In the November Regional Advisory Council (RAC) meeting agenda, we saw various proposals from the Division of Wildlife Resources (DWR) emerge for public comment, some of which directly relate to BHA core issues, including hunter opportunity and access. The Utah Chapter of BHA provided written comment to the different RAC’s and the Wildlife Board which mainly focuses around two issues affecting Access and Opportunity: (1) the recommended changes to the Landowner Association program and (2) the hunt structure research proposal. The Utah Chapter generally spoke in opposition in its written comment and is actively commenting at the RAC and Wildlife Board meetings on these topics.
All members of the public can participate in the RAC meetings and we strongly encourage BHA members and supporters to engage. Visit the DWR website for more information on the proposals and the dates/times of the public meetings.
The DWR put forth various changes to the Landowner Association program including the ability for LOA’s to exercise an option that would allow them to still receive the landowner Limited Entry voucher allocation benefits of the program (which entitles the LOA to a specific number of Limited Entry vouchers based on the LOA’s total habitat acreage in comparison to the total habitat acreage the unit) but removes the requirement to allow public access on the private lands in the program, in exchange for the LOA tag holders only being able to hunt within the private land enrolled in the LOA. The chapter addressed the issue it its written commentary as part of the public input process:
“We have serious concerns regarding the proposals put forth for the Landowners Association program. As outlined in the administrative rule R657-43-1, the purpose of the program is for landowners to qualify for and obtain big game hunting opportunities in recognition of the benefits their private properties provide to wildlife resources in Utah. We do understand the importance of landowners maintaining their habitat for wildlife, and how it indirectly benefits the public land hunter, and are appreciative of their support. However, it is later stated in that same rule (R657-43-1-3e) that one of the intents of the program is to increase and secure public hunting access on participating Landowners' Private Lands. The first proposal put forth directly contradicts this, as it allows large landowners to remove public access, in return for the LOA participants only being able to hunt the private land enrolled in the program on the unit. This obviously decreases hunter opportunity and access, and we are concerned that this sets a dangerous precedent that could negatively impact hunting opportunities for the public. What’s to stop CWMU operators from attempting to get rid of their public participation requirement? If the rule change passes, large LOAs would essentially be mini CWMUs without a draw for public hunters. From an access standpoint, this change to the LOA program exclusively benefits the landowners in the program at the expense of the public, and defeats one of the key purposes of the program. For this reason, we oppose this proposal.”
This is a difficult topic because the North American Model of Wildlife Conservation holds that wildlife is a public resource held in trust by the state. Finding ways to incentivize landowners to manage their lands for quality habitat and tolerate wildlife on their property muddies the waters, as incentive programs in Utah cost the Public in forms of opportunity. This proposal gets to the heart of a difficult question: Where is line between concessions from the North American Model and keeping landowners incentivized to contribute to wildlife and habitat? Private lands are critical to our wildlife, but as we have seen the value of premium private land tags dramatically increase and private lands wildlife management shift to more of a business, our chapter draws the line at public access to the resource.
Another contentious proposal that emerged in this round of recommendations was the introduction of a hunt structure research proposal, which would implement tests of various techniques in the General Buck Deer Season in the Southern Region to see impacts including antler point restrictions, shortened seasons, and weapons restrictions. Utah BHA opposed the proposal in its written commentary stating:
“We appreciate that the DWR is attempting to proactively respond to hunter feedback and grow more mature bucks in our general season units but are concerned this study will have a negative impact on hunter opportunity.”
Our Chapter questioned the feasibility of the study’s claimed objective of trying to find ways of implementing solutions to increase quality while maintaining opportunity. Utah BHA Vice Chair, Caitlin Curry addressed the Chapter’s concerns on the study’s undertones of shifting the focus of general units more towards the quality end of the spectrum when commenting at the Central Region RAC meeting; “the Mule Deer Management Plan clearly specifies that the primary goal of the General Season Deer Hunt upon its creation was to provide hunting opportunity to the public, and we continue support this focus. Our State has made the decision to put an extremely strong emphasis on quality over opportunity in the Limited Entry season. If there are hunter frustrations with not being able to have a ‘quality-focused’ experience, those concerns should be addressed in the Limited Entry program, not the General Season where there is a completely different objective.”
The DWR Big Game Projects Coordinator, Kent Hersey mentioned in the Central RAC meeting that the feedback that the DWR was hearing most consistently came from the trophy end of the “quality vs. opportunity” spectrum. The public comment period at the Central RAC seemingly showed the exact opposite, yielding opposition to the proposal from almost the entirety of the public’s comments. Utah BHA also questioned this overall sentiment, which Curry addressed in her public comment: “Our organization highly contests the notion that a majority of hunters value quality over opportunity in the General Season. Until we see survey data that a majority of hunters in our state value quality over opportunity on these general units, this study jumps to resource-intensive testing solutions to accommodate a perceived, but unverified sentiment.”
Both of these recommendations have gone through the Northern and Central RAC’s at the time of this writing and have been rejected by both groups. Three more RAC’s and the Wildlife Board meeting remain. Utah BHA will continue to put pressure on these items until a final decision is made at the Wildlife Board level.