25 Nov. 2013

Dear Colorado Parks and Wildlife Commissioners:

I am writing on behalf of Colorado Backcountry Hunters and Anglers (CO BHA) to offer general support for, and specific comments on, several Issue Submittals you will vote on in January.

W-004: As per comments previously submitted to CPW by BHA Southern Rockies Coordinator, Tim Brass, our nonprofit grassroots sportsmen’s group strongly encourages you to enact the Preferred Alternative, “Add new Section C to CPW #W-004,” outlawing the use of aerial drones in any aspect of hunting or scouting. Technology, industry, and human laziness will continue to attack the dignity of hunting and fishing, making more such restrictions necessary going forward.Sad but absolutely necessary.

007D.1 and 008B: Members and leadership of CO BHA, like the overwhelming majority of sportsmen and women we speak with nationwide, are embarrassed and outraged that elk and other big game animals are allowed to be privately owned and raised as if they were domestic livestock via the “game farm” industry in Colorado and elsewhere. The Agriculture Dept. concept and name “alternative livestock” both are biological charades, as elk et al. have not undergone thousands of years of selective breeding to engineer the wildness from them, and consequently suffer unduly in captivity. Moreover, private ownership of wildlife and pay-to-kill operations are a direct assault on the North American Model of Wildlife Conservation, without which both sportsmen and managers of free-ranging wildlife will gradually be replaced by the Texas model of private ownership of wildlife, high fences and canned executions for wealthy paying clients. And of course, we needn’t tell you about the dangers of diseased captive wildlife escaping (both from fenced enclosures and while being transported) or otherwise (such as nose-touching through fences) spreading potentially devastatingly contagious infections (and polluted genes) to Colorado’s elk and other big game. Colorado’s wildlife and sportsmen and women must be protected against these significant threats.

In sum, BHA, state and national, stand hard against the captive wildlife farming and shooting industries and support all thoughtful measures to control the growth of and potential damage caused by “elk farming” and canned executions. Thus do we urge you to pass the preferred alternatives for both Issues 007D.1 and 008B.

That said, we would like to register our concern with the final, weakening line in the preferred alternative for 007D, to wit: “unless CPW and the Department of Agriculture agree otherwise that the associated risk is negligible.” Our concern here springs from the obvious situation that having the Dept. of Ag oversee so-called “alternative livestock” operations is equivalent to putting the coyote in charge of the hen house. Is CPW of a sufficiently united and firm mind to withhold its agreement for, and to speak forcefully against, importation of captive wildlife that do not meet the standards of 007D.1, even when Ag disagrees? If not, the stated intent of the proposal and preferred alternative are seriously undermined from the outset. Consequently we would like to see this “escape clause” removed from the 007D.1’s Preferred Alternative language.

Similarly, the Preferred Alternative for Issue 008B also contains language that overtly weakens the implied intent of the new regulation, which is to protect big game species not already within the game farming and canned shooting industry (private ownership as “alternative livestock”) from becoming included in future. The worrisome wording is this: “Only Commercial parks licensed for species in the family Cervidae prior to 11/14/2013 and currently in possession of authorized species will be allowed to continue possession.” As we read this wording, it’s a clear endorsement for grandfathered operators to continue breeding and shooting the very species this Issue Proposal proposes to protect via banning their import into Colorado. CO BHA suggests that the wording be changed to outlaw continued breeding of the species of concern by operators who now possess them, so that when the current captive animals are shot or otherwise die, they will not be replaced by ongoing breeding in-state. With a concentrated herd-increase effort by grandfathered operators, there would be no need to import these species into the state in order to maintain and grow the now minimal portion of the canned shooting industry aimed at them.

021 and 004: CO BHA endorses and encourages the passage of both of these common-sense restrictions on the use of salt for baiting hunted species. Baiting is not hunting.

All comments above are based on our best reading and understanding of Issue Proposals from the wording provided. As always, if we have misinterpreted anything, we welcome clarifications from CPW.

We thank the CPW commissioners for your dedication and efforts to protect the welfare of our amazing state’s wildlife and sportsmen and women, and we thank you for your serious consideration of our positions and concerns.

Sincerely,

David Petersen

Vice Chair for Conservation

Colorado Backcountry Hunters and Anglers