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Thread: APHAs DRAFT DNR GUIDE CONCESSION COMMENTS Part I

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    Default APHAs DRAFT DNR GUIDE CONCESSION COMMENTS Part I

    The following document is the 19 pages of DRAFT suggestions that APHA intends to submit to DNR concerning the DNR Guide Concession Plan/Project. Due to the length of the document I had to break this up into three separate parts.

    To their credit, they sent it to their professional members for review.

    They also sent it to at least one former member, myself.

    Dennis
    ************************************************** **********

    APHA Draft Program Comments:
    APHA Draft Comments in Blue and Red, DNR Proposed Criteria in Black.

    Regarding Continued Program Development:
    As industry service providers, we request that DNR continue to provide opportunity for us to review and comment on future changes to the proposed program. This is a very important aspect as we have serious concerns with the program as proposed and feel strongly that we be allowed to review and comment on changes that are made in an effort to help continuing development produce the best results for DNR and the industry.

    Regarding Makeup of the Selection Panel:
    We strongly encourage DNR to have two industry representatives as well as a member of the Big Game Commercial Services Board within the makeup of the selection panel. Through the course of dealing with appeals related to USF&W guide use permits, the appeals regarding selection most commonly brought forward directly relate to the panels inability to define field craft, ethics, guide regulations and hunting regulation within the scope of the proposed plans of operations. If the selection panel has two industry representatives, and a member of the BGCSB it provides better integrity for the program and will diminish the potential for appeals. The industry representation should be made up of industry service providers of historic integrity who are either retired or do not operate on State or BLM lands. They may or may not have a vote related to scoring but their ability to point out important industry operation aspects is vital to providing a fair process.

    Additionally, industry representation on the selection panel will reduce the effectiveness of professional prospectus writers or attorneys hired by service providers to write their prospectuses. There are certain aspects of the plans of operation which a industry representative can recognize that a agency person would not, such as: actual versus proposed amount of airplane, boat, horse, staff, effort to facilitate proposed services, actual versus proposed amount of fuel storage required, actual ability to facilitate a economically viable operation, actual ability to conduct the proposed time spent with clients, actual ability to conduct proposed scope of operation related to logistics, weather and terrain etc. etc, the list goes on and on.

    Regarding Appeals and the Appeals Process:
    We have enough concern about the proposed criteria to know that there will be appeals. As the existing DNR appeals process has a substantial backlog of cases and limited staff we recommend the following:

    Use the scope of the above proposed selection panel as the appeals panel. If an applicant appeals a decision, they can come before the panel and argue their case once, as well as the selected winner. Decision by the panel after hearings are held for both sides would be final.

    Regarding Scoring of Criteria:
    With the makeup of the proposed scoring factors and low scoring ability within the plan of operations, and the high scoring for financial remuneration, the resulting applicant scores regarding stewardship, knowledge and experience are going to be very close regardless of the attempt of the criteria to discern the best operators.

    We suggest that the financial remuneration points be significantly reduced or completely deleted as suggested within our specific comments related to Scoring Criteria Number 4. Additionally, we have made several other suggested proposed criteria changes that would result in reducing the number of points awarded for certain criteria factors. We have also suggested within the criteria a number of proposed new criterions for your consideration

    Our recommendation regarding scoring has two options:
    a. Reduce the proposed scoring as suggested for certain criteria and redistribute the points in the stewardship factors to allow a broader range of scoring opportunity which will help discern the best operators on the ground.

    b. Reduce the proposed scoring as suggested for certain criteria and redistribute the points in the important stewardship factors. Then, convert the point system with a percentage system and combine aspects of each of the main scoring criteria with sub-factors as possible to allow a broader spectrum of grading ability. This will help determine the best applicants by broadening the scoring ability and well reduce the high potential for ties.

    Regarding proposed number of concessions to be awarded and applied for:
    We support the applying for maximum of four concessions.
    We have strong objection to being allowed to be selected for only two based on the following:
    For many years, Alaska’s guide industry service providers have been limited to three Guide Use Areas in an effort to restrain commercial impact. This concept has to a significant degree worked and has long been the established norm of the industry. No matter how many State, Federal or private land use authorizations held, a service provider can only operate within three GMU’s.
    This model should stay the same for a number of important reasons.

    Many existing service providers have been conducting hunts on State lands within three GUA’s for many years and have substantial investments in them. To suddenly disallow the three GUA concept to be used within State and BLM lands lends confusion to existing law and lends considerable potential challenge to maintaining the three GUA concept on Federal lands.

    We strongly recommend that DNR take into consideration the historical intent of existing law and allow for award of three concessions per applicant.

    Regarding proposed Full Rights and Limited Rights Concessions:
    The main reason we all are involved in this process is to relieve commercial impact and its potential on important wildlife populations. The past several years of development has brought us a long ways in regards to defining the problem and seeking solutions.

    As the program has been developed to reduce impact, naturally, service providers are worried that they may not prevail. When this comes to the surface, options that will allow the best opportunity to prevail, come to the surface. These options do not always provide for the conservation aspects that are important for the program to be a success but rather a manner to keep a larger number of service providers in the field. This being stated, the Full Rights Concession by itself, makes the most viable manner of effectively maintaining a good conservation basis to the program, as well as providing for less administrative oversight and long term sustainability of the program and the industry.

    Many of the proposed concessions have one to three proposed opportunities within them currently. These proposed numbers were discussed and agreed upon as viable long-term sustainable opportunities. With the new proposed “Limited Concessions”, many of the negotiated proposed concessions will no longer meet the original goals of viable and long-term sustainability. This directs us back to another mapping process and numbers of what kind of concession opportunities are to be developed that can still maintain a conservation basis. In short, goes against the grain of the overall intent of the program.

    It is also our understanding that once the proposed Concession Areas and the number of operators were defined, this information was given to ADF&G for conservation review, and with some changes was granted. With this new Limited Right’s Concession coming to the surface at this point in the process, it questions and jeopardizes all of the previous work.

    Much of the user group conflict that has come before the Board of Game has come from towns and villages that are dependent upon the river systems for important food harvest. Central Kuskokwim, Nushagak, Mulchatna, Noatak, Squirrel are all river systems that have experienced this conflict and resulting in very expensive management/conflict working groups and subsequent conservation measures that reduced or eliminated other (nonresident) opportunity. We need to keep this in mind in relation to the concession program. We do not want to have conservation concerns coming before the BOG related to the concession program or operators. This will undermine the integrity we are trying to develop.

    Much of the service provider conflict recognized through development of the Concessions program has come from highland region operators versus river operators. Please also understand that when the proposed concessions were developed, the upland seeking service providers had a certain sense of conservation and resource availability related to the river systems in the region and the migratory nature of the wildlife. Developing new river based concessions puts the original upland sought conservation basis in question.

    We recommend that the program be implemented only with the full rights concession model and that the few areas of concern within GMUs 16 and 17 be divided into upland and river concessions. Existing number of proposed upland concessions should stay the same and the number of river system concessions should be minimal. Additionally, sideboards need to be developed for defining river operators from upland operators. It is important to try to keep from distinguishing the river habitats by corridor width. This leads us down the path of Corridor Closures, which work against the best interest of the whole for everyone.

    Regarding Post Season Report and Ten-Year Terms:
    Integral to making the proposed program work is the necessity of utilizing a graded post-season report. This report should provide the conservation, hunter effort, illegal activity and accident and fee oversight information for each year. Additionally and as a new and very significant conservation aspect for ADF&G, the report should contain anecdotal information questions about predator and prey wildlife populations, recruitment numbers as well as any range and nutritional concerns etc. This would be a very beneficial history and new tool for ADF&G.

    Vitally important to the integrity of the program is for the service providers who are selected for the concessions to know that their work as good stewards results in the long-term viability of their businesses. This is very important to make this program work for the best interest of Alaska and the industry. Also important to understand is that service provider who starts into a new area has approximately a five-year learning curve regarding how to best operate in the area. This leaves five years left in the concession period before the existing operator under the program as proposed is thrown back into a pool of new applicants to compete for the area again. This is not in keeping with any good level of prudent business management or industry support. To help provide for this concern we recommend the following:

    Annual scoring for the Concessionaires Post Season report should be the same as what the NPS Concessions program uses: Satisfactory, Unsatisfactory and Marginal. We also recommend that the same guidelines used by NPS for earned renewal be provided in the next ten-year cycle of the concession. This allows for an operator who has consistently been a good steward of the wildlife, land, and industry and earned a satisfactory report to have a sustainable business.

    Ten-Year Terms Only. The five-year plus five year concept is an administrative burden and unneeded. Incorporate a method to take a concession back for unsatisfactory Post Season Report ratings and re-offer the concession with the next offering.

    Regarding Tie Breaker Concepts:
    The following recommendations were developed by the BGCSB DNR Subcommittee for consideration:
    1. Allow communication between tied parties for potential agreeable solution opportunity.
    2. Highest score of highest graded criteria.
    3. Number of concessions – tie would go to the applicant who has the least number of state concessions.
    4. Seniority factor.

    Regarding Transferability:
    We recognize that DNR has recommended not allowing any transferability of the proposed concessions. Please understand the following:
    a. We encourage DNR to understand that operating a business as a professional guide represents in most cases as good stewards of the available resources, a way of life and not necessarily an economic boon. In most proposed concession opportunities, even the most prudent of service providers will have little opportunity to generate annual revenues for personal future health or retirement needs. The transferability aspects built into the existing USF&W and NPS programs are working within the concerns brought forward by the Owsichek decision. Permits and Concessions transfers are being allowed and the process in which they are overseen provides the agencies with opportunity to participate in important aspects of the new entry. At the same time, new entry is happening through their regular offering process and young, comparatively new service providers are being awarded great opportunities. In short, these systems which include some transferability aspects are working for the best interest of the whole.

    b. Another important aspect of transferability revolves around a family oriented business. As a State, or as an agency, we should recognize the important aspects of providing good integrity to Alaska’s family run businesses. The professional guide industry operates in nearly a complete high-risk arena. Hunts are often booked several years ahead of time. If a concession operator has the misfortune to die while operating his or her business and has licensed and qualified spouse, sons or daughters that can help facilitate the existing plan of operations through the term of the concession, this should be taken into consideration.

    As proposed, a service provide, no matter how good of a steward he or she is, may or may not win the concession at the end of a ten year term and has no transferability. Once again, this situation discourages prudent business administration, challenges good stewardship and conservation and discourages family sustainability within the industry.

    We encourage DNR to look at the transferability provisions granted within the existing USF&W and NPS programs, review your existing authority in this regard and help make this program work for the best interest of the whole by providing some level of transferability opportunity within the program.

    Comments, Additions, Deletions, Regarding the Scoring Criteria as Follows in Blue:


    The following five questions must all be answered and supported with appropriate documentation prior to completing the remainder of the Criteria. Please circle the appropriate answer (you must be able to answer yes to the following to be considered further)

    1. Are you a Registered or Master guide in good standing with the Big Game Commercial Services Board and Occupational Licensing? This includes current with all fees, testing and other requirements.
    Yes No

    2. Are you certified by Occupational Licensing to guide in the unit you are applying for?
    Yes No


    3. Are you certified to guide for the big game species you are intending to guide for in the unit you are applying for?


    4. Are you currently registered for Commercial Day Use Activity on state land, on the DNR website?
    Yes No

    5. Is your bid amount equal to or greater than the minimum bid?
    Yes No

    6. Do you have proof you carry, and can provide coverage to the State of Alaska for bonding and insurance? Submit proof.
    Yes No

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    Default APHA Draft DNR Comments Part II

    ...and here is Part II
    Dennis
    ************************************************** ******************




    Scoring Criteria #1 – Relevant experience as a Big Game Hunting Guide and Guide Business owner

    This section will be scored for a range from 0-25 total points.

    The objective of this criterion is to accurately identify the individual applying for a GCA, and to verify the organizational structure of the business. This will be supported by providing specific answers to the following questions:

    Sub-factors are as follows:
    A. personal experience of the industry
    B. demonstrated ability to work with other individuals, agencies and communities

    Sub-factor A, Personal Experience as a Big Game Guide.

    Please consider the following suggestion related to determining scoring for experience.

    EXPERIENCE

    Guiding Experience
    Any ten years of last 20 would be scored as follows. Individuals could only score in one category for each year. Acting as:

    Reg/Master guide in concession area - 1 pt.
    Reg/Master guide in GMU - .5 pt
    Reg/Master guide in state -.2 pt
    Assistant guide in Concession are - .5 pt
    Assistant guide in GMU - .2 pt
    Assistant Guide in State - .1 pt
    Bonus 1pt over 10 years experience
    Bonus 1pt over 20 years experience
    Bonus 1pt over 30 years experience
    Bonus 1pt over 40 years experience
    (This is for guiding, not outfitting. Hunt records/affidavits must be able to show actual accompanying client in field on hunt.)

    Outfitting Experience
    Any ten years of last 20 may be scored as follows.
    Reg/Master in Concession – 1 pt
    Reg/Master in GMU - .5 pt
    Reg/Master in state - .2
    Bonus 1pt over 10 years experience
    Bonus 1pt over 20
    Bonus 1pt over 30
    Bonus 1pt over 40
    (In guiding and outfitting experience categories a minimum time may be required for a year to qualify. Based on different seasons throughout the state it may be difficult to generalize all concessions together.)


    1. Using the template provided, please describe your Big Game Guiding Experience. (2 points)

    2. How many years of big game guiding experience in Alaska do you have as a/an: (3 points)

    a. Assistant guide
    b. Registered guide
    c. Class A Registered guide
    d. Master Guide
    e. Other

    3. How many years of guiding experience do you have in the guide use area in which you are applying as a/an? Please provide dates and employers where appropriate.
    (3 points)

    a. Assistant guide
    b. Registered guide
    c. Class A
    d. Master Guide
    e. Other

    4. How many years of big game guiding experience do you have in other states? Describe in detail where your experience took place, what capacity you served the clients and what species you guided for. (2 points) Provide proof of experience, licensing etc. This criterion should not allow an applicant that has never guided outside of Alaska to be scored down in comparison with someone who has.

    5. Please provide copies of all hunt records for all clients you served for the past 10 years? (2 points) This criterion is good, except that by law, guides are only required to keep these records for four years. If applicants have purged their record keeping they may not have the hunt records. For clients prior to the four years you are capturing them in Scoring Criteria #1 Subfactor B, Question 5. If you are looking to define the experience in the area being applied for, these criteria would work better if you ask for any documentation including hunt records, guide-client contracts etc. that go back ten years, or further.

    6. Have you successfully completed any outdoor safety training? Please provide a copy of the course certificate. (Examples may include - Swift water rescue, avalanche awareness, Wilderness first responder, Wilderness EMT, Emergency trauma training, EMT, or similar.) (1 point)

    7. Please describe your formal education with regard to running a successful business or wildlife Management? (1 point) Should be required to show proof of completion.


    Sub-factor B, Demonstrated Ability to Work with Other Individuals, Agencies and Communities
    It should be discerned somewhere within the criteria that many service providers who operated historically on State lands, out of respect for wildlife conservation/availability-consumer protection-quality of experience concerns due to overcrowding, reduced their activities on these lands. Service providers who do not care about these concerns subsequently may have utilized what-ever methodology it took to be successful with harvest, regardless of their impact on the resources, or other service providers or their clients.

    1. Have you received all landowner authorizations as required for the past 10 years? Please describe where you have worked and show proof of permission. (2 points)

    2. Have you worked within a borough which requires authorizations for the last 10 years? (1 point) This criteria should be made clear that if an applicant has not ever guided within a borough and is not applying for a concession within a borough, that he or she can not be scored down in comparison with someone who has.

    3. Please provide letters of support from other land owners, boroughs, towns, villages, or native corporations regarding your past authorized use of the area. (1 point) This is a good criteria but should be looked at closely. If a applicant lives within a region and another does not, is it possible that any of these entities would give the local person the letter and not the other?

    4. Letter of recommendation for past clients. (1 point)

    5. Please provide a client contact list (including names, address, phone #) for all clients you served for the past 10 years. Please identify the following for each client specifically: Client did or did not harvest an animal, date, species hunted for. Also identify what capacity you served the client. (contracting guide, assistant guide, packer…) (2 points)
    6. Please describe how you educate your clients and employees how to be aware of local customs, traditions and courtesies. (1 point)

    7. Please describe your past and future meat handling protocol, including staff education, both while in the field and once back from the field. This may include meat sharing. (1 point)
    (2 points)

    8. Please provide copies of all licenses: Guide/outfitter, business, GUA, FAA, Coast Guard. (2 points) That are applicable to the area being applied for. An applicant who does not have a pilots or coast guard license but incorporates employees into his or her business that do, should not be scored down. Often times a guide who does not fly is much more active in the field with clients than those who do.

    9. Please describe your past and future trophy handling protocol including staff education, both while in the field and once back from the field. (1 point)



    Scoring Criteria #2, Operating Strategies Used to Protect and Conserve the Natural Resources of the Concession Area

    This section will be scored for a range from 0-30 total points.

    The objective of this criterion will be to evaluate the applicant’s prospectus for protecting, enhancing and preserving the Natural Resources within the GCA.

    The following proposed criteria are recommended for consideration.
    Level of Development needed to Facilitate Proposed Business

    Level of Development needed to Facilitate Proposed Business
    1. Existing or historic DNR land use authorization for the area being applied for.
    2. What new land use authorization will be needed to facilitate the applicants operation within the area being applied for?
    3. What existing facilities, equipment and supplies are currently maintained within the area being applied for are needed to facilitate the applicants plan of operations?
    4. What new facilities, equipment and supplies will be required to facilitate the applicants operation within the area being applied for?
    5. Does the applicant have contiguous private or public land use authorization that applies to his or her needed development within the area being applied for?


    Sub-factors are as follows:
    A. demonstrated willingness to protect wildlife and habitat resources on the ground
    B. protecting cultural sites and resources
    C. proven commitment to improving the hunting industry
    D. stewardship projects to complete to improve the area

    Sub-factor A, Demonstrated Willingness to Protect Wildlife and Habitat Resources
    These are good criteria. They need to be scored in a manner that does not allow for a “less is best” concept of grading. It takes a certain amount of support to effectively and efficiently provide a professional service. The scoring should be based on the overall scope of willingness and ability to provide good conservation of the resources.

    1. What do you propose to do to protect or minimize motor vehicle, ATV, snow machine, horse, boat and human impact on habitat within the area being applied for? (2 points)

    2. What do you propose to do to protect or minimize motor vehicle, ATV, snow machine, horse, boat and human impact on wildlife within the area being applied for? (2 points)

    3. What method will you use to minimize wildlife becoming accustomed to human food and contact? (2 points)

    4. How do you recognize big game cycles or population trends and how do you adjust your harvest or effort accordingly. (2 points)

    5. How do you/or will you communicate with wildlife managers of the areas you work? (2 points)

    6. If ADF&G and the BOG have authorized predator control in your areas, have you participated in these programs? Please provide copies of licenses/permits, sealing info, fur sales, etc. (1 point)

    7. How many predators identified by the Board of Game in an Intensive Management area where predator control is authorized did you or your clients take during the past 5 years? (1 point)
    Regarding number 6 and 7. It is important to understand that the Intensive Management (IM) law cannot be implemented in Game Management Units or Sub-Units where a certain level of historical harvest of ungulate species has not occurred. As such, there are regions where service providers have historically operated that will not have Intensive Management under existing law. If an applicant has been providing predator prey balance efforts in these areas but not actual IM areas they should not be down-scored or not be able to score as effectively as someone who has been only active within IM areas.

    This is an important criteria but should possibly be graded with two questions of one point each. One, on the applicants stewardship (predator/prey balance effort) of the area being applied for. And one for efforts in a different area of use which is within an IM Area.

    Additionally, some areas of State land such as on Kodiak, may have applicants who live on Kodiak. Should they be down-scored because they do not leave the island to conduct IM area predator harvest versus someone who is applying for a Kodiak concession who lives off of the island and can easily participate in IM effort.

    8. How do you propose to handle human and solid waste (garbage) generated from your activity? (2 points)

    Sub-factor #B, Protecting Historical, Cultural and Archeological Resources

    This is an important criterion. However, the Northern Archaic (4000 BC- Current) or older periods actual identifiable history in much of Alaska is minimally defined or documented. There are vast regions where few if any discoveries exist. There are also areas where cultural aspects of significant importance exist and they need to be recognized, respected and preserved. As such, it seems that this criteria could be scaled down to one point and the two questions combined. It would still generate the important consideration for these criteria.


    1. Please describe the type of information you will provide to your clients aimed at protecting the historical and archeological environment, additionally explain how the information will be provided. (1 point
    2. Please describe the type of information you will provide to your employees aimed at protecting the historical and archeological environment, additionally explain how the information will be provided. (2 points)


    Sub-factor #C, Proven Commitment to Improving the Hunting Industry

    1. How many years have you volunteered your time as an instructor for Hunter Education, Becoming an Outdoors Woman, youth shooting league or other outdoor related programs? (1 point)

    2. In the last year how many days have you volunteered as an instructor for Hunter Education, Becoming an Outdoors Woman, youth shooting league or other outdoor related programs? (1 point)


    3. How many big game hunting, bear baiting or trapping clinics have you instructed in during the past 10 years. (1 point)
    Regarding numbers one, two and three of this sub-factor: These criterion facilitate a needed responsibility for the guide service provider to be active in the public arena. As written, number two leans towards “run out and earn the one point”. They could be combined into one criterion with required documentation and graded with a focus on not just past but future involvement.
    This criterion should relate to all hunting, not just big game. Many youth programs start with small game. It is important to note that very few, (under five percent) guide service providers actually participate in bear baiting efforts. The bear baiting should be unidentified and kept within the hunting aspect. We recommend maximum of two points for the combined criterion.

    4. How many years have you served on a committee, board or organization related to the allocation of the natural resources of Alaska. This may include, but is not limited too ADF&G advisory committees, Regional advisory councils, Board of Game, Subsistence Board, Big Game Commercial Services Board, etc. (2 points)
    This is important criteria. It should be taken into consideration that certain programs are nearly impossible to become a member of as a guide service provider. As well, certain personalities do not lend themselves to serving at these capacities. However, involvement by guide service providers is vital within these arenas for the industry. The criteria should be designed to recognize documented participation in the processes by the applicant, such as written comment history, notarized affidavits of participation from Board Members etc.


    5. Please describe your past practice and future plans for donating hunts or services or money to organizations working to benefit the hunting tradition. This will included donated or discounted hunts, free accommodations at your facility, cash donations or other services. Examples may include Wounded Warriors, Hunt of a Lifetime, Hunter Heritage Foundation… (2 points)
    It should be understood that many service providers operate in regions where limited drawing permit programs or resource availability limit them to a small number of clientele per year. As such, they may not be as able as others who have better resource ability to compete fairly within this criterion. Free accommodations, cash donations and the like are very hard to document. The criterion should also relate to fishing, youth education, winter hunting or trapping, wildlife viewing, or conservation interpretive trip donations.

    Sub-factor #D, Stewardship Projects to Complete to Improve the Area


    1. One method of improving the Natural Resources of the area you are applying for is to offer to restore damaged or impacted resources, restore heavily impacted sites or clean up unauthorized camp locations within the concession area. Please identify projects that you feel would be beneficial to the natural environment of the area you are applying for and describe in detail the location, type of impact, method and timing of project you propose to take place. (2 points)

    2. List other projects you have completed for this or other land management agencies doing this type of work. (2 points)
    These criterion (both 1 and 2) may be very important concerns related to certain areas that have identifiable problems but not as important to areas that do not. Additionally, problem cases can be small or large in work required regarding contamination, clean-up, re-seeding etc. As such, the four points are high in comparison to overall scoring on a statewide basis. A suggestion would be to try to incorporate a partnership concept into this criterion by asking how the applicant would work with DNR, BLM or State Parks to mitigate problem scenarios. This could be done co-operatively by using a cost factor that would reduce the concessionaire’s annual fee requirement.

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    Default APHA Draft DNR Comments Part III

    APHA Comments part III
    ************************************************** ******************

    Scoring Criteria #3, Business Plan for Operating a Successful Business while Providing Quality Service to the Clients

    This section will be scored for a range from 0-30 total points.

    The objective of this criterion will be to evaluate the applicant’s business plan to provide appropriate service to the clientele.

    Sub-factors are as follows:
    A. Providing client and visitor services in a safe manner.
    B. Providing a quality hunting experience
    C. business plan that encourages cooperation with local communities
    D. operations plan for all facets of the business

    Sub-factor A, Providing client and visitor services in a safe manner.


    1. What aids or support do you provide to future clients to prepare them for the upcoming hunt before they arrive in Alaska? This will include gear lists, training regimens, and preparing them for possible extended stays beyond what is expected. (1 point)

    2. Please describe your emergency training requirements for all staff. (1 point)

    3. Please outline your emergency policy (suggest change to protocol) in the event of an incident or accident both while in camp or in the field. (1 points) This may be the most important aspect of being able to respond effectively to an emergency scenario in a high-risk environment. As such, we recommend (2 points). There should not be a significant emphasis placed on supplying the most of the most modern of communications and safety equipment but rather to the competency and practicality of the emergency and communication plan.

    4. Please provide documents relating to your past and future safety policies, if available? (1 point) They need to be provided. The “if available” is not applicable if this criterion is included in the scoring.

    5. Please provide a detailed listing of past incidents or accidents that resulted in the injury or deaths of clients, visitors or staff. (2 points)

    Possible additional grading concept as follows:
    SAFETY 10% possible
    1% for each year operating as a Registered or Master Guide w/o an injury to clients or employees. Any ten years of last twenty years may be scored.

    This is a hard one to prove whether any have occurred or not occurred. Disqualification for withholding pertinent information is very important here. Additionally, definition of incident is a concern. If a client, visitor or staff member suffered a stroke, seizure, heart attack, overexertion or the like which required medical attention or evacuation, which had no basis in the reflection to the service provider, the service provider should not be downgraded.

    Sub-factor B, Providing a quality hunting experience


    1. Describe the type of hunts that you plan to offer, including a sample itinerary. (1 point)

    2. Please describe the time you will spend with each of your clients during their hunt and where you will be while the client is afield. (2 points)

    3. Provide promotional materials used regarding your business and the area in which you work. (1 point)

    4. What is your employee hiring policy? This is for all levels of service from camp host to assistant guide. (1 point)

    5. Please describe how you will train employees in relation to photography in the field? What tools do you provide to your staff in this area? (1 point) The second part this criterion is ambiguous and should be removed.

    6. How do you intend to satisfy the requirements set forth in AS 08.54 and 12 AAC 75? This includes ensuring your employees are capable of performing their duties and that you as the contracting guide satisfy yours. (2 points)

    7. As a registered or master guide, please describe how involved you are with each client in the field. This will include one on one service or contracting with other assistant guides to conduct the hunts. (2 points) Unless we are missing something here, the second part of this criterion is unnecessary.

    Sub-factor C, Business Plan that Encourages Cooperation with Local Communities

    1. Do you hire residents from within the Game Management unit that this GCA is located within? (1 point)

    2. Do you facilitate or provide information to clients regarding meat sharing, or offer meat to local shelters, food pantries, individuals, families or communities? (1 point) Provide utilized meat transfer forms or notarized letters of proof.

    3. Please describe your policy to avoid conflict with other user groups, local hunters, and private property owners in the GCA. (2 points)

    Sub-factor D, Operations Plan for all Facets of the Business

    1. Complete Operations Plans are required for successful application to operate within a GCA. A complete operations plan will include a minimum of the following. Please discuss in detail how your business prepares for and implements the following. Add additional sections as needed to suit your plan. (4 points)

    In asking DNR what they are looking for with the following criteria, they replied that they are looking to use the answers from each applicant for questions 1 – 4 of this sub-factor to discern a reasonable balance between the numbers of clients, number of staff and the number of potential harvest per species the applicant plans on having. DNR needs this information to maintain the conservation basis of the program and to help them with defining the successful applicants. From this perspective, we would have the following comments:

    If a service provider has engaged in the multiple specie type of hunt opportunity, he or she should not be graded down for lack of historical harvest of some of the species. In many cases, a single ungulate species hunt will include wolf or bear harvest opportunity on a trophy fee basis. If a wolf or bear was not harvested, they should not represent an down scoring potential.

    Less should not be best in relation to scoring for planned harvest effort, client base or staff.

    It is important to note that certain clientele seek services from certain types of service providers. This criterion should allow fairness between a service provider who has limited or no additional staff and one who has several employees per client. What is important is the scoring should be based upon the quality of the hunt experience provided or included within the applicant’s plan of operation and the conservation balance it provides.



    Communications
    Transportation
    Training
    Fuel Handling
    Emergency Operations
    Safety/rescue
    Waste disposal (solid/liquid)
    Camp location
    Camp site development

    A) Base Camp

    B) Spike Camps

    Site mitigation/rehab

    Training and Mentorship of staff to promote better business understanding
    ___________________________ ___________________________

    ___________________________ ___________________________

    ___________________________ ___________________________
    2. How many staff members will you employ at one time during the calendar year, to service clients while in the field? (2 points)
    a. Assistant Guides ________
    b. Camp hosts ________
    c. Packers ________
    d. Cooks ________
    e. Other ________


    3. How many clients will you book for each big game species during the calendar year from this concession area? (2 points)

    f. Brown Bear _________
    g. Black Bear _________
    h. Mountain Goat _________
    i. Dall Sheep _________
    j. Moose _________
    k. Caribou _________
    l. Bison _________
    m. Musk Ox ¬¬¬¬¬_________
    n. Wolf _________
    o. Blacktail Deer _________
    p. Other _________

    4. How many animals of each species so you expect to harvest each calendar year from this concession area? (2 points)

    q. Brown Bear _________
    r. Black Bear _________
    s. Mountain Goat _________
    t. Dall Sheep _________
    u. Moose _________
    v. Caribou _________
    w. Bison _________
    x. Musk Ox ¬¬¬¬¬ _________
    y. Wolf _________
    z. Blacktail Deer _________
    aa. Other _________


    Scoring Criteria #4, Financial Ability/Commitment to Operate as Big Game Hunting Business

    This section will be scored for a range from 0-15 (recommend no scoring or minimal scoring for this criteria) total points.

    The objective of this criterion will be to evaluate the applicant’s financial ability to commit to a long term financial obligation.

    Sub-factors are as follows:
    A. What new employees, insurance, equipment, facilities, supplies or stock will you need to facilitate your proposed plan of operations and how do you propose to secure the funding needed to facilitate your proposed level of service.
    B. Does/will your business generate enough revenue to continue to provide the level of service you will be committing to annually?

    Sub-factor A, Available Funds
    Do you have available funds on hand now to offer this level of service? (1 point)
    Historical ability to facilitate the applicants proposed service in the area being applied for should be given credit.

    Sub-factor B, Revenue
    Does your business generate enough revenue to commit to this annual concession agreement?
    Should we suggest a pro-forma here? It should just be basic projected annual revenue and cost pro-forma.

    1. Is your bid amount equal to or greater than the minimum bid? (1 point)
    Yes No (Check the box that applies.)

    My bid amount is $________________ annually. (This is the total amount you agree to pay annually if selected for this area) (13 points)
    This criterion, when compared with the basic line of grading all of the rest of the criteria, destroys DNR’s ability to define the best operator on the ground applicant and provides for manipulation of the selection process by those with substantial financial resources or backing to prevail. This works against public opinion and acceptance, resource management, social atmosphere and industry stewardship concepts of the proposed program.

    This must be changed to allow the best stewards to prevail and not applicants with the most money or backing. This criterion as written will lend the program to be taken advantage of by wealthy individuals, hunt clubs, and other organizations. It also creates a great dissatisfaction among the existing industry service providers which recognize the unjust aspect of stewardship versus financial prowess.

    The financial remuneration aspect of the GCA program will by itself introduce new cost burdening to the industry. These fees will be on top of land use fees for camp or lodge use of State, State Parks and BLM lands. The fee aspect of the program should be weighed in balance with what we know the industry can afford in relation to similar existing programs operated by NPS, USF&W and the USFS which in most cases, do not have additional land use fees involved for camps or lodges.

    We recommend the following:
    We strongly recommend that the revenue generation recommended below be held under five points/percent scoring ability total and that the point difference be applied to stewardship criteria to allow broader scoring opportunity where it is most important in helping define the best operators.

    Recommend the following:
    A minimum and maximum annual concession fee amount of between 1K and 2K.
    An annual client fee per concession: 0-5 clients = $120.00 per client, 6-10 clients $150.00 per client, eleven or more clients = $180.00 per client.

    The combination of the concession fee and the per client fee will help provide a measure of support and balance for the different levels of opportunity that exist within the concessions. A concession holder in a drawing permit area where allocation is limited will not pay as much annually as a concession holder in an area where there is over the counter allocation opportunity.

    When using these numbers, if an operator has land use fees of between $1,000.00 and $3,000.00 per year per concession, receives a concession with an annual concession bid of $1,700.00 per year and takes ten clients per year at the $150.00 per client fee, his or her annual fees to DNR would be approximately $5,000.00. This amount is in keeping with other existing programs.

    At this fee and use level, the 244 concession opportunities would generate approximately $700,000 annually from the concession program alone. This projection is more than enough to adequately fund the program and satisfies the constitutional failure aspect found in Owsichek.


    Scoring Criteria #5, Violations/Citations/Convictions/Defaults

    This section will be scored as a minus to the point total accumulated from above. Maximum point deduction is 30 points.

    It is important to note that the professional guide industry in Alaska is held to an extremely high level of administrative oversight. Annual licensing, land use authorizations, annual reports, fee payments to multiple land owners, borough fees, extremely complex guide regulations, extremely complex hunting regulations, guide client agreements, hunt records, guide use area registrations, FAA, USCG, general liability insurance for high risk business, workman’s comp for high risk business, the list goes on and on. All of this is usually administered by the individual service provider who also has to take care of his or her family, book the hunts in a extremely competitive market, take care of his equipment and or livestock and file his taxes on time. This required administrative oversight does challenge the best of administrative aptitude and abilities. Honest mistakes are made and this program needs to protect honest operators and not penalize them for being honest.


    In many scenarios, when an action in the field occurs that results in an regulatory breach such as the wrong ram being harvested by a client or a bullet passes through an animal and strikes another that could not be seen at the time of the shot, if the service provider does everything by the letter of the law, stops the hunt, retrieves and turns in the animal and the meat, he or she and the client are often led to pay a fine by existing regulation. A service provider should not be severely penalized by these types of historical events. If substantial down scoring is applicable to these types of concerns, it works against the industry and agency best integrity interest. If there is a recurring history, yes, there should be a down scoring.

    As such, this criterion is important, but do not reduce the opportunity for an applicant who has made honest administrative mistake to not be able to compete effectively in this program. Applicants who have intentionally broke the law, especially in wanton waste, same day airborne, guiding outside of use area, guiding without land use type of convictions are serious and the proposed criteria works. However, the criterion should allow some cushion for historical administrative error.


    The objective of this criterion will be to evaluate the past performance of the individual applying for a GCA with regard to legal or administrative action taken against them.

    1) Have you been convicted in court of a violation of Alaska’s hunting, fishing or trapping regulations within the past 10 years? (7 points)
    a. Misdemeanor
    b. Felony
    i. Plea deals resulting from wildlife violation but convicted of something less
    2) Have you been convicted in court of a violation of any states hunting, fishing or trapping regulations within the past 10 years? (7 points)
    a. Misdemeanor
    b. Felony
    i. Plea deals resulting from wildlife violation but convicted of something less

    3) Have you received a ticket and paid a fine out of court for violation of Alaska’s hunting, fishing or trapping regulations within the past 5 years? (4 points)

    4) Have you received a ticket and paid a fine out of court for violation in any state for hunting, fishing or trapping regulations within the past 5 years? (4 points)

    5) Have you ever been in default or non-compliance with any public land agency? (4 points)

    6) Have you had any licensing actions taken regarding your business by the State of AK Division of Occupational Licensing or the Big Game Commercial Services Board? (4 points)

  4. #4
    Member Vince's Avatar
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    Default

    thats strange...

    i dont see any mention of us...


    I think folks should get an extra point or two for standing ground against the wild and willey Bushrat,,, crossing swords with Alaskatruewammer hammers...and wrestling with Brwnbr JAKE.... after all thats what TRUE guidestuff is made of..
    "If you are on a continuous search to be offended, you will always find what you are looking for; even when it isn't there."

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    I really didn't get this part...when i do the math it comes out to $3200...what am i missin'?


    "When using these numbers, if an operator has land use fees of between $1,000.00 and $3,000.00 per year per concession, receives a concession with an annual concession bid of $1,700.00 per year and takes ten clients per year at the $150.00 per client fee, his or her annual fees to DNR would be approximately $5,000.00. This amount is in keeping with other existing programs"
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  6. #6

    Default

    Thanks for posting.
    Looks like there still may be time for some of you guys to "rack up" points by doing some "clinics" or seminars!
    On balance most of the suggestions seemed to be reasonable. However, still doubt the "most qualified" will end up at the "top of the heap", at least not without a drawing in many instances.
    Again - thanks for posting.
    Joe (Ak)

  7. #7
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    i agree that alot of the suggestions were pretty decent...also agree ( know thats twice in one post that i've agreed with joe ) that they won't get the best/most qualified outa this.

    I'm still not sure what the "most qualified" means. The guy that moved in to the area that i hunt sheep last year and double the pressure, well i just found out that he's been hunting on the native land and BLM lands with no land use permit. The land owners have been notified..but unless he's be ticketed theres no way that will count against him on his application...he's got more experience than i do, senority and more trespassing and disregard for the others around him. But i see no way to weed thru that to find the 'most qualified".
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  8. #8

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    Quote Originally Posted by BRWNBR View Post
    i agree that alot of the suggestions were pretty decent...also agree ( know thats twice in one post that i've agreed with joe ) that they won't get the best/most qualified outa this.

    I'm still not sure what the "most qualified" means. The guy that moved in to the area that i hunt sheep last year and double the pressure, well i just found out that he's been hunting on the native land and BLM lands with no land use permit. The land owners have been notified..but unless he's be ticketed theres no way that will count against him on his application...he's got more experience than i do, senority and more trespassing and disregard for the others around him. But i see no way to weed thru that to find the 'most qualified".
    I guess two points, first, "...( know thats twice in one post that i've agreed with joe )...", look on he bright side!, means you're assured of having been right TWO times!; second, "... I'm still not sure what the "most qualified" means...", neither is anyone else and therein is the problem.
    Joe (Ak)

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    ahh grasshopper has open mind..fill up quick..like jedi.

    overall i'd still like to know the real purpose of this GCP, APHA keeps saying something about viable buisness, sustianablity stuff. and i thought this was about over crowding in SOME AREAS. The only element that we could control with is is guided hunters,thats only about 1/4 of whats out there taking game. unguided non resdients, residents, predators, winters and guides. So i guess i don't see how the GCP has much of anything to do with managment in the over all scheme. it should be geared toward user conflicts and not wildlife managament or business sustainablity.
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  10. #10
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    Default Here's file with the blue/red/black lettering

    Dennis, mucho thanks for posting this up! Attached is the Word file with the different colored comments.

    I thought most everything was fairly reasonable too. Few things though still concern me.

    1) Transferability - trying to look into just what clauses the feds have to transfer leases, and I'm still unclear whether or not APHA is asking for the ability to sell leases for a profit.

    2) Selection Panel of scoring judges to include two "industry representatives" - I think such a thing will introduce yet more politics and perception of good-ol-boy system influencing concession winners. Even if those reps can't vote. And even if those guides are retired.

    Also note mention of "professional prospectus writers" etc. This is something I had heard a while back, that lawyers and professional writers would likely be hired to write a prospectus. Guess who can afford that? So even if the competitive bidding goes away, imo we will still see the same advantage given to those with more money, or backed by hunt groups or what have you, because it seems likely a more professional prospectus will go over better. Most guides ain't lawyers either, and some can't even spell worth a darn <grin, no offense to anyone>, so I'd say the cost of that will become yet another added cost every time someone applies for a concession area.

    3) Asking for 3 concession areas instead of the 2 allowed now in the plan. If that happens, then even more contracting guides will be hit and likely go out of business.

    __________________________________________________ __________________________________________________ ____________________

    Would sure like to know just how a competitive bidding process got introduced from on high, since APHA opposed it all along. Everyone I have spoken with outside DNR, other agencies etc, opposed such a thing for the reasons APHA listed.
    Attached Files Attached Files

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    gee mark who sayz gides kant spel...

    another point that bothers me to a point is the mention i hear on occasion of guys with lodges having more at stake with their financial investments and looking at a half mil loss if they loose their area.

    I don't really see why guys should be rewarded or punished for how they chose to invest their money and direction they decided to take their businesses.
    Guiding is an unstable industry, permits aside.
    It pains to think someone with a half mil lodge, feels like their loss would be greater than 100 percent of my families income...which is what would happen if i loose out. Just because i chose not to go big, don't mean i should be less favored...after all..its about the most qualified guide for the area right? not the most invested....
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  12. #12

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    Quote Originally Posted by bushrat View Post

    "...1) Transferability - trying to look into just what clauses the feds have to transfer leases, and I'm still unclear whether or not APHA is asking for the ability to sell leases for a profit.
    At least with the USFWS areas could be transfered with approval of the refuge manager after a prescribed amount of time.

    [/QUOTE] "...2) Selection Panel of scoring judges to include two "industry representatives" - I think such a thing will introduce yet more politics and perception of good-ol-boy system influencing concession winners. Even if those reps can't vote. And even if those guides are retired..." [/QUOTE]

    I would agree "industry representatives" should not vote, however, without their involvement, though perhaps a shock to some, the "spoof quotient" might be pretty high with some of the applications. If these representatives are directly involved in reading and evaluating the applications, those applications should be redacted in such a way as to assure the applicant's anonymity. (Same should probably apply to evaluators.)
    Joe (Ak)
    (Note: Will try to improve my spzlling. What do those red dooted lines under the words meen?)

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    Aw, I was just joshing on the spelling thing. Sorta <grin>.

    Joe, even if applicants are just a number, I'd bet that an industry rep, depending on the area applied for, would know just who that applicant was based on a bunch of other things in the application. You don't spend all those years guiding, as you have, without getting to know who guides where, who wants what, who flies, who doesn't, etc. The kind of redactions to ensure a rep wouldn't know who that guide was, imo would take out too much qualifying information.

    Are there "industry representatives" on the selection panel that the NPS and USFWS and USFS uses?

    And can you tell me if on USFWS leases there can be a profit made on transferring the lease?
    Thanks,

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    i agree with mark, give a descritpon (lol theres my spelling) of a guides business,location and operation plan and you could probably figure it out..'specially if your involved.
    however i do also think we need to have somene there who can say, ya, thats resonable or no he's full of it...how to get the best of both worlds is just another speed bump on an already terribly bumpy road.

    i don't really see this scoring criteria stuff as something that DNR has really thought thru..i'd hate to be the first guy scored...
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  15. #15

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    Quote Originally Posted by bushrat View Post
    Aw, I was just joshing on the spelling thing. Sorta <grin>.

    Joe, even if applicants are just a number, I'd bet that an industry rep, depending on the area applied for, would know just who that applicant was based on a bunch of other things in the application. You don't spend all those years guiding, as you have, without getting to know who guides where, who wants what, who flies, who doesn't, etc. The kind of redactions to ensure a rep wouldn't know who that guide was, imo would take out too much qualifying information.

    Are there "industry representatives" on the selection panel that the NPS and USFWS and USFS uses?

    And can you tell me if on USFWS leases there can be a profit made on transferring the lease?
    Thanks,
    First, I would assume that any individual in competition with a specific individual or for an area would be excluded providing advice. Further, I should think their involvement would be limited to clarification of specific issues and not scoring. Certainly any biases should be of concern, however, from what I've seen, hypothetically, there would be a much greater chance of this because of the relationships that develop between "managers" and guides operating in common areas. Certainly in the case of the USFWS I never saw this occur. Irony is that those guides that theoretically would be in a position of developing this type of "bias" would be the ones most involved in management issues, the very ones the program is trying to select.
    Of approximately forty prospectuses and scores sheet I reviewed, during various appeals (all USFWS) only one, was hard to understand how the scoring had been achieved. Statical testing did not demonstrate any sort of bias by a particular scorer towards any applicant.
    If you have specific knowledge about some of the past "biases" I would certainly appreciate their being posted.
    To my knowledge there were no industry representatives on the scoring panels for the USFWS. I don't know about the other agencies.
    Regardless of what the "policy" might be regarding profiting from the transfer of a concession, if they are transferable a profit will made should be what the parties involved want.
    Joe (Ak)

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    Joe, thanks for reply.

    I suppose I'd ask you then, if there are no industry reps on the scoring panel with USFWS (except for the appeal process I guess), just why then do we need them for a selection panel of the state GCP?

    I mean, if the spoof quotient is really there...which I don't necessarily disagree with...I wonder how the feds get around that in choosing appropriate concession winners. All along too I have heard that this is modeled on the fed concession program to a great degree.

    Not sure if I quite grasped this:
    "Regardless of what the "policy" might be regarding profiting from the transfer of a concession, if they are transferable a profit will made should be what the parties involved want."

    Are you saying that profit in transferring a concession is in the end a good thing overall? Not sure if I read that right.

  17. #17

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    Quote Originally Posted by bushrat View Post
    Joe, thanks for reply.

    I suppose I'd ask you then, if there are no industry reps on the scoring panel with USFWS (except for the appeal process I guess), just why then do we need them for a selection panel of the state GCP?
    That question would be best answered by reading some of those prospectuses. Mine excepted of course, the "spoof quotient" was pretty high in some of the prospectuses. Unfortunately in some, high enough to displace more qualified applicants.



    Quote Originally Posted by bushrat View Post
    Not sure if I quite grasped this: "Regardless of what the "policy" might be regarding profiting from the transfer of a concession, if they are transferable a profit will made should be what the parties involved want."
    After re-reading not certain I do either. Was trying to say that "regardless of the policy about profiting from the transfer of concession - if the individuals involved agree on compensation the "policy" will be un-enforcable.

    "...Are you saying that profit in transferring a concession is in the end a good thing overall? Not sure if I read that right...".

    I really have no opinion about being able to profit from the transfer. Though, if they can be transfered there should be a time restriction to prevent speculation.
    [/QUOTE]

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    Default transfer for profit

    hmmmmm
    This could turn out like DNR Shore Fishery Lease Program for set net sites. You have a CFEC permit (license) to fish. But all the good spots are taken. The DNR issues exclusive use rights (shore Fishery Lease) to locations where a permit holder can demostrate a prior use. A permit holder can get exclusive use rights to 2 locations and fish a part of his gear on each.

    Now along comes Mr Latent Permit and says. Hey man I got no place to fish How bout I pay you off for one of your locations and we both fish a long net on each.$$$ The DNR processes the transfer without any questions on terms of transfer and everybody is happy except the next guy in line that now has 2 big outfits in front of him.
    I do not think guide use areas should be transferable for a profit.

    Remember what Teddy Said:

    “I should much regret to see grow up in this country
    a system of large private game preserves kept for
    the enjoyment of the very rich.
    One of the chief attractions of the life of the wilderness
    is its rugged and stalwart democracy.
    There every man stands for what he actually is
    and can show himself to be"

    Theodore Roosevelt

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    Teddy is already rollin' over...
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    The APHA has a monopoly goal, not a goal of 'resource first' like they claim. If they did, they would go with a proven resource first plan that actually limits the amount of hunting pressure an area receives. The APHA and BGCSB won't address the FACT that if the concession program is successful on a 'resource' basis, there will be a flood of hunters delivered to the area, to rape it, by transporters with unrestricted land use. The APHA and is using the politicing practice of 'refuse to talk about things that they know are holes in their plan'. There plan is to put competitors out of business.

    The possibility of transferability is zero due to constitutional issues. However, the APHA is openly telling us they will push for it because it makes the whole idea of a concession program more enticing to guides that are about ready to retire. If the areas are transferable, they can sell them and get something for nothing...like welfare.

    Many of the people in the coffee shops and certainly those on this forum and the DNR public comment posts are seeing that the concession program is not about resource management. If there were people who really thought this was a good idea, they would get on this website and post their arguments about why we are wrong. They choose to go directly to the Governor and the DNR to spin their tales and throw out deceiving comments to keep the ball rolling in their direction. I have said it before, there tactics are smoke and mirrors/misdirection. They concentrate on their strong points and claim that there weeknesses are simply 'not understood' by the people that don't agree with them.

    The APHA is a small group of people with good organization. Perhaps less time on this forum and more time on typing to the governor would be more productive for all of us. Bobby Fithian said the Governor's email address is governor@alaska.gov The APHA sends many letters to the Governor's office to get their special interests attention.

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