CWF Opposes Expansion of Landowner Preference Beyond Pilot Projects

November 21, 2005

Colorado Wildlife Commission
6060 Broadway
Denver, CO. 80216

Re:  Colorado Statutes Title 33-4-103 -- 'Pilot' elk program

Dear Colorado Wildlife Commission Members:

The Colorado Wildlife Federation (CWF) supports the proposed pilot program to test new approaches to landowner preference in GMU 10 and on the eastern plains.  We support conceptually the third pilot that will be developed in southwestern Colorado.   Paired with the "above the quota" pilot already proposed for GMU 10, it might be best to try a "within the quota" option for the southwest pilot.  The Commission might even consider looking at the entire DAU E-20 (GMUs 61 and 62).   If a new idea could be developed successfully for those units, it likely would work elsewhere.   This process would provide this Commission with a substantial opportunity to explore the feasibility, costs and benefits of three unique options.   We ask that a substantial review and analysis of these pilots be completed and publicly reported prior to any further consideration of expanded landowner preference.

We also want to be perfectly clear that CWF strongly opposes, and will work to defeat, expansion of these pilots as discussed at the November Wildlife Commission meeting held in Greeley.  The new idea placed on the table during that meeting expands the original pilot concept dramatically.  It would result in something closely akin to a fully operational and completely new landowner preference system in those game management units for elk and, perhaps, deer that require five or more preference points to draw.  That is far too much too fast.  It also appears to disregard the strong sportsmen's opposition to any substantially expanded landowner preference programs. 

CWF already has major questions about how much the extra licenses currently under consideration will degrade the quality of the hunt in GMU 10 and whether the new access approach will provide meaningful benefits for sportsmen that are commensurate with the value of additional licenses provided to landowners.  We wonder whether the potential benefits of any of these changes will be sufficient to justify the substantial increase in administrative complexity that yet another preference program will generate.  In our opinion, the appropriate approach to address these questions would be to conduct a detailed assessment of a limited pilot program.

Furthermore, an analysis is unnecessary to establish that it would be inappropriate to increase the number of bull licenses in any game management units that are barely meeting or are already below their sex ratio objectives. Any new licensing package in these units should be generated from within the existing quota, rather than from the new licenses (that will exceed it).  We believe that the southwest pilot, yet to be determined, could explore this idea using a "within quota" model. Any new licensing strategy in this southwest region pilot should be produced from within the license allocations set by biological and community standards established by biologists based on existing DAU plans for the respective units.

Finally, we urge the Commission to maintain the integrity of this potential compromise throughout a three to five year test period.  Individuals from all sides will likely seek changes such as increasing the number of public licenses and making the private voucher licenses valid on public lands.   We encourage the Commission to seek greater understanding of this complex sportsman-landowner licensing and access issue before making substantive changes to the existing system.

We reiterate CWF's position that allowing current landowner licensees to hunt on public land is inappropriate unless the "reasonable public access" requirement can be enforced.   We also believe that any increase in landowner licenses that would be valid for hunting on public land is unacceptable.

We appreciate the opportunity to comment on this important issue.

Sincerely,

Wayne East, Executive Director
Colorado Wildlife Federation

Suzanne O'Neill, President
Colorado Wildlife Federation Board of Directors

Kent Ingram, Vice President
Colorado Wildlife Federation Board of Directors