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Thread: AK BHA Guide Concession Program comments

  1. #1
    Member bushrat's Avatar
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    Dec 2005
    Now residing in Fairbanks from the bush

    Default AK BHA Guide Concession Program comments


    March 30, 2010

    To: Clark Cox
    Department of Natural Resources
    Division of Mining, Land & Water
    550 West 7th Ave, Suite 900c
    Anchorage, Alaska 99501-3577

    Re: Guide Concession Program to limit the number of big game guides operating on state lands

    Dear Clark and staff,

    Thank you for the opportunity to comment on the proposed Guide Concession Program (GCP).

    Alaska Backcountry Hunters & Anglers (AK BHA) is a conservation organization chapter dedicated to protecting and conserving big wild public-lands habitat. We also advocate for prudent wildlife management policies and allocations (including a state-mandated resident preference to our game) that ensure sustainable game populations and wildlife diversity.

    AK BHA opposes the Guide Concession Program as it is currently drafted.

    Wildlife Resource Issues and Concerns

    Part of the rationale behind the proposed GCP is that the allowance of an unlimited number of big game guides (and their client hunters) to operate on state lands, and some other BLM lands, has created an overabundance of guides and their clients that is causing “biological harm” to our wildlife populations. Essentially, overharvests are occurring in some areas, by guided non-resident hunters, and those overharvests affect both sustainability and future general hunting opportunities for all.

    The solution within the GCP to the problem of too many guides and guided clients causing biological harm to our wildlife populations is to limit the number of contracting guides that can operate in each new proposed concession area. With the ostensible intent to reduce the number of guided clients who can thence hunt in those concession areas.

    But the reality of the proposed GCP, as it is currently posited, actually does nothing at all to reduce actual guided hunter numbers, because there is nothing concrete within the framework of the proposed GCP that would prevent a contracting guide who wins a concession lease from hiring an unlimited number of assistant guides to work within that concession area.

    We have been told that DNR will attempt to work with the Alaska Department of Fish and Game (ADFG) to set sustainable biological harvest limits in concession areas for guided hunters, and that concession leases will only be awarded to contracting guides who submit a prospectus that aligns with those harvest goals. We would certainly support such harvest limits, but within the current framework of the proposed GCP, since there is nothing to ensure this will actually take place, we cannot support it.

    Other Solutions

    AK BHA continues to wonder why other more viable, concrete, and lawsuit-free legal solutions to the problems we continue to have with an overabundance of guides and their hunter-clients in some areas haven’t been truly considered.

    There has always been one concrete solution that would ensure overharvests by non-resident guided hunters does not and cannot occur: limit non-resident hunting opportunity in the areas where we have concerns with specific game species.

    Via the Board of Game, make those areas draw-only for non-residents and limit/cap the number of permits available to non-residents in a fair and equitable manner according to our state constitutional mandate that gives Alaskans a resident harvest priority to our wildlife. That is the solution that so many other states already have in place. This solution also helps to cure the other problems we currently have in some areas with conflicts between guides (guide vs. guide), and guides and resident unguided hunters.

    The other value of such a solution is that it is not open to any expensive legal lawsuits; the Board of Game has this authority without question and has used it already.

    That is the solution we prefer at this time, on an area-by-area basis.

    Other Concerns

    We want to also highlight the concerns we have for the many individual contracting guides of extremely high caliber and professionalism – some of whom are AK BHA members – who still actually guide clients in the field every year on fair-chase hunts, who will no doubt be forced out of business should this proposed GCP (as it is now worded) be put in place.

    Under no circumstances do we support any competitive bidding process!

    In speaking with the Department of Law, we have been informed that a competitive bidding process within the proposed GCP is more likely to help the program withstand the legal challenges that will surely come if this program is implemented.

    We firmly believe that any such competitive bidding process as proposed completely skews the intent of the GCP to pick the most qualified concession winner, and opens the door wide for manipulation of the entire application process by any guide who is wealthier than another, or gets the financial backing of hunt clubs and/or organizations.

    This puts us between a rock and a hard place, and is yet another aspect of why we must oppose the GCP as outlined.

    In closing, AK BHA well recognizes we have problems in some areas with the allowance of an unlimited number of guides and assistant guides, and where there are still general hunting (no draw permit needed) opportunities for non-resident hunters.

    These problems tend to be more prevalent in Dall sheep areas.

    The Board of Game well recognizes these problems, and so far has stalled implementing any widespread non-resident draw-only regulations for some species that would also cap the percentage of permits available to non-resident hunters, because of hopes this GCP would be implemented.

    As of March 30, 2010, we understand that DNR did not get the requested necessary funding or staff to follow through with implementation of this proposed GCP.

    The state of Alaska can no longer wait to fix the known problems. The guide industry can no longer wait to fix the known problems. We urge the guide industry to work with the Alaska Board of Game to look at each area and unit on a case by case basis, to define where problems are occurring, and to move to draw-only non-resident hunts in these areas that also cap non-resident hunting opportunity in a fair and equitable manner according to our constitutional directives to allow for resident hunting preference.

    Mark Richards, co-chair Alaska Backcountry Hunters & Anglers

  2. #2
    Member AlaskaTrueAdventure's Avatar
    Join Date
    Apr 2006
    Paradise (Alaska)

    Default Thanks...

    Alaska Back Country Hunters...Thanks.
    Thank you for your well written, well thought out comments concerning the DNR-APHA-BGCSB Guide Concession Area Plan.
    It's no secret that I have objected to this movement ever since it was first unveiled at the Dec 2008 APHA annual meeting, and then at the Jan 2009 BGCSB meeting in Anchorage.
    Following the conclusion of the semi-public teleconferences between DNR and the BGCSB Guide Concession Area Sub-committee in mid 2009, DNR regurgitated an even worse final product.
    Thanks, again, for the objections you expressed within your DNR-comments-document.
    I still believe it is unconscionable for the State of Alaska Dept of Naturable Resources to destroy the livelihood of honest and hard working Alaskans.
    The plan that DNR has presented, if implemented, represents an unjust loss of liberty.


  3. #3
    Join Date
    Apr 2009
    south of the AC

    Thumbs up Thanks

    Thanks Mark;

    I'm with you all the way this one.

    Well written.

  4. #4
    Member martentrapper's Avatar
    Join Date
    Apr 2006
    Fairbanks, Ak.


    DNR is a land manager. No business getting involved in wildlife management thru guide regs. They do have some requirement to manage use of the land.
    Good letter, Mark.
    If only some of your other responses were as sane!
    I can't help being a lazy, dumb, weekend warrior.......I have a JOB!
    I have less friends now!!

  5. #5
    Join Date
    Aug 2007
    Yukon Canada

    Default agree

    gotta agree, Mark very good letter, cant imagine any guide having a problem with those ideas. Good luck and hope the powers that be listen.

  6. #6
    Member Vince's Avatar
    Join Date
    Jul 2008
    Fairbanks most the time, Ancorage some of the time,& on the road Kicking Anti's all the time


    Good letter mark... sorry guys i still feel they should remove the mandatory guide requirement and let guides thin themselves out... folks that need a guide (you know the ones that you all carry up the mtn) will still buy a guide.

    especially here in the interior... and other areas with predator issues. by allowing non residents to take Griz with out paying a ton for it... we would have less of a predator management program problem and more funding for other areas... charge the fees accordingly of course... but allow folks to do what the departments are $$$$$ unable to.....
    "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."

    meet on face book here


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