Colorado BHA Tag Allocation Observations & Information

Colorado BHA Tag Allocation Observations & Information

This issue of resident vs. nonresident (and landowner) elk (and other) tag allocations has been a controversial issue in multiple Western states over the years, including Colorado. As a result, during May 2022 the Backcountry Hunters & Anglers (BHA) North American Board adopted a policy statement on hunting license allocation.

In addition, during 2017 the Colorado BHA Executive Leadership Team/Board adopted a position statement on Big Game License Resident/Non-Resident Allocations. Since then, there has been much additional discussion and information made available related to tag allocations. Hence, the information below may be of interest/use currently and/or going forward:

1. 2022 North American (BHA) Policy Statement: Hunting License Allocation.
2. 2017 Position Statement (Colorado BHA): Big Game License Resident/Non-Resident Allocations (It’s acknowledged that some of the information in this Statement may now be dated).
3. “The Secret to the Elk and Deer Tags in Colorado.” Public Land Jurisdiction: 3/24/22.

2022 North American (BHA) Policy Statement: Hunting License Allocation

Purpose: The intent of policy statements are to provide a formal mechanism for Backcountry Hunters & Anglers to engage in specific conservation issues while establishing clear policy direction that not only defines the parameters of our position statements but the relevance to our mission. As declarations of policy, statements do not direct specific actions, establish policy priorities or allocate BHA resources.

Sponsored by: Originally proposed by the Kansas, Montana, and New Mexico Chapters of BHA, this statement reflects revisions made by the North American Board of Directors.

North American Board Action: Adopted on May 13, 2022.

North American Policy Statement: Backcountry Hunters & Anglers upholds the North American Model of Wildlife Conservation which states that “government allocates access to wildlife without regard for wealth, prestige, or land ownership,” and that wild game hunting opportunity must be allocated in a fair and equitable manner.

BHA does not support the allocation of state, provincial, or territorial issued transferable and/or saleable hunting licenses or authorizations for any wild game species as compensation. Entitlement to wild game hunting licenses, tags or other authorizations that monetize opportunities on public trust resources for private gain should be disallowed.

We urge wildlife management agencies to avoid policies and regulations that establish transactional circumstances that monetize wild game hunting opportunity and compromise equity in access to public trust resources.

2017 Position Statement (Colorado BHA): Big Game License Resident/Non-Resident Allocations

During May 2017, the Colorado Backcountry Hunters & Anglers (BHA) Executive Leadership Team/Board adopted the Position Statement below regarding big game license resident/non-resident allocations.

The points made are generally still relevant today, especially considering that many Colorado resident hunters are increasingly concerned about the impacts of unlimited non-resident over-the-counter (OTC) tags (in particular) in units where they’re available.

This combined with multiple elk herds and habitat across the state experiencing increasing pressure from year-round outdoor recreation makes tag allocation decisions all the more important. For additional information also see: “Trails vs. Elk: ‘They’re Just Dying Off.’” Backcountry Hunters & Anglers: 12/3/21.

May 2017 Position Statement (It’s acknowledged that some of the information in this Statement may now be dated).

Recent discussions during Colorado Parks & Wildlife Commission meetings on changing allocation methods for resident and non-resident (NR) big game license allocations—which have the potential to increase license allocations to non-resident hunters from the general pool—has alarmed resident/public land hunters along with sportsmen conservation groups in Colorado. The Colorado Chapter of the Backcountry Hunters & Anglers (BHA) opposes any efforts to increase non-resident license allocations, and (hence) decreases resident allocations, for the reasons below:

All decisions on license allocations should, first and foremost, be premised on scientific wildlife management data and principles, with conservation of the resource given the highest priority. The recent license allocation discussion(s) occurred after the failure of a funding bill for Colorado Parks and Wildlife (CPW) in the state legislature, with (apparently) some outfitters and agricultural interests offering/proposing that more non-resident licenses equates to more income for the CPW. The discussion appears to be driven solely by the potential financial benefits of the more lucrative non-resident licenses, while science-based wildlife management does not seem to be a consideration.

Colorado currently allocates more licenses to non-resident hunters than any other western state. In the western part of the state, the current draw format stipulates that 20% of the licenses in limited units be allocated to landowners as landowner vouchers. Many of these vouchers are sold with hunting packages to non-resident hunters for significant profits, of which none goes to funding our state’s wildlife department. In addition, with the remaining 80% of available licenses, the allocations are generally 65%/35%, or in a very few game management units 80%/20%, resident/non-resident ratios.

Consequently, 55% of the licenses have the potential to be allocated to non-resident hunters in certain units (20% landowner preference plus 35% non-resident allocation). An increase to the non-resident allocation has the potential for non-residents to receive upwards of 60% (or more) of the allotted licenses. This is an egregious and unacceptable scenario. Given the already overly generous non-resident license allocations, we don’t consider an increase beyond the current license split to be a preferential outcome. Other western state license splits are detailed below.

Arizona - 10% maximum NR licenses &10% maximum for total sheep licenses; Idaho - 10% maximum NR licenses; New Mexico - 10% maximum NR licenses with an outfitter, 6% without an outfitter; Montana - 10% maximum NR licenses for draw licenses; Wyoming - 15% maximum NR elk licenses, 20% maximum NR deer, antelope, sheep, moose and goat licenses; California - 1 NR elk license, 1 NR Antelope license, 10% maximum NR sheep licenses; Oregon - 5% maximum NR deer and elk licenses, 3% NR antelope licenses, 10% NR sheep and goat licenses; Utah - 10% maximum NR licenses; Nevada - 10% maximum NR licenses.

Additional non-resident license allocation would further upend the North American Model of Wildlife Management in Colorado. America’s greatest hunters-conservationist, Teddy Roosevelt, was the forefather of the North American Model of Wildlife Management (NAM). The North American Model, in turn, updates and expands Aldo Leopold’s foundational Land Ethic as laid out in his 1949 classic, A Sand County Almanac. In a nutshell, this concept guarantees that wild game belongs to the people, held in trust by the states. Wildlife in the United States is considered a public good to be conserved for everyone and accessible to everyone, not a commodity that can be bought and owned by the highest bidder.

However, these discussions seem to indicate that some outfitters and agricultural interests are influencing the wildlife commission to move even further away from NAM, toward maximizing profits for these two groups/entities without concern for science-based wildlife management. This agenda has no place within the tenants of the North American Model of Wildlife Conservation. In fact, profiteering from wildlife is in direct conflict with NAM. It represents a throw-back of hunting toward a “pay to play” activity and is a characteristic of the aristocratic society where the nobles and “well to do” are the only ones who have access to hunting-angling and other outdoor recreation opportunities.

Our American heritage is rooted in the tradition that all Americans have the opportunity to hunt and fish for food and recreation. However, these discussions geared toward increasing non-resident license allocations are, in a nutshell, moving Colorado toward ever more layers of privatization of big game hunting opportunity. While we generally support the mission of outfitters and agriculture, setting up a system with a “grab all you can get” agenda is a characteristic rooted in myopic greed, with little or no concern for the resource.

Based on the reasons above, the Colorado Chapter of the Backcountry Hunters & Anglers opposes any changes to big game license allocations that would result in lower resident hunter license allocations. We also request that the Commission conduct a formal survey of other western state license allocations and consider bringing Colorado’s license allocation into line with the averages for these states. Methods should also continue to be developed/emphasized that increase and promote Colorado residents’ participation in hunting, angling and other outdoor recreation.

“The Secret to the Elk and Deer Tags in Colorado.” Public Land Jurisdiction: 3/24/22

Some Colorado BHA members have requested that we consider the issues/concerns raised in the following post and possibly adopt a related/updated policy/position statement: “No State Treats Resident Big Game Hunters Worse than Colorado-Tag Allocation-Hiding in Plain Sight. The Secret to the Elk and Deer Tags in Colorado.” Public Land Jurisdiction: 3/24/22. https://publiclandjurisdiction.com/no-state-treats-resident-hunters-worse-than-colorado/

This information herein is, in general, likely not new to most Colorado big game hunters, but some of the specifics/details may be (assuming the data is accurate, which we ask you to determine for yourself if you have questions/concerns). We’ve also included some of the key points/data in the bullets below.

The post also notes/states (in part): “In March 2021, Colorado finally proposed a Senate Bill, SB 21-150 (Reserve Big Game Hunting Licenses for Residents), to ease resident hunter frustration as a result of a tag allocation bias inflicted on resident hunters for decades—when compared to other western states.”

Key Points (please do your own research regarding the data/observations below if you have questions/concerns)

• “… Colorado gives 200% to 350% more limited deer and elk tags to nonresident hunters than the average western state … On average all other western states give just 10% of big game tags to nonresidents.”
• “Currently, Colorado has nonresident big game tag allocation caps of 20% and 35% for limited mule deer and elk tags. 20% of the elk and deer tags are given to nonresidents in the limited units that take 6 or more preference points to draw, all other limited units give ‘up to’ 35% of tags to nonresidents.”
• “The limited big game tags requiring less than 6 preference points need a hard cap 10% with no loopholes. SB 21-150 proposes 33.3% (1/3), this is not much better than the current 35% cap for non-residents.”
• “CPW is still using the tag draw data from the 2007 – 2009 draw results (15-year-old data) to determine which units give 20% or 35% of the tags to nonresident deer/elk hunters. The amount of limited deer/elk units that now require 6 or more preference points has surely doubled since 2007 … Today, many more limited units should be at 20% vs 35% for nonresident hunters.”
• “Example: Unit 40 archery elk in Colorado has gone from 3 preference points to draw in 2009 to 8-9 preference points since 2017. But since the CPW does not update the system, 35% of tags in unit 40 (Glade Park) are still going to nonresidents, when the legal amount should be 20% … Thousands of trophy (6+ points) tags are filtered to nonresident hunters using this ancient data in our modern world.”
• “This November 2020 Colorado Parks and Wildlife Report shows … [the impact on] resident hunters each year because of the CPW using the 2007-2009 data.”
• “These are not hard caps in place for the limited deer and limited elk hunts, the current caps only apply to the 1st choice draw. There are 4 draw choices in the CO big game tag draw system. If all the tags are not drawn in Choice 1 they roll over to choice 2, 3, etc.”
• As a result/for example, “nearly 50% of limited elk tags went to nonresident hunters last year in unit 41–Grand Mesa.”
• “Here is a link to thirty-four (34) limited deer unit hunts that gave 41% to 71% of deer tags to nonresidents … Here is a link to fifty (50) limited elk unit hunts that gave up to 83% of the tags to nonresidents.”
• “There is no nonresident tag allocation cap for limited pronghorn, bear, and turkey licenses. The nonresident license allocation is specific to elk and deer. Therefore, nonresident hunters could draw all the license quota available, if they have enough preference points.”
• “New deer and elk tags offered after 2007 that take more than 6 points to draw have the 65/35 split … The legal resident/nonresident allocation split should be 80/20 in this trophy elk unit which far exceeds 6 points … CPW policy is to give a 65/35 split for all new hunts since 2007 regardless of the points necessary to draw the tag.”
• “Nearly all other western states only allocate 10% of big game tags to nonresidents (this is for all tags regardless of how long it takes to draw).”
• “In 2021 Colorado sold about 94,000 Over-The-Counter elk tags. Archery OTC elk hunters have doubled between 2002 and 2021, with more nonresident archery hunters than resident hunters.”
• “With over 94,000 OTC elk hunters in 2019, of which about 42,000 are nonresidents, the state is over hunted. You can pack in 6-10 miles and it’s still over hunted.”
• “Wyoming and Montana have transitioned non-residents to a draw system for the ‘general’ tag rather than an over-the-counter tag. This would be a good option to help balance the number of non-residents in the field, but ultimately there needs to be a cap on all non-resident tags issued, and this number should be based on herd management and safety goals rather than financial goals …”