10/23/13

RE: Path Forward Comments

Brian Kurzel & CPW Staff,

On behalf of Colorado Backcountry Hunters & Anglers, I want to thank you for providing the opportunity to comment on the Draft Path Forward document.

Colorado Backcountry Hunters & Anglers represents sportsmen and women who value the opportunity to experience the challenge, solitude and multifaceted reward that hunting and fishing our wild public lands and waters provides. We strongly believe that the management of our publicly owned wildlife be based on science and that this scientific information be publicly available. We also understand that scientific research overwhelming indicates the negative impacts of motorized recreation can have on wildlife habitat. It is from this understanding that we offer the following comments on the Draft Path Forward document:

Background Information:

Public Input (p 3) – As we explained through a letter submitted by BHA representatives on the Colorado Sportsmen Advisory Committee (CSAC) in September 2013, sportsmen have growing concerns with the lack of public input on the “Path Forward” plan. Despite what is stated in the draft plan (p 3), CSAC was never consulted on the plan’s development, nor was the Sportsmen Roundtable, to date. Either these groups need to be formally consulted and their input incorporated, or this language needs to be removed. Further, we understand that while sportsmen were not involved with the initial development of the plan, other interests, such as the State Trails Committee (STC) (see discussion from 9/20 State Trails Committee Meeting) provided extensive comments which have
since been integrated into the plan. The public input process, thus, has been flawed and unbalanced, resulting in the issues we’ve highlighted below.

Strategic Plan (p 5) – We have questions/concerns about Objective #6 – “Continue to direct leadership, support and resources to promote and establish a statewide interconnected trails network” (pg 6), which seems to have recently been added. This objective is overreach and indicative of the input by special interests as it relates to a specific type of recreational development. This would be akin to including an objective to “direct leadership, support and resources to develop a statewide network of shooting ranges.” We support promoting an interconnected trail network, just as we support providing a network of shooting ranges; however, we don’t believe either warrant a specific facility-based objective. Further, the trails mentioned are, for the most part, outside of CPW’s direct jurisdiction as most are on public lands that CPW does not manage, thus this. The objective should either be removed or significantly revised.

CPW User Trends (p 5) – It is generally noted that hunting participation is falling and fishing has increased slightly. While this may be true long-term, some reference should be made to the most recent upswing in hunting participation in the last 5 years (see USFWS 2011 report on participation and/or 2013 CO Limited License Statistics (despite boycott)). This should also be included in language on Participation in Outdoor Recreation (p 12).

Habitat Protection:

Objective #2 should be broadened to ensure that the natural resource information referenced is also shared within the agency and that it is clear that this science-based information also be shared with sportsmen publicly.

Mention of the need to balance the agency’s sometimes conflicting missions – expansion of recreational use & protection of habitat – must be clearly outlined in the Path Forward Document. As written, this is not clearly outlined in the draft document. This “need for balance” is a key component that was identified by stakeholders through the State Comprehensive Planning Process (SCORP) and it should also be included in the Path Forward document.

Independent wildlife review of trail developments needed - Managing two sometimes competing interests will be a challenge for the merged agency. While we understand that CPW must in some ways approach recreational development projects with one voice, we have major concerns with the approach that has been outlined in the draft plan, whereby “…former parks and wildlife have integrated the review process for trail grant applications. Previously wildlife staff reviewed and commented on trail applications by submitting comments to the State Trail Committee. Now wildlife managers assist with the preliminary review of applications so that CPW provides one recommendation to the State Trails Committee regarding each grant application (p. 12).”

This internal, politicized approach is problematic. While it may make sense for CPW to come at projects with one final recommendation, it is crucial that the impacts of motorized, mechanized or industrial development on wildlife habitat and hunting opportunity be reviewed by wildlife managers and that this independent analysis be made available for public review (i.e. the State Trails Committee & the general public). Without this critical input, committee members and the public will be unable to make an informed decision which ensures the habitat protection goal is met. The bedrock of the North American Model of Wildlife Management is that management decisions be based on science and that the public have this information available. It is inexcusable for CPW to abandon this principal in pursuit of “integration.”

Financial Sustainability:

Language should be included in the plan which specifically references the desire/input expressed by sportsmen to explore and discuss non-traditional funding sources for wildlife management.
Again, some mention of the need for balance between the aforementioned need for increased recreational use, and habitat protection, should be included in this section as well.

Recruitment & Retention:

The language which reads “CPW recognizes that more must be done to recruit and retain hunters and anglers, as well as attract additional park visitors and to provide better opportunities for trail users and water sports enthusiasts”, which seems to have been added to the plan, would broaden CPW’s mission beyond ‘parks and wildlife’ to include promotion of trails facilities on other public/private lands. Again, this biased facility-based language would be akin to CPW including a provision for say campgrounds, shooting ranges, wildlife viewing areas, etc. This language should be removed. Colorado Backcountry Hunters & Anglers thanks you for providing the opportunity to submit comments on the Path Forward. We fully anticipate the department will take our comments into serious consideration when developing the final plan.

Sincerely,
Tim Brass
Southern Rockies Coordinator