildlife Federation continues to express major concerns about an increasing privatization and commercialization of big game hunting opportunity in Colorado.  We urge the members of the Colorado Wildlife Commission to adopt a  visionary approach and represent the entirety of Colorado interests, and especially that of

the average hunter.  If any special emphasis is conferred upon interests through allocation of limited licenses for Colorado big game, that emphasis should be given to the average hunter.  Collectively, the average hunters account for the purchase of 300,000 deer and elk licenses in Colorado, hunt on their own, and do not buy landowner vouchers to do so.   Average hunters are the anchor of wildlife management, and Colorado should not ever take them for granted.  In big game limited license allocation, average hunter interests should be championed every time over money interests.   Then, let it be carved in stone that "Colorado wildlife resources owe no one a living."  

Conflicts of Interest

As we begin this new year, the Colorado Wildlife Federation is acutely aware of the increasing complexity of wildlife management and policy challenges that confront the Wildlife Commission.   As wildlife commissioners are expected to and do possess  familiarity with wildlife management issues and the judgment necessary to reach policy determinations, it is inevitable that from time to time individual commissioners may experience apparent or actual conflicts of interest.  The mere appearance of a conflict of interest can be as damaging as an actual one.   When a Commissioner has a personal interest in a particular matter that is before the Commission, whether financial or otherwise, the Colorado Wildlife Federation strongly believes that the affected Commissioner(s) should abstain from voting on such matter.      

Thank you for the opportunity to comment on these matters.

Sincerely,

Kent Ingram, Chair-Elect
Colorado Wildlife Federation

Suzanne O'Neill, Outgoing Chair
Colorado Wildlife Federation