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NRA Comments on Proposed Travel Management Plan for Federal Lands in San Luis Valley

Friday, December 28, 2007

1803 West Highway 160
Monte Vista, CO 81144
 
RE: Travel Management Plan
 
Dear Mr. Dallas:
 
Thank you very much for the notice you sent to the Federal Lands Hunting, Fishing, and Shooting Sports Roundtable, of which the NRA is a member, alerting us to the proposed travel management plan (TMP) for federal lands located in the San Luis Valley.
 
The concern of the NRA in this and other TMPs is that an exception is not being made for hunters to retrieve game off designated routes.  Unfortunately the TMP does not address the degree to which non-hunting OHV users have taken advantaged of the hunting season to violate rules pertaining to non-designated routes so there is no way of knowing what the magnitude of the problem is.
 
The TMP states that because it has been rarely possible to determine if someone was legally off a designated route to retrieve game, the privilege was often abused under the current management policy.  But, it is not clear how the level of abuse was ascertained, if it has been rarely possible to determine who was and who was not legally off a designated route.  The TMP provides no information on the effect that a restriction of 300 feet in a perpendicular direction from the edge of a designated route will have on those who hunt in the area.
 
The TMP states that if there are no restrictions on motorized game retrieval, the enormous size of the area to be covered makes it virtually impossible for law enforcement to patrol solely for this purpose; hence, the proposed 300 foot restriction.  This restriction, according to the TMP, will alert law enforcement that tracks beyond that point will be cause for investigation for potential violation.
 
The NRA is well aware of the tight budgets that both the BLM and the Forest Service are working with and can understand the need to prioritize law enforcement duties.  However, there would appear to be an opportunity to provide a balance between ensuring against the wasteful loss of game and the management of OHV use.
 
Unrestricted motorized game retrieval should have a negligible impact on the enforcement of OHV rules because hunting is not a year-round activity; its success is not an outcome for every day of hunting; and based on the assumption that not all hunting in the area is big game, there would be a limited need to use an OHV for game retrieval.  Furthermore, game retrieval occurs randomly, not by traversing a specific route, so the impact on the land would be minimal.
 
It would seem that an exception for hunters could be instituted on a trial basis, having big game hunters possibly notifying the San Luis Valley Public Lands Center where they will be hunting and on what day so it would limit law enforcement's concern or need to investigate OHV off-road tracks on that particular day, in that particular area.  The NRA's concern is that the 300 foot restriction will present the kind of barrier to hunting that the President's Executive Order #13443 signed August 17th of this year and entitled Facilitation of Hunting Heritage and Wildlife Conservation is designed to alleviate. 
 
Again, thank you for your letter notifying the members of the Federal Lands Hunting, Fishing and Shooting Sports Roundtable of the TMP and the opportunity to comment.
 
Sincerely,
 
Susan Recce
Director
Conservation, Wildlife and Natural Resources
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