LAST EDITED ON May-11-12 AT 10:07AM (MST)[p]Greg-
After reviewing the proposed revisions, I see several potential problems. I have attached a link to a redlined version of the statute the shows the proposed language:
http://wildlife.utah.gov/public_meetings/info/2012-05_packet.pdf
My concerns are as follows:
1. The proposed language claims to cap the number of tags at 10% for sheep (or 8 permits, whichever is less) and 5% for other species (or 8 permits, whichever is less). However, if you look at the ratios used to determine the permit numbers, the percentages could actually end up being much higher. For instance, once you have 5 sheep tags on a unit, then the DWR allocates 1 conservation permit. That equates to 20% of the sheep tags being sold to the highest bidder. Same thing with other species, once you have 11 permits on a unit, the DWR allocates 1 conservation permit. That equates to 9% of the permits being sold to the highest bidder. Thus, the language of the statute is inconsistent and confusing. Given past experience, this inconsistency will be construed in a manner to allocate as many conservation permits as possible.
2. Why is the cap for sheep permits 10% and all other species 5%? Why should we agree to set aside one out of every ten tags for the rich? This ratio is simply too high.
3. The revised statute states that the number of conservation permits "MAY be reduced for once in a lifetime conservation permit species" if the number of public permits declines during the time period that multi-year permits are awarded. I am happy that they are attempting to address this glaring problem with the current version of the conservation permit rule. However, why is the language of the statute permissive rather than mandatory ("may")? Why doesn't it read "SHALL be reduced"? If the general public experiences a reduction in tags due to a decrease in herd numbers then the conservation organizations should experience a corresponding decrease. I have no faith that the DWR, the Wildlife Board or the conservation groups will voluntarily reduce the number of conservation permits unless they are required to do so.
4. Why is the language that provides for a potential reduction in conservation permits limited to once-in-a-lifetime species? If the general public experience a reduction in limited entry tags (deer, elk, pronghorn, etc.) due to decreased herd numbers then the conservation organizations should experience a corresponding decrease. There should not be preferential treatment for the conservation groups and the wealthy.
5. Has anyone (the DWR, the Wildlife Board or the conservation groups) done an analysis based upon last year's permit numbers to see what effect these proposed revisions would have on conservation permit numbers? Does the number of permits increase, decrease or stay the same?
6. Why not do away with multi-year permits and simply have the Wildlife Board allocate permits on a year-by-year basis? Let me guess--the conservation groups need to know years in advance how many tags they will have available to sell at their banquets. Come on! The headaches that these multi-year permits have created are not worth any alleged benefit resulting therefrom.
7. Greg argued in his post that if we substantially reduced or did away with the conservation permit program then the DWR would have to increase the number of nonresident permits to make up for the revenue decrease. There are a couple of problems with this argument. First, 90% of the revenue from these permits is used for conservation projects and the conservation organization is allowed to keep the remaining 10% for overhead, salaries, beer, peanuts, etc. Therefore, the money generated from these permits is not part of the DWR's general budget. Thus, a decrease in conservation permits may result in fewer conservation projects but it would not hamper the DWR unless the DWR attempted to fund the same number of projects out of their existing budget. Second, if had to make a choice, I would prefer see an increase in NR permits rather than having 350 tags being sold to the highest bidder. I would rather have some more of my NR friends who have been waiting patiently in line draw a tag then the same big wigs that jump to the front of the line year after year. After all, we are all NR's in every state except one. If we can generate the same revenue by modestly increasing the NR tag allocation and doing away with 300+ conservation permits, I say go for it!
8. Finally, Utah has set aside nearly 350 premium permits to auction to the highest bidder. There more conservation permits in Utah than all of the other western states combined. Is the hunting in Utah so much better than the surrounding states such as to justify this number of high dollar tags? I don't think so. The return on the investment for the average hunter does not justify setting aside 350+ tags a year. Why not cap the number of conservation permits at one tag per unit? I would like to see a drastic reduction in the number of conservation permits.
These are a few of the thoughts rattling around in my head after reading the revised statute. What am I missing? Perhaps Greg or someone else from these groups or the DWR can address some of these concerns.
Hawkeye
Browning A-Bolt 300 Win Mag
Winchester Apex .50 Cal
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