Draw Process Working Group

To our CPW Commissioners and the DWG,

After reviewing the recent DWG meeting on May 29th regarding proposed changes to the license reissue process. I would like to take this opportunity to have my voice heard.

I firmly advocate for maintaining the status quo of our current reissue system, and I am opposed to implementing the suggestions put forth by the DWG in this regard.

The reissue system, as it stands, is a unique facet of Colorado's hunting landscape and should be preserved. Our weekly reissue opportunities provide equal access to all hunters.

The reissue list is not intended to be "fair" or convoluted, nor should it divert financial resources from wildlife conservation efforts.

Proposed changes, such as automating tag reissuance, may defer issues and strain resources without addressing the core problem. Maintaining the status quo would be more prudent.

The discussions around premium tag issuance often prioritize self-interest over broader conservation concerns. Conservation should be paramount in hunting discussions, as hunting plays a crucial role in managing wildlife populations.

On the matter of tag allocation to nonresidents, I align with the DWG's consensus of prioritizing resident applicants through all four choices before allocating over 25% to nonresidents. Their deliberations on this topic were insightful and well-reasoned.

I want to address the hot-button issue in the room regarding using points for all four choices. This approach will not mitigate point creep, not even marginally. Hunters will adapt and still strive for those once-in-a-lifetime opportunities. The reality is, for some tags, the demand far exceeds the supply.

The only viable solution to address point creep and accommodate more hunters is to issue more tags. Increasing tag availability without compromising scientific integrity and quality experiences requires improving habitat and increasing access. Bureaucratic changes and rule adjustments will never adequately solve this issue; action on the ground could.

Let's redirect the resources spent on bureaucracy towards wildlife conservation efforts. By investing in habitat enhancement and expanding access, we can truly make a difference for our wildlife.

Thank you for considering these important matters affecting countless hunters.

One thing that should be discussed and presented to the group is Resident early access to leftover tags. With the likely elimination of OTC, the leftover list is a residents last chance to get a hunting tag in their home state. Residents should have first choice, early access, and a right to get leftover tags before non-residents. This should be a comfortable time table like 3 days (when it’s initially released) early access so all residents have a chance to pick up tags. Then give non residents access and allow them to clean up. This seems like a very fair change - Residents take priority but non-residents have their chance so minimal tags are left unsold.

Overall, I think the group is doing a great job and heading in the right direction.

I like the idea of a hybrid draw but I think the 50/50 percentage allocation is too high. It should be 90/10 or 80/20 so the highest point holders have the greatest chance of being guaranteed a tag but also leaving a random portion to incentivize applicants with lower points to throw their name in the hat and still have a chance. The proposed idea of having bonus points on the random side still gives preference to the higher point holders but it adds complexity. By giving a high percentage of tags to the highest point holders, the one or two tags left in some of the highest demand hunt codes can go into a truly random lottery with no bonus points. It seems much simpler than having a max point draw and then a percentage of random draw that uses bonus points. I don't think this would cause much grief from the high point holders if only one of 10 tags gets issued to a random draw. Putting 5 of those 10 tags into a random draw is going to really irritate people. Even if the 5 bonus point tags are weighted to the high point holders. It still doesn't guarantee their draw and it has to be a kick in the shorts when a bunch of people with single digit points outdraw the same amount of people that have been waiting 20+ years for that tag.

The proposed 75/25 tag allocation across the board for residents and non-residents is ridiculous. We just improved this issue for residents by going to 80/20 for high demand tags and 75/25 for the lower demand tags. If we are going to make it one allocation, CPW should put Coloradan's first and make it at least an 80/20 across the board split. Wyoming, Utah, Arizona, and Montana cap non-residents at 10% of the tags in their draw. Colorado giving 20% across the board is more than generous. Between resident/non-resident splits and the OTC archery elk issue, Colorado residents continuously having to fight their own state agency over being overly generous to residents of a different state is getting really old.

I like the idea of switching to a bonus point system for moose, sheep, and goat. Squaring bonus points is easy to understand and it gives preference to those that have been putting in and waiting the longest. Our system now is like the DMV letting people walk in and cut in line in front of those that have been waiting an hour.

I don't like the idea of only putting in for one of the big three species per year and getting preference points only for the other two. I think this will create a wave effect where a lot of people will base their application on the previous years applicants and this will make the draw very unpredictable from year to year.

I agree with the group that you should only draw one of the big three species in a year but I think a good alternative to only being able to apply for one species in a year would be what Utah does for their non-resident draw. Drawing each species one at a time and pulling out the successful applicants from the later species draws. Since there are the fewest mountain goat applicants out of the three, have that draw go first. If you draw a mountain goat tag, your name drops out of the sheep and moose draw. Increasing the odds for those in the sheep and moose draw who don't have a mountain goat tag that year. Since sheep has the next fewest applicants, that draw is next. Those that draw a sheep tag drop out of the moose draw. This still allows for one species to be drawn per person but it gives hunters three draws to be hopeful for.

I also agree with only being able to harvest each of the big three species once in your lifetime. It isn't fair for someone to harvest two sheep before many others can't even draw one. This should also bring down point creep since the applicants in theory will be going down slightly every year by taking out those that have already harvested that species.

One other thing that I don't agree with is using points for 1st through 4th choices for all A list tags. With the threat of OTC elk tags going away for even residents, I may now have to choose whether or not I want to have a guaranteed elk tag every year in my normal OTC unit every year or have the opportunity of one day being able to draw one of Colorado's elk units that provide a higher quality hunting experience like 2, 201, 61, etc. I am confident I would be able to get an archery bull tag somewhere in the state as a leftover but a large part of my hunting experience is the tradition of being able to go to the same familiar spot every year.

I don't have an issue with youth having preference in the secondary draw. I agree with the commenter below that we should include disabled veterans in that preference too.

I appreciate the work you guys are doing and I have enjoyed listening to you work through this process.

My wife is a 100% disabled veteran (DV). She recently completed her hunter safety course here in Trinidad, CO. She was hoping to draw a 2024 bear tag to hunt on our land but was unsuccessful and awarded a PP. I told her we can try again on the secondary draw and then watch the reissue list.
Knowing “youth ages 12-17 receive priority for all licenses” is a great thing. My suggestion is to add a percentage / category of DV’s to have priority over general applicants in the secondary draw in addition to the youth so veterans like her have a better opportunity to draw a hunt.
Thanks for all you do!
Sincerely Michael S.

The reissue process meeting is this coming week. Please consider allocating reissued tags based off NR:R ratios or based off residency of the returned tag. Similar to models of other states. Colorado has 1.7% of the nations population, but residents are competing against an unknown (to the public) number of non residents when it comes to re issue tags.

Thanks
Patrick

I continue to observe the work being done by the Draw Process Working Group (DPWG) and I am still left with unanswered questions and concerning comments being expressed by the group. I have reviewed numerous public outreach efforts including the 2022 Big Game Attitude Survey, 2022 License Focus Group and numerous letters from CPW staff to the Colorado Parks and Wildlife Commission and Senate Bill 18-143, The Future Generations Act. I have reviewed comments left on the Engage CPW website and found the vast majority of individuals have similar concerns.

The #1 goal of Senate Bill 18-143, the Future Generation Act was stated as "Grow the number of hunters and anglers". Recommendations put forth by the DPWG are centered on what barriers can we put in place to limit participation, what process can we put in place to prevent someone from gaining a preference point and hunting in the same year, how can we force someone to use their preference point, what fees can we institute to slow participation. All of these seem direct opposite of what S.B. 18-143 desired. CPW has spent dollars and exerted employee hours historically on Hunter Recruitment, Retention and Reactivation Programs in an effort to maintain or increase hunter numbers and participation and the DPWG effort has centered on how to decrease participation, only allow a hunter to apply for one of the "Big Four", apply for a preference point or license but not both, force them to use their preference points and not allow a person the ability to hunt, contribute financially and assist in meeting harvest objectives while building preference points for a desired hunt which may take one, two or three points. Terms used include "repeat offenders" "barriers to entry" are particularly disturbing.

The Big Game Attitude Survey Summary Report dated 08/25/2022 (Quartuch, M.R. and Vornholt, M. (2022) Big game attitude survey summary report. Colorado Parks and Wildlife) is quite revealing in the feelings of those who replied to the survey. 61%of respondents believed the fairest way to distribute high demand licenses was through use of preference points. 48% of individuals were somewhat -to- very satisfied with their ability to draw a limited license and more than half (51%) are satisfied with the way preference points are used to award deer, elk, bear and pronghorn licenses. When asked which attributes were most important in big game license distribution, respondents said (by a #1 rank) (1) fairness (37%) and (2) predictability (29%). They overwhelmingly favored (61%-resident, 23%-nonresident) preference points points as the fairest method to distribute licenses. Resident respondents also overwhelmingly favored a 80%-resident 20% nonresident license allocation.

In a letter from CPW staff to the Colorado Parks and Wildlife Commission dated Aug. 25, 2022 dealing with preference points staff's recommendation was Status Quo, stating that 95% (nonresident) to 99% (residents) of the 2021 limited licenses for deer, elk, bear and pronghorn required 5 or fewer preference points to draw. Staff also stated "Preference point creep, which is cited by some hunters as a reason they did not draw a desired tag is limited to a small portion of hunt codes and licenses. Changes to the preference point system could have unintended consequences that exacerbate point creep and affect additional hunt codes" Based on my observations and opinion the system is not broken. Changes to the limited license draw process will at a minimum affect 247,001 hunters (2023 number of elk applicants) and quite certainly more when you consider hunters who apply for deer, bear or pronghorn but not elk.

Except for Big Game Attitude Survey and Big Game License Distribution Survey, which occurred two years ago, no public outreach other than the Engage CPW website, which was non functional during the most critical time period for the DPWG and which continues to be in disarray (one comment repeated 27 times and another repeated 12 times and numerous other comments repeated to a lesser degree making it extremely difficult to read) no effort has been undertaken as far as public outreach. The Big Game Season Structure (BGSS) process which in all reality will have a smaller impact on hunters, held 17 in person and 2 virtual public meetings.

I would ask that the DPWG look at the most recent surveys completed, valid comments and concerns expressed on the Engage CPW - Draw Process Working Group - webpage. Comments have been forced to be reactive to recommendations made by the DPWG and I would hate the process to be a "one meeting and done and we are not looking back or addressing valid comments expressed by the public".

I have submitted my thoughts previously on Primary Draw Methods, Preference Points and recommendations on Sheep, Goat and Moose draws and they remain the same. I would ask that the DPWG is given a detailed explanation on the current reissue process, (i.e. high point licenses are not just thrown on the list), consideration that some licenses come on the list midseason, etc... I would recommend maintaining the current license reissue process with no changes.

I have hunted Colorado Big Game for over forty years. I am very familiar with the preference point system and draw system which I believe to be fair, equitable and predictable, all-important characteristics. I support the status quo for the current draw and preference point system. When 98.6% of Colorado residents and 93.8% of non-residents are accumulating 5 or less points I'm not sure any changes need to be made. Any recommendation to split the quota 50:50 between standard draw and a bonus point draw only serves to exacerbate preference point creep for those with the points historically necessary to draw while awarding licenses to those with fewer points. This system is complex, not transparent to the hunter, and negatively affects predictability. Again, 98% have fewer than 6 points, do not represent a concern from the draw or preference point process, but would be drastically affected by this proposal. This proposal will do nothing to force or incentivize the use of points at the top end of the scale.

I do not support the required use of points for other than the 1st choice in the draw process. All choices from 2-4 in the primary draw should reward licenses without having to sacrifice points whether its an "A" license or not. By being able to draw a license in the 2nd-4th choice it demonstrably shows the licenses are not high in demand. The ability to draw licenses in the primary draw shows efficiency of the draw and contributes to management of the species. To require the use of points to draw a tag in all four choices will only force hunters into the secondary draw. This belief that hunters should not be able to obtain a point and draw a license in the primary draw is exclusionary and discourages participation. It also does not reflect reality when hunters are trying to build points for a hunt they desire but still want to participate in a hunt and contribute to the management of Colorado's big game resource through the purchase of a big game tag. In my instance, I can hunt buck deer and cow elk every third year by building points but still hunt every year in the meantime by using second choice doe tags and OTC elk tags. The draw and preference point process should continue to encourage annual participation by hunters from a continuity standpoint. Getting into the field to hunt big game takes a lot of time and preparation. Disrupted participation leads to curtailed participation.

I believe the DWG and the Commission should revisit Banking and/or Averaging as a means of resolving preference point creep at the upper end of the scale. These are the only means of addressing creep for those 1.4%. With proper guardrails in place either of these two methods could solve the problem at the upper levels. To do nothing means we aren't serious about solving creep so let's admit that and in the meantime quit proposing "solutions" for the other 98% where the system is working.

I am confused with the groups recommendation to go to a straight 75:25 resident/nonresident draw allocation. This to me represents a pullback from the recently adopted 75:25/80:20 draw allocation. If simplification is the priority then the group should recommend a straight 80:20 draw allocation which would represent a step forward for residents and not a step backward.

Let's refrain from implementing recommendations that are exclusionary or discourage participation. Under that banner I would include the charging of preference point fees, forcing the use of preference points for all list "A" licenses regardless of where in the draw process they are available, and the use of an "Either use points to get a license or Preference Point only" split choice boxes as a precursor for the primary draw. Big game hunting requires a continuum of participation otherwise, because of the time and monetary commitment, it's easier to just drop out.

I look forward to seeing the final recommendations that come forward from this group as a final comprehensive document. I believe that each proposal similar to the Big Game Season Structure working group should include a Status Quo option. I would also hope some level of public meetings are conducted perhaps through the regional sportsman caucus groups to gain additional public input. Submitting these proposals directly to the Commission does not adequately address the input needed for these major changes being forwarded for consideration.

With regard to the recent discussions surrounding the draw for Moose, Goat, and Sheep licenses I have very little input to provide as you have already excluded my participation due to financial considerations with regard to the $50 preference point fee you instituted several years ago. I don't believe there's enough of a difference between the weighted point draw and the bonus draw system to warrant the change. I do support the lifetime or 5 year restrictions on reapplying if one of these species is harvested to ensure full opportunity for participation by all.

Lastly, while acknowledging and thanking them for their commitment to the resource, I believe it is a process violation to have members of the Commission as voting members on these working groups. The role of the Commissioners is to represent their constituents and be able to question and cast a critical eye on proposals submitted to them for consideration. As members of this working group they have agreed, in advance, to support the consensus opinion of the group being brought forward to the Commission, all of this before they have received input from the hunting public and heard from their fellow Commissioners. I was alarmed at the lack of questions and discussion at the Commission meeting when the preference point options were presented. Although I don't believe it's been an issue with the DWG the appearance of undue influence potentially exerted by Commissioners serving as voting members of these groups should be avoided. This is an issue that warrants further discussion for the future by leadership within DNR and CPW.

Thank you for your consideration.

Apply NR allocation limit to all 4 choices in the drawing.

Non-Residents were issued most of the tags in the archery units that were recently changed from OTC to limited entry.

I'm a third generation Colorado native. My family has a long tradition of building memories while hunting and fishing in Colorado. We are common folks, middle class blue collar workers and civil servants who worked through college to pursue careers helping our fellow Coloradoans with the hope to make Colorado a better place for our kids. The meat we harvest feeds our family, and the memories we make while hunting and fishing enrich our lives and relationships with each other. We hunt all big game species when we are lucky enough to draw licenses, and we greatly value the opportunity and privilege as Colorado residents to have preference to hunt big game in this state.

For my family, maintaining the ability to predictably acquire big game hunting licenses plays a vital role in our hunting lifestyle. Regarding limited licenses, we understand that we may not all have the ability to draw a preferred license every year, but at least we can save a few points and study the draw statistics to PLAN based on a PREDICTABLE SYSTEM so that every year at least one member of our family has a decent license and our entire family can enjoy going with them. I want to reiterate how important a predictable draw system is to us. Removing a preference point system or changing it to a hybrid (50% preference point - 50% bonus point) system would greatly reduce this predictability and hurt our family tradition of hunting in Colorado.

For all the grumbling I hear over preference point creep, the reality is that we currently have a reliable and predictable system for drawing big game hunting licenses for elk, deer, pronghorn, and bear. Colorado largely manages for "opportunity" and not "quality." While there are a handful of "trophy" units and preference point creep in those units makes it unlikely that new hunters will have a chance early in their hunting life to draw one of those coveted licenses, that is actually still a fair system. I can't look somebody in the eye who has built preference points for 25-30 years for a quality hunt and keep a straight face while telling them the system should change to further reduce their odds of drawing so a younger person with a handful of points can draw license. Can you? Can you tell a 75-year old person that after investing decades into a plan for a quality hunt that you will give the opportunity to someone half their age with half their points? The reality is that preference point creep is only an increasing issue in a handful of quality hunts, while the system actually works very well for the rest of draw hunts. Why change a system that works because of the squeaky wheels who want better odds at a license in one of the most coveted "trophy" hunts? No everybody will have the chance for these licenses, similar to having the chance to draw a bull moose or bighorn sheep ram license.

The preference point system for the primary elk, deer, pronghorn, and bear draw is not broken. Again, let me reiterate this point, the current primary draw preference point system is not broken in terms of preference going to the person with the most points. The system is fair and the system is predictable. The system is also easy to understand. I heard repeated mention that CPW needs to move people (with preference points) through the draw process. In truth, people who want to move through will do so by using their preference points when they are ready to do so. They can either invest decades into trying for a coveted "trophy" unit license or they can use their points on another hunt with greater predictability in drawing based current demand, draw odds, and their own personal interests. As hunters applying in Colorado, we all have the choice to choose a personal application strategy, and having a predictable system makes it easier to do so.

While I support maintaining the current preference point draw system for the primary draw, I do not support the current allocation of licenses to nonresident hunters. Currently, Colorado is one of the most generous states when it comes to license allocation to nonresident hunters. While I enjoy hunting in neighboring states on occasion, I understand that residents of those states should always have significant priority. Those residents pay taxes, contribute to the local economy, contribute to the local communities, and help support the state every day of their lives. I am just a visitor to neighboring states, and I appreciate the occasional opportunity to hunt there, but I am a guest and guest privileges simply don't hold much weight over the folks who live there. For Colorado, please align resident/nonresident limited license allocation with neighboring western states. The extra money that nonresidents pay for their licenses does generate significant revenue, but the bottom line is that residents should always have significant preference for licenses and that preference should better align with neighboring states to help reduce demand in Colorado (might even help reduce some of the preference point issues for residents that is also a concern).

Regarding youth preference, I want to voice my support for continued preference in the primary draw. Kids are our future and I appreciate the increased opportunity that kids have in Colorado compared to when I was a kid. Nowadays, kids have greater preference to draw a license in the primary draw and have opportunity to hunt all seasons (for antlerless) if they don't harvest an elk or deer. Incredible opportunity compared to when I was a boy and might get two weekends a year to chase after a deer. My hat is off to the good folks who helped make this opportunity happen for our kids. Thank you for this! Just one thought on the youth preference though, specifically regarding 100% youth preference in the secondary draw and the idea of using preference points for 2nd, 3rd, and 4th choices in the primary draw. I imagine that if preference points are used for all choices in the primary draw that many more licenses will go to the secondary draw because folks don't want to risk using preference points for a license that should take no points to draw. If there is a large increase in licenses into the secondary draw and youth preference remains 100%, then significant opportunity for licenses will be removed for everyone else. I fully support increased youth opportunity, but not at the expense of preventing our more seasoned hunters from getting into the field too. Please consider reducing the youth preference in the secondary draw to something more like 50% (still higher than the primary draw) if you change the primary draw to require use of preference points for all options.

A final comment on the primary draw and preference point system. Regardless of what happens with preference points vs a hybrid system, please only have points apply to the first choice of the primary draw application. We greatly value having the ability to apply as a first choice for a hunt that takes preference points, while have our 2nd/3rd/4th choices be less desirable options that do not have preference points. This allows us to plan for hunts that may take 1-3 preference points so we have a good hunt every few years, while also have a chance at a less desirable hunt that won't use our preference points so we can still have time to spend as a family in the field hunting. This is part of our planning, and something we have the ability to do because of the current system that is predictable and allows for 2nd, 3rd, and 4th choice options that do not use preference points.

My final comments relate to discussion over the draw process for moose, sheep, and goat. Currently, we have a weighted point system that is basically the same thing as a bonus point system. From what I understand from these meetings, they may work a little different but the result on draw odds is virtually identical. This is very similar to the draw system used in Utah for their limited entry hunts, and I know other states that use a similar process for highly prized hunt opportunities where demand is very high for the few coveted licenses available. I struggle with this a little, because every year I see occasions where people with a few weighted points draw a coveted license instead of people with several times more weighted points. That said, given the VERY LIMITED number of licenses, and the the exceptionally high demand for those licenses, it seems this system is working to meet the goals of CPW (provide preference for high point holders, while also giving others a chance to draw a license for these species). Personally, I'd support staying status quo with the current system for sheep, goat, and moose. However, I do think there should be a once-in-a-lifetime harvest for bighorn ram and either-sex goat license holders. Similar to bull moose, if you harvest a bighorn ram or goat on an either-sex goat license, then you should not be allowed to apply for those again (including auction / raffle tags for same). That said, I think the greatly reduced demand for mountain goat nanny licenses, bighorn ewe licenses, and cow moose licenses is justification to allow hunters to still be allowed to apply for these licenses after a waiting period following harvest. Just my two cents on the matter.

Lastly, on the issue of landowner vouchers and auction (not raffle) licenses. Landowner vouchers should ONLY be valid on the landowner's property and NOT ON PUBLIC LAND. Further, eliminate auction licenses in Colorado and convert the auction licenses to raffle licenses with a purchase cap of just a few raffle tags. Stop perpetuating the sale of a public resource and allowing the wealthy to have preference for coveted licenses in this state. I generally support CPW (formerly DOW) management practices and programs, but I hate seeing a rich fella be able to drop $30,000 every year to buy a landowner voucher for their annual unit 201 bull elk hunt (or something similar to this). Rich man's sport... thought we were trying to prevent this sort of thing with the North American model....

Thanks for the chance to comment. My hat's off to CPW's field staff of game wardens and biologists who put boots on the ground every day and know what it means to manage with science while working in our communities. Governor be damned, our hunters and anglers want an agency full of highly educated wildlife folks to manage our states wildlife resource and not a bunch of pencil pushing special interest groups who don't know what it means to responsibly use a renewable natural resource for the good of wildlife and people. God bless

Regarding the re-issue process, please leave the system as is but please take peoples points for A-list tags. No person should be getting A-list tags without their points being wiped out.

A TON of unit 76 Elk tags went to people last year with 0 consequences to their points......this is just plain ridiculous. This is a tag that people wait 15+ years to hunt. They are being awarded to the person with the fastest trigger finger on their computer mouse with 0 consequences to their existing preference points.

Start taking peoples points and stop giving out high point tags without requiring people to use their points. Even if it is 5 points for a tag that normally goes for 20 points, it is at least fair to eliminate their points and set them back to 0 points for next year's draw.

The way the re-issue process is currently set up, it is only increasing point creep.

Thank you CPW for considering this idea.

I am late to the game here but have watched a little bit of the working group meeting recordings, some of the Commission meetings, and have read a number of the comments below. The comments below are disconcerting at best. This is the venue for the general public to submit comments to the working group, I now see that this venue is down for 2 months? How can I trust that this feedback I’m providing will either: 1-be read by anyone involved in the working group, or 2-be provided to Commissioners by the agency? Just seeing the high number of repeat messages tells me that this website and comments aren’t being managed at all. I’ll be honest-I gave up on page 3. Again, being this late in the process I’ll focus on the comments provided here previously. It is also painfully obvious that there are members of the Commission that do not have a clue about preference points or the system to allocate them. This is particularly troubling for someone who has been applying for licenses and accumulating preference points for more than 40 years.

There is a lot of wisdom coming from Retired2021-obviously someone who has a grasp on the process and a vested interest as well.

Don’t require the use of preference points through 4 choices or on
secondary draw. As noted by others here it will do nothing but
force people to apply for high preference point units that they
won’t draw and then get their preference point-pushing the
licenses into the secondary draw or leftover list.

No exorbitant preference point fees-and I feel $50 to be exorbitant.
Do not make this a rich man’s sport. Please eliminate it from the
Big 4 also. That goes for the small game species permits being
considered elsewhere.

Do not limit a person’s ability to apply for the “Big 4”- Retired2021
nails it on this one. If you can’t show me there is a problem-don’t
tell me you’re going to fix it. Desert bighorn should remain the
same-you can’t apply for rocky mountain and desert bighorn at the
same time. What is being proposed for the rest of the Big 4 is
marginally acceptable to me. Doing away with the current
weighted system and going to the modified hybrid draw. I feel that
those folks that are long term investors in the current system will
be rewarded as requested by Snellstrom below.

Again, marginally acceptable to me, is moving to a modified hybrid
draw for all species. Highly invested applicants should benefit
from this, but folks new to the system will have some chance of
drawing. The impact on new people needs to be considered. I am
lucky to have invested 40+ years into the system, but my
grandchildren will have a very limited opportunity to seek high
quality hunting options.

I don't believe that preference point banking has been fully vetted.
There is a lot of speculation as to how it will play out. It wasn't
given a chance when it was tried previously. A very simple example
is used as the reason not use it. An applicant with 20 points will be
able to draw a 5 point unit 4 times-that's purely speculation-
regardless a high number of preference points are used. It seems
to me that that is what is wanted.

I mention a couple of times-Marginally Acceptable. I use those terms because I have spent 40 years in this system that, if it functions as advertised, is predictable and fair.

I listened to the Draw Process Working Group's work session #3 dealing with weighted points. This work session centered around the "Big Four" species consisting of Desert Bighorn Sheep, Rocky Mountain Bighorn Sheep, Mountain Goat and Moose. Three of the four species utilize a weighted point system and Desert Sheep utilizes a random draw. Additionally, an applicant is prohibited from applying for both a Desert Sheep and Rocky Mountain Bighorn Sheep in the same application year. Similar to previous discussion on preference points, much time was spent on those individual at the top of the weighted point scale. I wish the group would take a hard look at how few number of individual are at that level in relation to the total number of applicants or CPW give detailed information and numbers on how preference points and weighted points are spread across the board. For Mountain Goats, Adult Resident applicants with three preference points and ten or more weights make up 5.3% of total applicants, those same Adult Residents with three preference points and a max of twenty-two weights make up 0.04% total applicants. Numbers are similar but slightly higher for Rocky Mountain Bighorn Sheep and Moose. For Rocky Mountain Bighorn Sheep, Adult Resident applicants with 3pp and 10 or more weighted points-7.8% of total applicants, 3pp and max 22 weighted points-0.3% of total applicants.
For moose, Adult Resident applicants with 3pp and 10 or more weighted points-8.8% of total applicants, 3pp and max 22 weighted points-0.42% of total applicants. By far, the majority of applicants are on the lower end of the scale and given the ratio of licenses allocated each year to applications received each year, most will not draw a license for these four species in their lifetime. Nothing will change that. I wish CPW would provide draw success information that details percentages of licenses drawn in relation to preference points and weighted points. Show that the weighted point system statistically favor those with high points while still allowing a small opportunity for an applicant with fewer points a chance to draw. If the system works as designed, say that. If the system is flawed, say that but endorse it with proven data. The Draw Process Working Group proposed several alternatives to address the current situation. I would not support allowing a person to only draw one of the four species per year or withdrawing their applications for remaining species if they are successful in an earlier draw. This does happen each year but the number of applicants who draw two of the three/four species is so small it won't make a difference and only penalize those lucky enough to draw. I do not support limiting a person to only applying for one of the four species. You have lowered my chance of success from 1% to zero on those species you prohibit me from applying for. Unlike
some members of the Draw Process Working Group who apply in 5 or 6 states annually for Bighorn Sheep, Moose or Mountain Goat, many Colorado hunters are only able to apply in Colorado as a resident hunter. Do not limit them in their own state.

I do support making Rocky Mountain Bighorn Sheep rams a "once-in-a-lifetime" license if a person harvests a ram. I do support making any Mountain Goat a "once-in-a-lifetime" license if a person harvests any mountain goat. If a person draws a license for any of the four species and does not harvest, install a waiting period before that person can apply again, similar to the waiting period now in place for those that successfully harvest a Mountain Goat or Rocky Mountain Bighorn ram. I would recommend that the "once-in-a-lifetime" limits also apply to any auction, raffle or special sheep management license or license sold/issued through the Bighorn Sheep Access Program (BSAP).
Do not make change just for the sake of making a change. Please articulate what the goals and objectives are for any action and identify how the changes will assist in meeting those.
As I stated in an earlier post, I feel the current Parks and Wildlife Commission has a poor understanding of the current preference point system, how they are acquired or are utilized, a poor understanding of the current draw process and how changes will impact individual hunters. Consider a status quo approach for those pieces that are working well.

Thank you to those Draw Process Working Group members who take the initiative to review comments submitted here and to those that realized that the website was down for nearly two months and unavailable to receive any public comment on these important issues given the fact that no public meetings were scheduled and public participation is not allowed during the work session.

The DPWG should PLEASE MAKE NOTE of CPW Director Davis mentioning in his opening remarks to the April 5th commission meeting that hunters deserve to be able to have certainty in being able to draw an Elk license every year. As mentioned already in my previous DPWG public comments, the DPWG recommended change to require use of all preference points with all four primary drawing choices would greatly reduce the hunters confidence/certainty in being able to draw a hunt they have traditionally been able to obtain by way of the 2nd-4th choice, while also continuing to be able to obtain an additional preference point from the primary drawing 1st choice towards a license which is requiring more preference points than they currently have available. While knowing a hunt they have traditionally been able to obtain with confidence/certainty from a primary drawing 2nd-4th choice is not one that has traditionally been found available from the “left-over” secondary drawing. And/or, not finding any other hunt they might have found desirable listed as one that is available in the “left-over” secondary drawing. Or, what is “left-over” in the secondary drawing having by-far fewer licenses left and by-far too many hunters competing to draw that license, than what they would have had confidence/certainty in drawing that license when applying for it in the primary drawing 2nd-4th choice. When not finding any desirable hunt “left-over” in the secondary drawing, the hunter will be greatly disappointed and likely decide not to hunt.

I know this all sounds redundant to my earlier comments on this subject, but given CPW Director Davis’s remarks on this subject sounding this same concern/consequence, I feel it would be wise for the DWGP to revisit their recommendation that would require the use of all preference points on all four primary drawing choices. I might also mention (again) that although I have been a proponent for a preference point change for many years, given the “deeper” thought/consideration that is now being given to all the ideas for preference point change, and the vast far-reaching consequences and cost each would have, in my humble opinion “the remedies are looking more problematic” than what is the existing lesser problem itself. As staff has also recommended during the many previous commission meetings when the subject of preference points has been discussed, I am now recommending staying with the status quo with its predictability and hunter familiarity with the current system and how to make the best use of it as being the better idea on the table.

Why can't we make a change in the way premium tags are drawn? Why not issue 25-30% to the highest point holders and the rest be drawn as they are. Within 5 years this would "clear the decks" of the highest point holders also rewarding them for their long term allegiance. Then the drawing pool would be more equitable for all participants. As it is the system is not rewarding long term drawing participants with tags and some of these people who have been trying for 26 years may die before they are rewarded for their long term support.? I have many other well thought out ideas, just ask me. I am not new to this game I have been applying for Moose in Colorado long before preference points were given and I remain unsuccessful and have the maximum Moose points possible. Thank you.

Make the 75/25 Resident/Non-resident split also apply to second choice.

SUBJECT: My Comments, per Draw process Working Group briefing to March 14th Commission Meeting Agenda item #27: Draw Process Workshop

INTRODUCTORY COMMENTS (If not wishing to read my lengthy comments, please kindly read my closing comments):
1) For more than two months the ENGAGECPW.ORG web site for the Draw Process Working Group (DPWG) public comment input capability was not functional. Unfortunately, during that lengthy outage, and in-person comments during DPWG meetings not supported, public commenters had no means/opportunity to provide input/comment to the DPWG during that lengthy outage. Of most recent concern/importance was this outage prevented the ability to provide important public comment both before and for weeks following the discussion and decisions made during the very important DPWG Session #2 Preference Point meeting.

2) Similar to the commission meeting process, it would be very helpful if the DPWG staff briefing
materials could be posted for public review a week or so prior to a DPWG meeting. So, similar to the beneficial pre-commission meeting agenda public comments, this same benefit could be made available to the DPWG members prior to discussions and decisions being made during DPWG meetings.

MY COMMENTS, per the March 14th DPWG DRAW PROCESS WORKSHOP COMMISSION BRIEFING: I watched the DPWG Session #1 and #2 streams with great interest, as I also do for every commission meeting. There was obviously lively discussion and deep far-reaching consequences with all the preference point ideas considered during the DPWG Session #2 Preference Points meeting and those ideas then briefed to the March 14th commission meeting. That has been the case every time the preference point topic was discussed during recent year’s commission meetings, sportsman’s roundtables, focus groups, public outreach surveys, etc.. I appreciate a moment to provide my views for further DPWG and commission consideration on the subject of preference points:
- I do NOT support the DPWG recommendation for a change that would require preference points to be used with all four primary drawing choices.

- During a past preference point focus group meeting I participated in, staff briefed that a majority of non-residents looking to get the primary drawing first choice preference point do not enter the primary drawing looking to draw on a 2nd-4th choice which if doing so would have provided them a hunting opportunity. Whereas, a majority of residents looking to get a preference point from the primary drawing first choice do in fact provide a 2nd-4th primary drawing choice they are familiar with and have confidence in drawing that 2nd-4th choice which does provide them a successful draw for a hunting opportunity they desire and are familiar with. Like that majority of residents, this is what I do along with my family members and friends do, while looking towards accumulating enough preference points to then later drawing a license for a hunt code that is requiring more points than we currently have. If requiring the use of all preference points with all four primary drawing choices, you can obviously see the consequence and serious dissatisfaction a change like this would have that requires all preference points to be used with all four primary drawing choices.

- Obviously, after all primary choices have drawn, the “left-over” secondary drawing choices which would not take away preference points cannot be expected to be any hunt code choices which the hunter may be familiar with and/or would be undesirable to hunt. Then not hunting, due to the DPWG recommended change, and in order to continue to acquire a desired primary drawing preference point, would financially hurt CPW, would be counterproductive to CPW harvest management objectives and hurt being able to reliably plan to hunt each future year while needing to continue accumulating needed preference points. Whereas, being able to plan for being able to acquire a preference point from the primary drawing 1st choice and then draw a license to hunt from a 2nd-4th choice every year greatly helps with hunter satisfaction and thus retention.

- The feeling I get from the DPWG recommendation is that there is something wrong with acquiring preference points towards being able to draw a license that necessitates having more preference points than they currently have, while still being able to reliably plan for being able to hunt every year from drawing a 2nd-4th primary drawing choice license.

I offer the following as what I believe may be the better ideas worthy of further in-depth consideration by the DPWG and commission rather than having to use all preference points for all four primary drawing choices:

During the 2022 commission meetings preference point discussions, staff felt that mitigating the issues related to preference points could take a couple of ideas working in tandem. The DPWG should take another in-depth consideration/look at tandem, or the individual benefit of, Banking and a Preference Point Fee. I’ll provide my comments on these two ideas as follows:

1. FOR BANKING which several DPWG members mentioned an interest in: I used Preference Point Banking along with many others during the one year it was in place and I and so very many other hunters felt that Banking is a good idea worthy of possibly further in-depth consideration/refinement/adjustment. Banking does significantly reduce preference point creep and high preference point numbers accumulation, both of which are overall the major objectives/needs expressed during preference point discussions. Details and improvements to banking needs to be further studied/considered to hopefully improve upon or reduce the effect on mid-to-lower point hunt codes. OF SPECIAL NOTE HERE IS THE FOLLOWING: During the May 2023 commission meeting, when staff briefed in depth the subject of preference point banking in response to commissioner Hasket’s request, staff presented several Banking related refinements that could be considered further, possibly improved upon or to stimulate further thought of other possibilities, to possibly help improve the effect of banking on mid-to-lower point hunt codes. During the DPWG meeting #2 discussion of banking, those ideas nor any other ideas that DPWG members might have had the opportunity to think of for helping with the banking effect on mid-to-lower point hunt codes were not mentioned for DPWG members consideration. It is likely that a discussion of ideas that might help with the effect of banking on mid-to-lower point hunt codes would have taken a lot more time than could be provided for during the DPWG #2 meeting. Alas, I believe banking could use further in-depth DPWG consideration and discussion.

2. A PREFERENCE POINT FEE, which several DPWG members mentioned an interest in: Briefed during the DPWG meeting and previous commission meetings, staff mentioned a couple of observations when the current preference point fee was implemented for Moose, Sheep and Goat. Mentioned was the number of Moose, Sheep and Goat license applicants was rising very rapidly. Also mentioned was that when the preference point fee was implemented for Moose, Sheep and Goat it leveled-off the creep of preference points for a period of time. Then after that period of time there was again some preference point creep rise. Obviously, the rapid increase in Moose, Sheep and Goat applicants had the eventual effect of seeing again a rise in preference points. My observation is, what would have been the even more rapid rise in preference points creep had a preference point fee for Moose, Sheep and Goat not been implemented. I should also observe that hunters who are going for the more difficult, “up-scale” Moose, Sheep and Goat licenses are not too concerned about what the cost is for a preference point knowing that it takes a large number of preference points to improve your chances to draw a Moose, Sheep and Goat license in the weighted preference point system used for Moose, Sheep and Goat. The subject of Preference Points in relation to Moose, Sheep and Goat is NOT the same consideration when related to Elk, Deer and Pronghorn and almost like trying to compare Apples and Oranges and both these use very different preference point handling systems.

Rather than a preference point costing the Elk, Deer and Pronghorn hunter essentially nothing with only a very small $8 cost related to submitting a drawing application, the Elk, Deer and Pronghorn hunter should be also charged an additional fee for a preference point, like what is already being done for Moose, Sheep and Goat. A preference point fee for Elk, Deer and Pronghorn would help with Elk, Deer and Pronghorn preference point creep, by giving those hunters a second thought about whether or not to check the box on the drawing application for a preference point that would now have many thinking to not check that box. The point is that when fewer Elk, Deer or Pronghorn hunters select to receive a preference point, there will be less preference point creep. Elk, Deer and Pronghorn hunters are currently receiving a BENEFIT from a preference point. Yet there is no cost specifically associated with receiving that significant benefit. Given that CPW systems already have in place a fee based preference point for Moose, Sheep and Goat, this could be simply, quickly, easily and inexpensively expanded upon to include a preference point fee for Elk, Deer and Pronghorn…. A preference point fee could also help offset the CPW revenue losses from having moved to a 75/25 percent resident/non-resident license allocation. And how about the revenue loss from what is a significant movement away from unlimited OTC licenses (which has already been discontinued in the severe winter zone) and the huge reduction in limited licenses in the severe winter zone for what is expected to be years while the herds recover. Also, consider that a preference point fee for non-resident Moose, Sheep and Goat is much greater than that for a resident and the same could be applied as a greater preference point fee for non-resident Elk, Deer and Pronghorn. And, where each year a cost of living adjustment takes place for licenses, why has the $50 preference point fee for Moose, Sheep and Goat never increased, when staff briefed that the statutory limit is $100. Also consider that a preference point fee exists for all the big game species in other states. Also in other states, the preference point fee is a “tiered” scale with a different fee for each big game species. With a higher fee as you move up the “scale” from a Pronghorn being a much lower fee than what the fee should be for the likes of a Moose, Sheep and Goat.

Making it increasingly costly to individual hunters and their families to participate in hunting due to increasing financial requirements is counter to the efforts of recruitment and retention. But two observations here may be helpful: Again, there is a benefit received from a preference point, but currently no cost specifically associated with receiving that significant benefit. Also, if increased overall cost to a hunter when there is a preference point fee is of most concern then please discontinue requiring the overwhelming unpopular requirement to purchase a “qualifying license” forced upon hunters. The “qualifying license” requires a hunter to also purchase an additional “qualifying license” they may not need or use in addition to the license they are submitting for in the drawing. And, why is it that a fishing license alone, which a majority of hunters would find more useable and satisfied with is not a “qualifying license”. Again, if increasing overall hunt cost is a major concern, discontinue the “qualifying license” and implement a preference point fee that is currently free and would actually provide a useable benefit to all hunters who receive a preference point. A preference point fee will also have the added benefit of reducing preference point creep, does not have all the complex far-reaching unintended consequences that other preference point ideas have, could be simply, quickly, easily and inexpensively implemented and would help reduce CPW revenue losses from current changes that have already been made and other upcoming new and expected changes and factors.

CLOSING: Rather than the far-reaching and sweeping idea of using all preference points for all four primary drawing choices, and the significant serious hunter dissatisfaction and consequences a change like that would have, I offer my comments above related to banking and/or a preference point fee.

OR MAYBE CONSIDER MORE SERIOUSLY:
Although I’ve been a proponent of a change to the current preference point system for a long time now, the more I consider the ramifications and consequences of the possible preference point changes/ideas; the more I have been concerned about:
- No clear public reasonable favor for any one of the preference point change ideas.
- The widely varying and very serious far-reaching differing consequences of the various preference point change ideas.
- Staff having briefed during every preference point discussion during recent years that issues of preference points only affects an extremely small low single-digit percentage of hunters.
- The very heavy cost financially for systems/process changes, years to implement, additional staff workload to make changes, etc., etc.
- Difficult preference point regulation/process change then requiring hunter re-education with its own new complexities and convincing all hunters that it’s fair, equitable and “simple”.
SO, as staff has mentioned/recommended to the commission during all previous preference point discussions, MAYBE WE SHOULD JUST KEEP THE STATUS QUO with its predictability and current hunter understanding of it and hunters knowing how to make best use of the current preference point system. Although the current system has it complexities, the change recommendations each have their own new far-reaching complexities. Simplicity is an overriding objective but what we have for the current system might be considered “simple” by thinking of it in terms of the fact that it is something that hunters already understand and know how to make the best use of it.

THANKS so very kindly for your time and hopefully serious consideration of my Draw Process Preference Point comments!

After watching the first 2 meetings in their entirety I can honestly say that I feel you folks are SEVERLY missing the mark with the preference points and the issues of addressing point creep.

To reduce point creep, you CANNOT let people get an A-list tag and still build points.

Unless I missed something it appears that the proposed changes are not going to do much at this point to curb point creep. You didn't even suggest requiring the usage of preference points on the secondary draw, which I feel is absolutely ridiculous because a TON of good tags make it on that list that people should be using their points to get.

Please, going forward for the work session # 3 and # 4 talk about how to implement the usage of preference points and how to actually get point creep stopped and force people to burn their points.

Stop "Encouraging" people to use them and FORCE people to use their points if they want an A-list tag. NO MATTER WHEN IT IS DRAWN.

People are getting tags and still building points under the current system you propose. You're all just kicking the can down the road when you can end the problem right here, right now.

People will put in difficult units as choices 1-4, knowing that they will not draw, and build a point, then just pick up a tag off of the secondary draw with 0 repercussions to their existing preference points......how is this really any different than the current system that you have that clearly isn't working?????????

Almost none of what you decided so far makes any sense.

This is NOT a difficult problem to solve. Just being honest.

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