ISSUES SUBMITTAL FORM
Date: 10/9/2019
ISSUE:
Should second and third rifle elk seasons be limited in GMU 83?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
This issue paper proposes converting OTC licenses for second and third rifle seasons to limited draw.
The primary purpose of this proposal is to attempt to address a severe human health and safety issue in
Game Management Unit (GMU) 83. This issue paper does not attempt to change the current population
or sex ratio objectives of E-33. This proposal also does not contemplate making GMU 83 totally limited.
Archery and muzzleloader seasons would remain unaffected.
This problem has roots deeply implanted in the history and culture of this part of Colorado. Therefore, a
significant explanation is needed to understand the full context of the situation. Area 17 personnel,
especially Conrad Albert, have essentially solved the game damage side of this equation. What could
amount to numerous damage claims ranging from a few thousand dollars to over a half-million dollars per
farm each year, has been abated through the efforts of Area 17 DWMs, Game Damage, and HPP. The
solutions implemented by them each year keeps nearly everyone happy with only occasional damage
claims filed. Typically, it is less than one claim per year.
Elk move from large mountain ranches to valley floor alfalfa fields, passing through relatively flat
subdivisions creating a situation where hunters pursue elk via the extensive public road network and
bullets fly across roads, near or through houses, and tensions are high over large areas of the county.
Video footage exists on FB that shows some of the behavior that we describe here. These safety
concerns have existed for decades, including involvement and concern from state senators and
representatives. There is a significantly increased likelihood of injury or property damage now that more
landowners are starting to live on previously empty lots within the subdivisions.
GMU 83 presents a unique challenge for managing elk. Over 99% of the unit is private property. This
ownership ranges from vast private ranches that encompass the entire mountain range on the east side
of the unit, to subdivision tracts made up of thousands of small individually owned lots. Due to the
historical land-grant status of these areas and cultural traditions, communal use of these lands has been
the norm for hundreds of years. Fast forward through changes in ownership by Spain, Mexico, and the
United States, much of the use of the area remains unchanged with the exception of the establishment of
the mountain ranches and numerous large subdivisions. In addition, nearly two thousand miles of county
roads crosshatch across these subdivisions and agricultural lands - most are every square mile. See
attached map.
Elk spend their time on the mountain ranches (Trinchera and Cielo Vista) during spring and summer.
Once snow falls in the high country, these elk herds migrate down to lower elevations creating conflicts in
the subdivisions and the agricultural areas. During the seasons, large numbers of elk are regularly
trapped on the valley floor by a deluge of hunters that can easily access them on the county roads.
When such circumstances exist, it is not unusual for elk to cross dozens of different properties in a short
period. Conditions quickly devolve into an unsportsmanlike, inhumane, and dangerous situation. Some
have suggested that this is a law enforcement problem. Area 17 has ten commissioned officers for
approximately 8,000 square miles. When conditions in GMU 83 are bad, we have assigned up to six Area
17 officers, along with numerous county deputies and several state troopers. Still it is not enough to
mitigate the situation. There are too many elk spread out over too large an area that is easily accessible
to hunters.
Until recently, most subdivision lots have been unoccupied; however, that is changing with numerous
homes and trailers setting up residency upon these lots. Absentee-owned lots are mostly unsigned,
unfenced, or not patrolled. Numerous new residents do not understand the history or existing culture and
do not allow or appreciate hunting on or around their lots.

1

 GMU 83 licenses are unlimited during second and third rifle season and open to OTC hunters. Snow and
forage conditions dictate when elk leave the mountain ranches. Often this migration occurs during the
second or third season. Once the elk are in place and accessible, the word gets out quickly. Uncontrolled
numbers of OTC hunters from other GMUs enter the unit, exacerbating existing problems, which include
trespass and safety violations to take advantage of what they perceive to be an easy hunt. These
problems are at their worst during the rifle seasons when hunters run large numbers of elk across vast
areas of the valley floor through agricultural lands and subdivisions.
In previous attempts to stem some of these problems, an eight-foot wing fence was built to protect the
Sierra Grande School, and we changed all limited licenses within the unit to PLO so as not to encourage
trespass. The fence mostly resolved the school safety problem, while the PLO effort made no difference
whatsoever. Therefore the historical trespass, safety, and fair chase problems continue.
Due to numerous, dangerous incidents and increasing tensions between homeowners, agricultural
landowners, and public hunters, CPW feels it is prudent to limit rifle license numbers during the second
and third rifle seasons. CPW also wishes to maintain the opportunity for the public to be able to
participate in general hunting seasons to manage elk numbers. Over the past several years, we have
found that the reduced number of hunters in the unit due to limitations in first and fourth rifle seasons
result in significantly reduced safety concerns and conflicts. We still need to manage elk, so limiting
second and third seasons will help significantly, but will likely not completely alleviate the problems that
we are currently experiencing.
WHO ARE THE EXTERNAL PUBLICS IMPACTED BY THIS ISSUE? WHAT PUBLIC INPUT
PROCESS HAS OCCURRED, IF ANY?
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
Prior to 2019, Area 17 personnel had several meetings with state senators and representatives, local
homeowners, HOAs, agricultural landowners and local hunting groups (Area 17 officers have
documented multiple complaints and at the Monte Vista Office).
CPW Staff has discussed this at the Area level extensively and has had numerous one-on-one, several
small group and limited large group conversations over the past several years with the stakeholders
mentioned above.
We had conversations with both Sen. Crowder and Rep. Valdez, both of whom have told us they support
limiting these rifle seasons.
The 2019 public involvement effort started prior to the end of 2018 and has continued up to now. Area 17
worked with Jody Kennedy and Mike Quartuch to develop a strategy to involve the public and gather their
input.
The public input effort began with a comment form that we distributed throughout Costilla County to target
full-time county residents from mid-March to mid-June. We held a public meeting in early August to target
part-time county residents and summer visitors. Immediately after the public meeting, we ran an online
survey that ran through Sept. 15, 2019. We publicized the survey via traditional and social media, through
two different press releases and several postings on Facebook.
Throughout the various public input efforts we asked the same three questions:
1. How concerned are you about public safety issues because of the current hunting season in
Costilla County?
2. How much would you support or oppose putting a limit on rifle elk licenses in GMU 83?
3. How much would you support or oppose the use of landowner licenses to help distribute local
hunters across GMU 83?
4. Support data included collecting respondent zip codes to determine local vs non-local status.
The following are graphical representations of the data gleaned from these efforts:

2

  

 

COMMENT FORM TARGETING YEAR-ROUND RESIDENTS (163 respondents)

Concern alaout pulalle safety

 

I Not at all eoneerned I Coneerned I Vent eonee rned

Support for n'fle ell< lleenses

A

 

I Dppose I Nietherfhlor I Support

Support for landowner lleenses

 

I Dppose I Nietherfl?dor I Support

 

 

 

 

PUBLIC MEETING IN FT. GARLAND, CO (69 respondents)

 

Concern about public safety

 

some; -

TDGUE 

 

 

some. - I

some; -

 

some. at

 

 

 

 

zoom; - ,x

-

000% i I I
ot at all Eomewhat Mode ratehr were concerned
concerned Concerned concerned

 

Support for limiting rifle elk licenses



HEDGE

 

SHORE

MINE

 

SHORE

ZUGUE



 

 



 

St ronglv Son'l ewh at Neither Somewhat St ronghr
oppose oppose oppose nor support support
support

 

 

 

 

 

 

Support for landowner licenses

sooner. - I
zsozea 
zoom - I
lsozea 
looses -

5m 

 

 

DENIES

 

Strongly.r 5on1 ewhat Neither Somewhat Stronghr
oppose oppose oppose nor support support
support

 

 

 

STATEWIDE ON-LINE SURVEY (53 respondents)

How concerned are you about public safety issues because of the current

hunting season in Costilla County?

53 resaonses

. Not at all concerned
. Somewhat Concerned

Moderately concerned
. Very concerned

 

 

 

Overall, the safety concerns are strong and readily evident among respondents. There is also
overwhelming support for limiting licenses to address that concern. Another possible tool to address this
issue is using landowner vouchers to distribute hunters over the landscape. Support for this idea is
slightly head of the opposition, but it is the least supported concept of the three questions that we asked.
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. * Preferred Alternative *: Specify that all general season rifle licenses in GMU 83 are limited with
licenses available through the limited draw. General season over-the-counter elk licenses (Hunt
codes EM000U2R and EM000U3R) would not be valid in GMU 83.
2. Status quo
Issue Raised by:
Author of the issue paper

Conrad Albert, Brian Bechaver
modified by Rick Basagoitia

6

 (if different than person raising the
issue):
CC:
Scott Wait, Rick Basagoitia, Brent Frankland
CORY CHICK
APPROVED FOR FURTHER CONSIDERATION BY:
REQUIRES NEW SPACE IN THE BROCHURE?
XYES ☐ N O
ARE ADEQUATE STAFF AND FUNDING RESOURCES AVAILABLE TO
IMPLEMENT?
X YES ☐ N O
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION:
RECOMMENDED FOR CONSENT AGENDA?

7

SW Region Area 17
☐YES X NO

 XMap® 7

Data use subject to license.

Scale 1 : 200,000

TN
0

© DeLorme. XMap® 7.
www.delorme.com

MN (7.9°E)

8

0

1
1

2
2

3

1" = 3.16 mi

3
4

4
5

5

mi
km

Data Zoom 10-0

 ISSUES SUBMITTAL FORM
Date:
10/9/2019
Should the Rabbit Mountain antlerless elk hunt code (EF020L3R) boundary be
expanded to also encompass areas used by the Red Hill elk herd?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
In 2014, a hunt code (EF020L3R) was created in GMU 20 to manage and focus harvest on a newly
established resident (i.e., non-migratory) elk herd at the greater Rabbit Mountain area in Boulder County.
The resident herd developed because Boulder County Parks and Open Space (BCPOS) acquired most of
the land in the area, while prohibiting any type of hunting on the property. This resulted in a refuge
situation for both elk and deer. The elk herd grew large very quickly and caused considerable conflicts in
the area including habitat damage to Rabbit Mountain and surrounding open space; game damage to
corn, hay and alfalfa operations; conflicts with livestock growers; increased vehicle-elk road strikes; and
damage to residential properties. Three years after the hunt code was created, CPW worked with BCPOS
to develop an elk and vegetation plan, which included a public harvest program on BCPOS properties at
Rabbit Mountain. Now in its third year, the program is successfully accomplishing the goals of
redistributing the elk herd, while reducing elk density and conflicts.
ISSUE:

Similar to the formation of the resident elk herd at Rabbit Mountain, a resident herd is also becoming
established in the Red Hill area, southwest of Rabbit Mountain. Also similar, are the factors leading to the
formation of the resident Red Hill elk herd and the conflicts associated with a resident elk herd. BCPOS
and the Department of Commerce are key landowners in the Red Hill area and hunting is not permitted
on those properties. This has resulted in the development of a resident elk herd in the area, which was
historically migratory. In 2018, the resident portion of the Red Hill elk herd was approximately 50 animals.
In 2019, the resident herd has increased to approximately 110 elk, with the total wintering elk herd
numbering over 400 animals. Conflicts, including refuging, game damage, vehicle-elk road strikes,
conflicts with stock growers and residential properties are on the rise. CPW and BCPOS are again
working cooperatively at Red Hill to resolve an elk refuging situation by monitoring elk distribution and
conducting surveys. Based upon GPS elk collar and survey data, we propose expanding the EF-020-L3R subunit boundary to encompass Red Hill and surrounding areas in order to focus hunter harvest to
redistribute elk and reduce elk density to prevent habitat damage and reduce elk conflicts. This hunt
code expansion proposal is the result of CPW working collaboratively with Boulder County and local
stakeholders to monitor the issue and develop impactful solutions.
Expansion of the hunt code would be most effective if hunting and harvest occurs along the first hogback,
west of U.S. 36. However, if hunting occurs too far to the west, it is likely that elk will actually move east
into the refuge area from the hunting pressure and continue to cause issues. Alternative 1 is preferred
because it encompasses the necessary geographic area to address management goals with well-defined
boundaries.

9

 Figure 1. Proposed boundary extension to EF020L3R hunt code, which includes portions Red Hill west of
U.S. 36, bordered by Boulder County Parks and Open Space Trails (Preferred Alternative 1).

10

 WHO ARE THE EXTERNAL PUBLICS IMPACTED BY THIS ISSUE? WHAT PUBLIC INPUT PROCESS
HAS OCCURRED, IF ANY?
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
External publics include BCPOS, surrounding landowners, motorists and hunters.
CPW continues to collaborate regularly with BCPOS and local stakeholders on the issue. CPW and
BCPOS have presented the most recent collar and survey findings to Boulder County’s Commissioner
and the Parks and Open Space Advisory Committee Meetings in May and February 2019.
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. *Preferred Alternative*: Amend the boundary of EF020L3R hunt code to include the Red Hill
area. The area bounded on the N by the Little Thompson River; on the E by U.S. 287; on the S
by Boulder CR 34 (Niwot/Neva Roads), U.S. 36, Boulder CR 94 (Lefthand Canyon Drive); on the
W by Geer Canyon Drive, Boulder County Trail Wapiti, Boulder County Trail Ponderosa Loop
(western loop), Boulder County Trail Wild Turkey, Boulder County Trail Picture Rock, Red Gulch
Road, Boulder CR 84 (Old St. Vrain Road), Colo. 7, U.S. 36, Boulder CR 71N (Blue Mountain
Rd), Larimer Co Rd 37E, Lonestar Rd, then Stagecoach Trail N at the intersection of Lonestar Rd
and Stagecoach Trail (See Figure 1).
2. Status Quo
Issue Raised by:
Ben Kraft and Joe Padia
Author of the issue paper
(if different than person raising the
issue):
CC:
Kristin Cannon, Shannon Schaller, Mark Leslie
APPROVED FOR FURTHER CONSIDERATION BY:
Mark Leslie
REQUIRES NEW SPACE IN THE BROCHURE?
☐YES ☒ N O
ARE ADEQUATE STAFF AND FUNDING RESOURCES
☒YES ☐ N O
AVAILABLE TO IMPLEMENT?
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
Terrestrial and NE Region
RECOMMENDED FOR CONSENT AGENDA?
☐YES☒ N O

11

 ISSUES SUBMITTAL FORM
Date:
10/9/2019
ISSUE:
Should antlered hunt codes EM003O1R and EM003O4R, EM004O4R, and EM005O4R in
DAU E-2 be changed to either-sex hunt codes EE003O1R and EE003O4R, EE004O4R,
and EE005O4R; and should GMU 214 be separated from the EM003O1R hunt code into
a separate GMU-specific EM214O1R hunt code?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
Either-sex licenses are an effective management tool for increasing antlerless harvest. Either-sex
licenses were employed to reduce elk populations in the Bear’s Ears DAU E-2 from 2003 – 2012. Elk
populations in the Bear’s Ears herd were significantly over objective and the either-sex licenses were
extremely effective in helping to achieve antlerless harvest objectives. In fact, from 2003 – 2012,
antlerless harvest on either-sex licenses was 37% and 40% for the 1st and 4th seasons, respectively
(Tables 1 & 2). After reducing the elk population nearly to the long-term objective range, 1st and 4th
season either-sex licenses were eliminated and replaced with antlered-only licenses in 2013.
Table 1. First season antlerless harvest off-take on either-sex (E/S) licenses 2003 – 2012.
1st Season E/S % Cow Harvest
Year

Hunters

2003

1100

Bull
Harvest
295

2004

1111

2005
2006

Cow
Harvest

Total
Harvest

% Cow
Harvest

174

469

37%

418

130

548

24%

1170

347

109

456

24%

1019

326

84

410

20%

2007

1056

355

111

466

24%

2008

1039

240

164

404

41%

2009

975

153

230

383

60%

2010

1082

269

190

459

41%

2011

1074

130

159

289

55%

2012

1072

244

210

454

46%
37%

Avg.

Table 2. Fourth season antlerless harvest off-take on either-sex (E/S) licenses 2003 – 2012.
4th Season E/S % Cow Harvest
Year

Hunters

Bull
Harvest

Cow
Harvest

Total
Harvest

% Cow
Harvest

2003
2004
2005

553

181

124

305

41%

2006

552

148

74

222

33%

2007

793

84

27

111

24%

2008

825

69

22

91

24%

2009

761

62

52

114

46%

2010

840

192

137

329

42%

2011

813

144

115

259

44%

2012

776

91

169

260

65%
40%

12

Avg.

 Since either-sex licenses were stopped in 2013, it has been difficult to maintain this herd within the
population objective range due to the herd’s high fecundity rate and inconsistent annual harvest resulting
from the weather-related migration of this herd. Weather plays a key role as to when elk migrate in the E2 herd and can have a significant effect on harvest. Harvest rates can be highly variable from year-toyear. For example, cow harvest rates from 2003 – 2012, when either-sex licenses were active, averaged
19.8%. This resulted in a negative population growth with the intent of managing the population to
objective. In contrast, cow harvest rates have averaged 14.1% since 2013, after the sunset of 1st and 4th
season either-sex licenses. The average difference of a 6% lower cow harvest rate, highly variable
annual harvest due to weather conditions, and high fecundity rate has resulted in the E-2 herd remaining
steadily above the desired population objective range. The long-term population objective range for the
Bears Ears elk herd is 15,000-18,000 elk. The 2018 post-hunt population estimate for the herd was
approximately 24,000 elk.

Figure 1. Cow harvest segment rate vs. elk population trend 1999 – 2018.
Based on past management experience with the Bear’s Ears elk herd, staff recommends the
reinstatement of either-sex hunt codes for the 1st and 4th rifle seasons in most of the GMUs within DAU E2 (GMUs 3, 4, 5, 301, 441). Either-sex licenses proved to be one of the most effective tools for managing
this population to and maintaining it within the long-term population objective range.
However, GMUs on the eastern end of the DAU are showing reduced calf production compared to the
rest of the DAU and there is desire to manage antlerless harvest more closely in those areas while
increasing antlerless harvest in the remainder of the DAU. For this reason, staff proposes removing GMU
214 from the multi-GMU EM003O1R hunt code and creating a GMU-specific 1st season antlered-only
hunt code for GMU 214 (EM214O1R).
STATE LAW REQUIRES CPW TO SOLICIT INPUT FROM STAKEHOLDERS THAT MAY BE
AFFECTED POSITIVELY OR NEGATIVELY BY THE PROPOSED RULES. THE FOLLOWING
STAKEHOLDERS HAVE BEEN ADVISED OF AND INVITED TO PROVIDE INPUT ON THE
REGULATORY CHANGES PROPOSED IN THIS ISSUE PAPER:
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.

13

 There has not been public outreach conducted regarding this issue. However, license demand for eithersex licenses suggests there would not be opposition to changing antlered-only licenses to either-sex
licenses.
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. *Preferred Alternative*: Create hunt codes EE003O1R, EE003O4R, EE004O4R, and
EE005O4R to replace existing hunt codes EM003O1R, EM003O4R, EM004O4R, and
EM005O4R. Also, remove GMU 214 from the EM003O1R hunt code and create a GMU 214specific first season hunt code (EM214O1R).
2. Status quo with no change to current hunt codes EM003O1R, EM003O4R, EM004O4R, and
EM005O4R.
Issue Raised by:
Author of the issue paper
(if different than person raising the
issue):
CC:

Area 6 Terrestrial Biologist Darby Finley
Revised by Brad Petch

NW Senior Biologist Brad Petch, A6 AWM Bill deVergie,
A6 AAWM Mike Swaro, A10 AWM Kris Middledorf, A10
AAWM Josh Dilley, A10 Terrestrial Biologist Jeff Yost,
affected A6 and A10 DWMs
APPROVED FOR FURTHER CONSIDERATION BY:
ROMATZKE
REQUIRES NEW SPACE IN THE BROCHURE?
☐YES ☒ N O
ARE ADEQUATE STAFF AND FUNDING RESOURCES
☒YES ☐ N O
AVAILABLE TO IMPLEMENT?
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
Terrestrial
RECOMMENDED FOR CONSENT AGENDA?
☐YES ☒ N O

14

 ISSUES SUBMITTAL FORM
Date:
10/9/2019
ISSUE:
Should GMU 591 (Ft. Carson) be added to the list of antler-point restricted units in W254.A?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
GMU 591 (Ft. Carson) is currently the only Game Management Unit (GMU) west of I-25 that does not
have an antler-point restriction but is over-the-counter for either-sex elk archery licenses and the 2nd & 3rd
season bull elk rifle licenses. In antler-point restricted units, hunters are required to harvest bull elk with
four (4) or more points or a brow tine on one antler. The purpose of the antler-point restriction is to
prevent too many bull elk from being harvested in over-the-counter units since there are few other ways
to restrict harvest in these units. The antler-point restriction limits the harvest of yearling (spike) bulls,
which allows this age-class to reach maturity before they can be harvested.
Currently, bull elk hunters on Ft. Carson can take any bull elk with antlers that are at least 5 inches in
length, including yearling spike bulls. GMU 591 was excluded from the antler-point restriction to provide
military personnel with maximum opportunity to harvest bull elk on the military installation, since, due to
training and deployment schedules, they have limited time to scout and hunt.
During the 2018 rifle season, a long-time Ft. Carson hunter asked Colorado Parks and Wildlife to
consider making Ft. Carson a 4-point antler restricted unit, bringing the issue to our attention. The hunter
was concerned about the harvest of yearling bulls and thought converting the unit to an antler-point
restriction would improve the quality of bulls on Ft. Carson. Following that discussion, we reached out to
several interest groups, including natural resources and conservation law enforcement staff on Ft.
Carson, as well as Ft Carson hunters. The majority of stakeholders supported the conversion of GMU 591
to an antler-point restrict unit, and several people commented that they would welcome this change (see
below).
We anticipate little impact from this proposed change. At least 90% of the bulls harvested on Ft. Carson
between 2015-2018 had 4 or more points, and thus would be legal under the new rule (source: Ft. Carson
Natural Resources & CPW harvest statistics). Notifying hunters of the change would be facilitated through
the use of the iSportsmen system, since hunters are required to check in to this system before accessing
the installation. This change would also simplify Colorado Parks and Wildlife regulations since it would
bring elk antler-point regulations on Ft. Carson in line with all other over-the-counter elk units west of I-25
in Colorado.
STATE LAW REQUIRES CPW TO SOLICIT INPUT FROM STAKEHOLDERS THAT MAY BE
AFFECTED POSITIVELY OR NEGATIVELY BY THE PROPOSED RULES. THE FOLLOWING
STAKEHOLDERS HAVE BEEN ADVISED OF AND INVITED TO PROVIDE INPUT ON THE
REGULATORY CHANGES PROPOSED IN THIS ISSUE PAPER:
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
Internal parties include: SE Region Biologists, Customer Service Representatives, District Wildlife
Managers, Assistance Area Wildlife Managers, and Area Wildlife Managers. This issue was discussed
internally before we reached out to external partners.
External parties include: Ft. Carson staff.
We discussed this change with Ft. Carson staff at the 2018 annual INRMP (Integrated Natural Resources
Management Plan) meeting. Ft. Carson natural resource staff, conservation law enforcement personnel,
and base representatives attended that meeting. Ft. Carson natural resources staff were in favor of the
change. Additionally, we addressed this issue at a meeting specifically with Conservation Law
Enforcement personnel. Conservation Law Enforcement personnel were concerned about the lost hunting
opportunity for soldiers that could occur if this change was enacted.

15

 Ft. Carson hunters: We informed Ft. Carson hunters through an email that was sent to over 1,000
individuals. Ft. Carson Natural Resources staff who generated the list of hunters through the iSportsmen
system sent the email. The email also included a letter from CPW that outlined the proposed change and
invited individuals to contact Julie Stiver with questions or concerns about the change. We received 7
emails in support of the change and 3 emails against the change. Those in support of the change believe
it will lead to better quality bulls on the military installation and several commented that it was a long
overdue change. Comments against the change included: reduced opportunity, already limited harvest
(due to restrictions on the military installation & adjacent private property), and change is unnecessary
because the system is not currently broken.
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. *Preferred Alternative*: Add GMU 591 to the list of antler-point restricted units in W-254.A.
2. Status quo
Issue Raised by:
Author of the issue paper
(if different than person raising the
issue):
CC:

Julie Stiver, Wildlife Biologist, Colorado Springs
Same

Brett Ackerman, Brian Dreher, Frank McGee, Cassidy
English, Cody Wigner, Mike Trujillo, Jamin Grigg, Jim
Aargon
BRETT ACKERMAN
APPROVED FOR FURTHER CONSIDERATION BY:
X☐YES ☐ N O
REQUIRES NEW SPACE IN THE BROCHURE?
ARE ADEQUATE STAFF AND FUNDING RESOURCES
X☐YES ☐ N O
AVAILABLE TO IMPLEMENT?
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
Terrestrial
RECOMMENDED FOR CONSENT AGENDA?
☐YES X☐ N O

16

 ISSUES SUBMITTAL FORM
Date:
10/9/2019
ISSUE:
Should GMUs 59 and 581 be separated in the EF059P5R hunt code and should we
eliminate the EE059P1R and EE511P1R hunt codes in data analysis unit (DAU) E-23?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
While the E-23 (Elevenmile Elk Herd) population remains above the population objective of 2,700-3,300
(2018 post-hunt estimate = 4,000), many local hunters, landowners and outfitters have complained about
what they perceive to be a drastic reduction in the elk population within GMU 59 in recent years. These
constituents are concerned that the extended private-land-only (PLO) season that is combined with GMU
581, may be the cause of the perceived decline that they have observed. In an effort to address their
concerns, Area 13 and Area 14 staff recommend separating the currently combined GMUs 59/581 PLO
antlerless hunt code into two separate hunt codes to allow staff to continue high levels of PLO cow
harvest in GMU 581, while reducing PLO cow harvest in GMU 59. Staff also recommends eliminating
hunt codes EE059P1R (35 licenses; 2018 1st choice applicants = 28) and EE511P1R (10 licenses; 2018
1st choice applicants = 5), which are considered to no longer be desirable or necessary. Staff will examine
adding this quota to the existing first season quotas in both these GMUs.

17

 STATE LAW REQUIRES CPW TO SOLICIT INPUT FROM STAKEHOLDERS THAT MAY BE
AFFECTED POSITIVELY OR NEGATIVELY BY THE PROPOSED RULES. THE FOLLOWING
STAKEHOLDERS HAVE BEEN ADVISED OF AND INVITED TO PROVIDE INPUT ON THE
REGULATORY CHANGES PROPOSED IN THIS ISSUE PAPER:
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
E23 elk hunters, landowners, and outfitters
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. *Preferred Alternative*: Create hunt code EF581P5R (valid for GMU 581), while making existing
hunt code EF059P5R valid only for GMU 59.
Eliminate hunt codes EE059P1R and EE511P1R.
2. Status quo
Issue Raised by:
Area 13 and Area 14 staff
Author of the issue paper
Jamin Grigg, Wildlife Bio, Area 13
(if different than person raising the
issue):
CC:
BRETT ACKERMAN
APPROVED FOR FURTHER CONSIDERATION BY:
X☐YES ☐ N O
REQUIRES NEW SPACE IN THE BROCHURE?
ARE ADEQUATE STAFF AND FUNDING RESOURCES
X☐YES ☐ N O
AVAILABLE TO IMPLEMENT?
SE Terrestrial
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
RECOMMENDED FOR CONSENT AGENDA?
☐YES X☐ N O

18

 ISSUES SUBMITTAL FORM
Date:
10/9/2019
Should additional archery, muzzleloader and rifle hunt codes for antlerless moose be
created east of the Peak-to-Peak Highway in GMU 38?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
Moose harvest in GMU 38 occurs entirely west of the Peak-to-Peak Highway. This is because more
moose and public land open to hunting are found west of the highway, while much of land east of the
highway is private, parks and open space. However, moose occur east of the Peak-to-Peak Highway and
sometimes these moose move into populated areas and create issues in unincorporated subdivisions and
in the Denver and Golden metro areas. The majority of harvest opportunity east of the Peak-to-Peak
Highway is on private land, with several small public land parcels available. A notation in the brochure,
similar to language currently in use, will be made to notify hunters that landowner permission is advisable
and most land for this hunt code is private.
ISSUE:

New antlerless hunt codes, which restrict antlerless moose hunting to the area east of the Peak-to-Peak
Highway (Figure 1), will focus moose hunting, increase moose hunting opportunity, and increase moose
harvest in eastern portions of the GMU. This may also reduce moose conflicts in eastern and metro
areas of the GMU. The new hunt codes would be separate standard archery, muzzleloader or rifle
seasons, but with the option of moving the rifle season to run concurrent with the regular rifle deer and elk
rifle seasons (with no hunting during the breaks between the seasons), when necessary to meet
management objectives.
Figure 1. Proposed boundary for new additional antlerless moose hunt codes in GMU 38, represented by
the green polygon.

19

 WHO ARE THE EXTERNAL PUBLICS IMPACTED BY THIS ISSUE? WHAT PUBLIC INPUT PROCESS
HAS OCCURRED, IF ANY?
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. *Preferred Alternative*: Create new antlerless moose hunt codes in GMU 38, which would only
be valid east of the Peak-to-Peak Highway. Create hunt codes for the standard archery,
muzzleloader and rifle seasons, but with the option of moving the rifle season to run concurrent
with the regular deer and elk seasons (with no hunting during the breaks between the seasons).
Create a hunt area within GMU 38 bounded on the west by US Highway 6/Colorado 119 and
Colorado Highway 119.
2. Status quo
Issue Raised by:
Ben Kraft, Tim Woodward, and Joe Walter
Author of the issue paper
(if different than person raising the
issue):
CC:
Mark Lamb, Shannon Schaller, and Mark Leslie
APPROVED FOR FURTHER CONSIDERATION BY:
Mark Leslie
REQUIRES NEW SPACE IN THE BROCHURE?
☒YES ☐ N O
ARE ADEQUATE STAFF AND FUNDING RESOURCES
☒YES ☐ N O
AVAILABLE TO IMPLEMENT?
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
RECOMMENDED FOR CONSENT AGENDA?
☐YES ☒ N O

20

 ISSUES SUBMITTAL FORM
Date:
10/9/2019
ISSUE:
Should GMU 361 be separated from GMU 36 for antlered moose hunting and should
new GMU 361-specific antlered and antlerless moose and GMU 36-specific antlerless
hunts be created?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
Following reintroduction efforts in 1978, moose populations in the mountains of Colorado have increased
to an estimated 3,000 statewide. As with most pioneering ungulate populations, moose in Colorado
continue to expand and occupy additional habitat.
The M-3 (Middle Park) moose herd is no exception to this expansion, with moose now occupying the full
suite of diverse habitat types available to them in Grand, Summit and the northern portion of Eagle
Counties. Bulls, cows, and calves are frequently observed throughout the DAU (which includes GMUs 15,
18, 27, 28, 36, 37, 181, 361, and 371). GMUs 36 and 361, situated primarily in the Radium Basin area
and the western side of the Gore Range, were the last portions of the DAU to become populated with
moose. GMU 361 and the northern portion of GMU 36 are comprised of conifer and aspen forests with
prolific willow and riparian galleries draining the ridge into the Piney River (GMU 36) and Colorado River
(GMU 361) basins. The divide between GMUs 36 and 361 is Piney Ridge, a prominent terrain feature.
Road access into the heart of GMU 361 is very good, but hunters still have the opportunity to get away
from road networks if they desire to hunt remote terrain. The southern portion of GMU 36 lies directly to
the north of Interstate-70, Gore Creek, and Eagle River. Moose sightings, roadkills, and other conflicts
with humans have been on the rise along the I-70 corridor, especially around the town of Vail.
Currently the M-M-036-O1-A, M-M-036-O1-M and M-M-036-O1-R hunt codes include both GMUs 36 and
361. In 2019, under the current hunt code structure three antlered bull moose licenses will be issued to
hunters. To date, all of the harvest from these hunt codes has been derived from GMU 36. This dynamic
occurs as a result of easy access and proximity to moose in GMU 36. Under the current hunt codes,
officers and biologists see a repeated pattern of hunters choosing to hunt moose in the Piney River
drainage (i.e., GMU 36) where harvest statistics show previous harvest, and spending little to no effort
scouting and hunting GMU 361. As a result of this trend in harvest distribution, GMU 361 has been left as
an untapped gem for moose hunting. All age and sex classes (e.g., bulls, cows, yearlings, and calves) are
seen on public land in GMU 361 during the summer, archery season and into the regular big game rifle
seasons. Public land deer and elk hunters report frequent sightings of moose in GMU 361, often seeing
moose more frequently than elk. Despite the frequency of quality moose sightings, no bull moose have
been harvested in GMU 361.
Currently there are no female moose hunt codes for GMUs 36 and 361, but in recent years, moose
numbers appear to be increasing based on the frequency of sightings in both GMU 36 and 361 and also
an increase in roadkills and moose-human conflicts along I-70 in GMU 36. Moose-human conflicts in
these GMUs have not reached the same magnitude as in the more densely moose-populated portions of
M-3 (e.g., Breckenridge, Grand Lake), but in order to proactively manage this growing portion of the
moose population, there is both a need and an opportunity to open GMUs 36 and 361 to antlerless
moose hunting.
Separating GMU 361 from the existing GMU 36 hunt codes would encourage hunters to tap into another
segment of Colorado’s moose population in a hunt with a backcountry feel. In addition, creating separate
hunt codes would allow for the creation of GMU 361-specific antlered and antlerless moose licenses. This
will allow for an increase in the number of these highly desirable bull and cow licenses available to the
public and could present another opportunity for a hunter to harvest a once- in-a-lifetime Colorado bull
moose.
Creation of GMU 361-specific hunt codes (both male and female) and the addition of antlerless moose
hunt codes for GMU 36 would increase hunter opportunity in these units where both cow moose and
quality bull moose are regularly observed.

21

 STATE LAW REQUIRES CPW TO SOLICIT INPUT FROM STAKEHOLDERS THAT MAY BE
AFFECTED POSITIVELY OR NEGATIVELY BY THE PROPOSED RULES. THE FOLLOWING
STAKEHOLDERS HAVE BEEN ADVISED OF AND INVITED TO PROVIDE INPUT ON THE
REGULATORY CHANGES PROPOSED IN THIS ISSUE PAPER:
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
M-3 Resident and Non-Resident Moose Hunters
No formal requests for public input have occurred at this time. However, CPW staff has had regular
communication with moose license holders in GMU 36 to encourage hunting in GMU 361.
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. *Preferred Alternatives*: Separate GMU 361 from GMU 36 for antlered moose hunting. Open
both GMU 36 and 361 for antlerless moose hunting by creating GMU-specific hunts.
2. Status quo
Issue Raised by:
Author of the issue paper
(if different than person raising the
issue):
CC:

Rachel Sralla (DWM), Bryan Lamont(Terrestrial Biologist),
Julie Mao (Terrestrial Biologist), Devin Duval (DWM-Vail)
Revised by Brad Petch

Area 8 and 9, Brad Petch (Senior Wildlife Biologist)
JT Romatzke (Northwest Region Manager)
APPROVED FOR FURTHER CONSIDERATION BY:
ROMATZKE
REQUIRES NEW SPACE IN THE BROCHURE?
☒YES ☐ N O
ARE ADEQUATE STAFF AND FUNDING RESOURCES
☒YES ☐ N O
AVAILABLE TO IMPLEMENT?
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
Terrestrial
RECOMMENDED FOR CONSENT AGENDA?
☐YES ☒ N O

22

 ISSUES SUBMITTAL FORM
Date: 10/9/2019
ISSUE:
Should the moose license in GMU 65 be either-sex?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
The Cimarron Moose Herd (DAU M-4) has significantly grown and expanded since 2013, but is still a
small, low-density population that utilizes multiple GMUs. In 2013, moose were common in the upper
Cimarron drainages. By 2019, moose can be found across the majority of GMU 65 at times and are
expanding into GMU 70 to the west. The moose are starting to utilize private land much more often.
Moose vs. vehicle collisions and public concern have become more common as well. In 2015, a bull
moose license was made available in GMU 65 (MM065O1R). Efforts to survey the moose population
in GMU 65 have shown increased numbers of moose, and increased use of private land. The moose
hunters in 2015, 2016, 2017, and 2018 have all seen plenty of cow moose, but due to bull moose
rutting behavior, bulls can be difficult to find in the unit during the rifle season. The moose habitat is
limited in GMU 65, which increases the threat of losing that habitat to over use by moose. With the low
odds of drawing a moose license, we would like to give the moose hunters in GMU 65 an opportunity to
harvest a either cow or bull moose if the opportunity is there. The licensed moose hunters in GMU 65,
as well as other public input, have told us that an either-sex license would be beneficial for the
opportunity to harvest. Although the population is growing and expanding its range, the herd is not to
the point where we feel it would be beneficial to have increased harvest each year by means of more
licenses.
WHO ARE THE EXTERNAL PUBLICS IMPACTED BY THIS ISSUE? WHAT PUBLIC INPUT
PROCESS HAS OCCURRED, IF ANY?
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
Moose hunters in GMU 65 will be affected by this change. Previous GMU 65 moose license holders
have been consulted as well as hunters that are interested in hunting in this unit and private
landholders in GMU 65. All members of the public that have provided input prefer the extra opportunity
to harvest a moose.
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. * Preferred Alternative *: Create an either-sex hunt code for moose in GMU 65.
2. Status quo
Issue Raised by:
Matt Ortega, Brad Banulis
Author of the issue paper
(if different than person raising the
issue):
CC:
Scott Wait, Renzo DelPiccolo, Kelly Crane
CORY CHICK
APPROVED FOR FURTHER CONSIDERATION BY:
REQUIRES NEW SPACE IN THE BROCHURE?
☐YES ☒ N O
ARE ADEQUATE STAFF AND FUNDING RESOURCES AVAILABLE TO
IMPLEMENT?
☒YES ☐ N O
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION:
RECOMMENDED FOR CONSENT AGENDA?

23

Terrestrial
YES X NO

 ISSUES SUBMITTAL FORM
Date:
10/9/2019
ISSUE:
Should an archery season for rams be added to S-66?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
Rocky Mountain bighorn sheep Data Analysis Unit (DAU) RBS-12 consists of Game Management Units
(GMUs) S-11 (Collegiate North), S-17 (Collegiate South), S-66 (Mt Elbert), and S-76 (Holy Cross). The
DAU is 1,317 mi2 and includes portions of Chaffee, Eagle, Gunnison, Lake, and Pitkin counties. The RBS12 sheep herd is indigenous, meeting the criteria for Tier 1 designation. The 2018 post-hunt population
estimate for RBS-12 is approximately 375 animals.
Rifle licenses in S-66 have numbered 6 since 2010 and success rates have been 52% during that timeperiod. Hunter reports indicate abundant numbers of rams within the GMU (reports from fall 2018
estimated a minimum of 60 ewes, 30 lambs and 30 legal rams within the GMU). Given that the
population in S-66 is doing well, Area 13 staff believe that additional opportunity could be added in the
form of an archery ram season in 2020.

STATE LAW REQUIRES CPW TO SOLICIT INPUT FROM STAKEHOLDERS THAT MAY BE
AFFECTED POSITIVELY OR NEGATIVELY BY THE PROPOSED RULES. THE FOLLOWING

24

 STAKEHOLDERS HAVE BEEN ADVISED OF AND INVITED TO PROVIDE INPUT ON THE
REGULATORY CHANGES PROPOSED IN THIS ISSUE PAPER:
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
Sheep hunters, outfitters and wildlife watchers. Discussion with Rocky Mountain Bighorn Society and
local outfitters.
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. *Preferred Alternative*: Add an archery ram season (SMS66O1A) to S-66 with the season
starting the first Saturday in August and lasting 25 days.
2. Status quo
Issue Raised by:
Area 13 staff
Author of the issue paper
Jamin Grigg, Wildlife Bio, Area 13
(if different than person raising the
issue):
CC:
BRETT ACKERMAN
APPROVED FOR FURTHER CONSIDERATION BY:
X☐YES ☐ N O
REQUIRES NEW SPACE IN THE BROCHURE?
ARE ADEQUATE STAFF AND FUNDING RESOURCES
X☐YES ☐ N O
AVAILABLE TO IMPLEMENT?
SE Terrestrial
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
RECOMMENDED FOR CONSENT AGENDA?
☐YES X☐ N O

25

 ISSUES SUBMITTAL FORM
Date:
10/9/2019
ISSUE:
Should the ewe bighorn sheep season in S-35 be eliminated?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
Following the fall bighorn sheep season in 2017, hunters approached CPW staff with their concern over
the lack of bighorn sheep observed in S-35. This concern was over both the lack of rams within the unit
and also the lack of lambs observed with the small number of ewes that they observed during their hunts.
In response to their concern, CPW reduced the number of ram licenses for archery and rifle in the winter
of 2018. In addition, CPW staff performed a helicopter survey of the unit. Results of the survey found
fewer sheep than expected, but it is important to note that this unit has very complex habitat, with cliff
bands among heavy stands of timber. Given the concern over the number of sheep in the unit, we
propose the elimination of the ewe season in S-35. We will continue to survey the unit and re-evaluate the
possible addition of a ewe season in the future.
STATE LAW REQUIRES CPW TO SOLICIT INPUT FROM STAKEHOLDERS THAT MAY BE
AFFECTED POSITIVELY OR NEGATIVELY BY THE PROPOSED RULES. THE FOLLOWING
STAKEHOLDERS HAVE BEEN ADVISED OF AND INVITED TO PROVIDE INPUT ON THE
REGULATORY CHANGES PROPOSED IN THIS ISSUE PAPER:
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
S-35 hunters, wildlife watchers and outfitters
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. *Preferred Alternative*: Eliminate the SFS35O1R season and hunt code.
2. Status quo
Issue Raised by:
Area 11 staff
Author of the issue paper
Allen Vitt
(if different than person raising the
issue):
CC:
APPROVED FOR FURTHER CONSIDERATION BY:
REQUIRES NEW SPACE IN THE BROCHURE?
ARE ADEQUATE STAFF AND FUNDING RESOURCES
AVAILABLE TO IMPLEMENT?
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
RECOMMENDED FOR CONSENT AGENDA?

26

BRETT ACKERMAN
☐YES X☐ N O
X☐YES ☐ N O
SE Terrestrial
☐YES X☐ N O

 ISSUES SUBMITTAL FORM
Date:

10/9/2019

ISSUE:

Should there be two ram seasons in S-15, and should the dates of the ewe season in
S15 be changed to accommodate the two ram seasons?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
Ram Seasons:
The bighorn population in S-15 has been increasing over the past several years, which includes the
number of mature rams. This allows for more hunting opportunity in the unit. The issue with taking
advantage of this opportunity and increasing ram licenses is that it puts too many ram hunters in the
unit and the quality of the hunt drastically decreases. It often takes ram hunters 15 or more years to
draw a license to hunt these highly sought-after animals. Being able to hunt them with minimal
interference from other bighorn sheep hunters is an important aspect to the limited, high-demand hunt.
To circumvent this issue and increase licenses while still maintaining a quality hunt, we propose
creating two ram seasons. Licenses would be distributed in the two seasons while still maintaining
hunter numbers in each season at a level that provides a quality hunt. The seasons would be set up to
allow each season a two-week period without any overlap and then a two-week period of overlap. This
would allow the maximum number of days for hunters.
The first season would be a split season. The first split would start on the Saturday one week before
Labor Day weekend (recommended by local outfitters) and would run 12 days, ending on a
Wednesday. The second split would begin the third Saturday after Labor Day and run 16 days, ending
on Sunday.
The second season would start the Saturday after Labor Day and run 30 days, ending on Sunday.
This would provide approximately two weeks of hunting for each season without overlap and still
ensure each season lasts approximately four weeks (recommended by RMBS). The last two weeks of
both seasons would overlap and the seasons would conclude on the same day. Considering both
seasons, ram hunting would occur one week before and one week after the opening and closing of the
current season.
The 2020 dates would be:
•

First season: Aug 29 to Sept 9 and Sept 26 to Oct 4

•

Second season: Sept 12 to Oct 11

The 2021 dates would be:
•

First season: Aug 28 to Sept 8 and Sept 25 to Oct 10

•

Second season: Sept 11 to Oct 10

Ewe Seasons:
A ewe season was created in S-15 in 2010 and the season dates were made to allow ram hunters an
opportunity to hunt prior to ewe hunters entering the field. This was made to provide ram hunters a high
quality hunt prior to adding more hunters into the field with the ewe licenses. The above ram season

27

 proposal calls for each ram season to have an approximate two-week season independently and then
16 days combined. The overlap in the two ram seasons would start the third Saturday after Labor Day.
We propose having the ewe season start the third Saturday after Labor Day, the same time as the ram
season overlap, and run for 16 days. This would allow each of the two ram seasons to have days in
the field without overlap with other bighorn seasons in the same unit and still provide ewe hunters a
quality hunt. Many of the ram hunters will be finished hunting by the time ewe season opens,
minimizing the number of hunters in the unit at any given time. This is an important consideration for
S-15 bighorn hunters as well as archery hunters.
STATE LAW REQUIRES CPW TO SOLICIT INPUT FROM STAKEHOLDERS THAT MAY BE
AFFECTED POSITIVELY OR NEGATIVELY BY THE PROPOSED RULES. THE FOLLOWING
STAKEHOLDERS HAVE BEEN ADVISED OF AND INVITED TO PROVIDE INPUT ON THE
REGULATORY CHANGES PROPOSED IN THIS ISSUE PAPER:
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
Internal: DWMs, AWMs, ATWBs
External: Terry Myers, Rocky Mountain Bighorn Society – supported the idea and recommended
keeping seasons four weeks if possible. Local guides/outfitters including Ash Tully and Mike Ray were
supportive of the idea and recommended starting the first season the week prior to Labor Day.
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. *Preferred Alternative*: Two ram seasons that run for two weeks independently and then
finish with a two-week overlap. Adopt the ewe season dates as proposed.
2. Two three-week ram seasons that have no overlap.
3. Status quo: One ram season.
Issue Raised by:
Author of the issue paper
(if different than person raising the
issue):
CC:

Brad Weinmeister ATWB and Doug Purcell DWM

Scott Wait SW Senior Ter Bio, Matt Thorpe AWM A15

APPROVED FOR FURTHER CONSIDERATION BY:
REQUIRES NEW SPACE IN THE BROCHURE?
ARE ADEQUATE STAFF AND FUNDING RESOURCES
AVAILABLE TO IMPLEMENT?
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
RECOMMENDED FOR CONSENT AGENDA?

28

Cory Chick
YES

NO

YES

NO

Field Ops/Terrestrial
YES
NO

 ISSUES SUBMITTAL FORM
Date:
10/9/2019
ISSUE:
Should a second season archery hunt code be added for bighorn sheep in GMU S-69
(SMS69O2A)?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
The bighorn sheep herd of S-69 (Cochetopa Canyon – Gunnison Basin) is currently marked by high
reproductive performance and has the ability to provide greater opportunity for ram harvest in the near
future. However, the unit has a relatively small land area and already has two other ram seasons
(SMS69O1R and SMS69O1A) and two ewe seasons (SFS69O1R and SFS69O2R). With the growing
population, the harvest quota will need to be increased in coming years. It is common for hunters and
staff to find rams during these primary seasons grouped into a single large bachelor group of ~30 rams,
containing most of the rams in the S-69 herd. Adding tags to the current seasons will potentially cause
high hunter crowding and conflicts among hunters seeking a single group of rams. However, it appears
that the large bachelor group breaks up in the fall prior to the rut, but after the current archery and rifle
seasons. Implementing another season, later in the fall, once this ram group has dispersed into smaller
sub-groups, is anticipated to provide a hunt opportunity in which multiple licenses could be authorized
without hunters being too crowded. If this hunt code achieves its purpose into the future, staff will
consider changing the method of take for this season to rifle with a new issue paper. Start and end dates
for this new season (SMS69O2A) would run from October 15 – November 15. Other bighorn sheep hunt
codes in the Gunnison Basin have the potential to be modeled after this “late” archery hunt code if it
proves useful.
STATE LAW REQUIRES CPW TO SOLICIT INPUT FROM STAKEHOLDERS THAT MAY BE
AFFECTED POSITIVELY OR NEGATIVELY BY THE PROPOSED RULES. THE FOLLOWING
STAKEHOLDERS HAVE BEEN ADVISED OF AND INVITED TO PROVIDE INPUT ON THE
REGULATORY CHANGES PROPOSED IN THIS ISSUE PAPER:
*IT IS ASSUMED THAT ALL NECESSARTY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
A public meeting was held in Gunnison on August 14th 2019 to present this and other issue papers. No
comment was received.
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. *Preferred Alternative*: Add hunt code SMS69O2A.
2. Status quo
Issue Raised by:
Author of the issue paper
(if different than person raising the
issue):
CC:

Kevin Blecha

J Wenum, Scott Wait, Cory Chick, Craig McLaughlin, Nick
Gallowich
Cory Chick
APPROVED FOR FURTHER CONSIDERATION BY:
REQUIRES NEW SPACE IN THE BROCHURE?
X YES NO
ARE ADEQUATE STAFF AND FUNDING RESOURCES
☒YES ☐ N O
AVAILABLE TO IMPLEMENT?
Terrestrial
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
RECOMMENDED FOR CONSENT AGENDA?
YES X NO

29

 ISSUES SUBMITTAL FORM
Date:
10/9/2019
ISSUE:
Should a ram rifle hunt code be added for bighorn sheep GMU S-70 (SMS70O1R) and
the current archery hunt code for S-70 be removed?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
The bighorn sheep herd of S-70 (Fossil Ridge) has been recovering since a disease related die-off in the
winter of 2007-2008. Observations by CPW staff and public are indicating that this herd has not fully
recovered, but larger groups comprised of all-age classes of rams are being consistently documented.
While, the source of these rams are not exactly known, it is believed to be a combination of native
production within Data Analysis Unit (DAU) RBS-23 (S-26 and S-70 combined) and dispersal from
neighboring herds. Two years ago, a combined-unit hunt code was established to allow archery hunters
to hunt in either S-70 or the neighboring herd of S-26 (Taylor Canyon). However, the difficulty in
accessing S-70, compared to S-26, has led to little hunting effort in the S-70 portion. In order to help
provide much desired bighorn sheep hunting opportunity to hunters, and to better distribute hunters
throughout DAU RBS-23, this issue paper opens a bighorn ram rifle-only season (SMS70O1R) in S-70
concurrent with other local rifle bighorn ram seasons (e.g., Sep 3 – Oct 6). The current archery hunt code
(SMS26O1A) would be deactivated for S-70, but still apply for S-26 using its normal end and start times.
STATE LAW REQUIRES CPW TO SOLICIT INPUT FROM STAKEHOLDERS THAT MAY BE
AFFECTED POSITIVELY OR NEGATIVELY BY THE PROPOSED RULES. THE FOLLOWING
STAKEHOLDERS HAVE BEEN ADVISED OF AND INVITED TO PROVIDE INPUT ON THE
REGULATORY CHANGES PROPOSED IN THIS ISSUE PAPER:
*IT IS ASSUMED THAT ALL NECESSARTY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
A public meeting was held in Gunnison on August 14th 2019 to present this and other issue papers. No
comments were received.
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. *Preferred Alternative*: Add ram hunt code SMS70O1R and restrict SMS26O1A to apply only to
GMU S-26.
2. Status quo
Issue Raised by:
Author of the issue paper
(if different than person raising the
issue):
CC:

Kevin Blecha

J Wenum, Scott Wait, Cory Chick, Craig McLaughlin, Nick
Gallowich, Chris Parmeter.
Cory Chick
APPROVED FOR FURTHER CONSIDERATION BY:
REQUIRES NEW SPACE IN THE BROCHURE?
X YES NO
ARE ADEQUATE STAFF AND FUNDING RESOURCES
☒YES ☐ N O
AVAILABLE TO IMPLEMENT?
Terrestrial
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
RECOMMENDED FOR CONSENT AGENDA?
YES X NO

30

 ISSUES SUBMITTAL FORM
Date:
10/9/2019
ISSUE:
Should CPW offer mountain goat female-only licenses for all seasons in G-10 (Tenmile
Range)?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
Some introduced populations of mountain goats have increased rapidly approximating the irruptive
patterns typical of ungulates introduced into new habitats (Caughley 1970; Festa-Bianchet and Cote
2008). These rapid increases in population size have caused concerns among managers about mountain
goat populations exceeding carrying capacity, overuse of habitat, increased competition with bighorn
sheep (Hobbs et al. 1990, Gross 2001), and potential conflicts with recreationists. Compared to goat
populations on native ranges that can support only conservative harvest rates of < 4% (Festa-Bianchet
and Cote 2008), harvest rates of 7% to >15% have been required to slow and reverse population growth
in some CO herds (e.g., DAU G7; CPW unpublished data) and other introduced herds (Adams and Bailey
1982, Houston and Stevens 1988, Williams 1999). Consequently, managing introduced mountain goat
populations via traditional either-sex hunting licenses presents unique challenges. Issuance of limited
female-only mountain goat licenses in specific circumstances may increase the efficacy of population
reductions while maintaining a desirable age structure among male and female segments. While eithersex licenses will continue to be the norm, issuing female-only licenses are appropriate in select units.
Mountain goat unit G-10 was first opened to hunting in 2012 with 7 either-sex licenses offered. Currently,
10 either-sex licenses are offered annually. Additional dispersal licenses are also offered for units
outside/around G-10 as necessary to remove mountain goats outside the boundary of G-10. In 2012, the
G-10 population was estimated to be between 46 and 62, and currently is estimated to be between 60
and 80. G-10 is not managed as a high quality unit, but rather for a healthy, but small population (~50).
Harvest success in the unit has consistently remained high (80-100% success for 2012-2018). Typically
hunters target mature billies with their either-sex license, resulting in around 75% of all harvests from
2012-2018 being males. In recent years, the G-10 population has grown to the point where goats have
expanded into S-12, a neighboring bighorn sheep unit that is managed for no mountain goats. Every year
for the last 5 years, mountain goats have been observed far south into the S-12 unit. To mitigate these
undesired movements into S-12, Colorado Parks and Wildlife has historically issued dispersal licenses to
hunters. Hunters that have been selected for these licenses were hunters that had applied for a G-10
license and were initially unsuccessful, but were next in line following the drawing. Between 2012 and
2018, 18 mountain goats were harvested outside of G-10 using the dispersal licenses.
In addition to the increase in G-10 mountain goats moving into undesired areas (i.e., S12), there has also
been an increase in human/wildlife incidents with mountain goats in this unit. G-10 (i.e., Tenmile Range)
is an extremely popular recreation area for hikers, bikers, fishermen and mountaineers, and it is not
uncommon for recreationists to find themselves in close proximity with mountain goats. In most of these
incidents, nannies with kids are reported to be the issue. In addition to the already existing either-sex
licenses, female-only licenses will provide a tool to aid managers in controlling the mountain goat
population in G10, as well as to help reduce potential conflicts with recreationists.
Literature Cited:
● Adams, L. G. and J. A. Bailey. 1982. Population dynamics of mountain goats in the Sawatch
Range, Colorado. Journal of Wildlife Management 46: 1003-1009.
● Caughley, G. 1970. Eruption of ungulate populations, with emphasis on Himalayan thar in New
Zeeland. Ecology 51: 53-72.

31

 ●

Festa-Bianchet, M. and S. D. Cote. 2008. Mountain goats: ecology, behavior, and conservation
of an alpine ungulate. Island Press, Washington, D.C. 265 pp.
● Gross, J. E. 2001. Evaluating effects of an expanding mountain goat population on native
bighorn sheep: a simulation model of competition and disease. Biological Conservation 101:
171-185.
● Hobbs, N. T., J. A. Bailey, D. F. Reed and M. W. Miller. 1990. Biological criteria for introductions
of large mammals using simulation models to predict impacts of competition. Transactions of the
55th North American Wildlife and Natural Resources Council. Pp 620-632.
● Houston, D. B. and V. Stevens. 1988. Resource limitations in mountain goats: a test by
experimental cropping. Canadian Journal of Zoology 66: 228-238.
● Williams, J. S. 1999. Compensatory reproduction and dispersal in an introduced mountain goat
population in central Montana. Wildlife Society Bulletin 27:1019-1024.
STATE LAW REQUIRES CPW TO SOLICIT INPUT FROM STAKEHOLDERS THAT MAY BE
AFFECTED POSITIVELY OR NEGATIVELY BY THE PROPOSED RULES. THE FOLLOWING
STAKEHOLDERS HAVE BEEN ADVISED OF AND INVITED TO PROVIDE INPUT ON THE
REGULATORY CHANGES PROPOSED IN THIS ISSUE PAPER:
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
G-10 mountain goat hunters--CPW staff has had periodic discussion with G-10 mountain goat hunters
and other recreationists about mountain goat management challenges in G-10. The proposed alternative
is responsive to these discussions.
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. *Preferred Alternative*: Create G-10 nanny-only licenses available in each of the four mountain
goat seasons already established in G-10 (i.e., create hunt codes GFG10O1R, GF010O2R,
GFG10O3R, and GFG10O4R). Hunting would be limited to weekdays only, as with other goat
licenses in G-10.
2. Status quo
Issue Raised by:
Tom Davies and Elissa Slezak
Author of the issue paper
Tom Davies, revised by Brad Petch
(if different than person raising the
issue):
CC:
Area 1 and 9, Brad Petch, Bryan Lamont, JT Romatzke
APPROVED FOR FURTHER CONSIDERATION BY:
ROMATZKE
REQUIRES NEW SPACE IN THE BROCHURE?
☒YES ☐ N O
ARE ADEQUATE STAFF AND FUNDING RESOURCES
☒YES ☐ N O
AVAILABLE TO IMPLEMENT?
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
Terrestrial
RECOMMENDED FOR CONSENT AGENDA?
☐YES ☒ N O

32

 ISSUES SUBMITTAL FORM
Date:
10/9/2019
ISSUE:
Should the current four individual G-15 nanny-only mountain goat seasons be
combined to create one nanny-only season that runs concurrent with each of the four
either-sex mountain goat seasons in G-15?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
The G-15 mountain goat unit is located in southern Grand, northwestern Summit and western Clear
Creek counties, and is part of the G-7 DAU (the G-7 DAU includes GMUs G-7, G-15, and G-16). The G15 GMU was developed to stop expansion of mountain goats from the core of the DAU. The mountain
goat population in G-15 has historically been and continues to be managed for a low population size (i.e.,
< 50 mountain goats). Licenses were first offered in G-15 in 2002 with four seasons, each season offering
two either-sex licenses. In 2010, nanny-only licenses also began to be offered for G-15 (2009 Issue
Paper created these seasons). The nanny-only licenses were established to provide additional
management tools to aid in managing for low population density, decrease the likelihood of the G-15
population expanding outside of the G-15 unit, and to reduce potential competition with bighorn sheep.
Over time, these nanny-only licenses have proven successful at decreasing the population and thus
reducing the chance of a growing population that would expand outside of the established G-15 unit. As
the population has decreased (Figure 1), hunter success has also decreased (Figure 2).
Figure 1.

Figure 2.

33

 Every summer, in late July, CPW staff conducts mountain goat ground counts in G-15. The number of
mountain goats observed, particularly nannies, during coordinated ground counts as well as hunter
scouting observations have been decreasing over the last few years. Every year, several G-15 hunters
contact CPW staff with concerns that they are putting in significant effort to locate mountain goats prior to
their hunting season, but are having difficulty locating any mountain goats. The difficulty of locating a
nanny has increased disproportionately compared to the difficulty of locating a billy. Managers have seen
an increase in the number of hunters turning in their license prior to the season out of concern that they
would not be successful. Staff does educate hunters that the unit is managed for a low population, and it
may take a greater effort for success compared to other mountain goat units. Despite the low numbers of
mountain goats being observed in G-15 during the summer by staff and hunters, during the hunting
seasons more goats are observed and it is presumed that annual movements from adjacent GMUs (e.g.,
G7 and G16) into the G-15 unit are occurring.
As a result of the G-15 population decline and the herd moving to within the objective range, nanny-only
and either-sex licenses have been reduced beginning in 2015. Additional reductions in nanny-only
licenses may be necessary if population trends indicate a decrease that is below acceptable levels.
However, the current four-season framework requires that a minimum of 4 nanny-only licenses be issued
annually.
Now that managers have achieved the goal of reducing the G-15 population to objective, adjusting
strategies to ensure that managers maintain a small population without eliminating the population is
necessary. By combining all nanny-only seasons into one season, managers will gain additional flexibility
in license setting when responding to changes in population trends in G-15. Additionally, combining
nanny-only seasons may also potentially increase harvest success of nannies by allowing hunters more
time to hunt.
STATE LAW REQUIRES CPW TO SOLICIT INPUT FROM STAKEHOLDERS THAT MAY BE
AFFECTED POSITIVELY OR NEGATIVELY BY THE PROPOSED RULES. THE FOLLOWING
STAKEHOLDERS HAVE BEEN ADVISED OF AND INVITED TO PROVIDE INPUT ON THE
REGULATORY CHANGES PROPOSED IN THIS ISSUE PAPER:

34

 *IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
G-15 mountain goat hunters
No formal public outreach has occurred at this time.
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. Preferred Alternative: Combine the current four nanny-only seasons into one long nanny-only
season that runs concurrent with each of the either-sex mountain goat seasons in G-15 (i.e.,
combine the current GFG15O1R, GFG15O2R, GFG15O3R, and GFG15O4R hunt codes into the
GFG15O1R hunt code, with season dates to run from the first day of the GEG15O1R season to
the last day of the GEG15O4R season. Hunting would be limited to weekdays only, as with other
goat licenses in G-15.
2. Status quo
Issue Raised by:
Author of the issue paper
(if different than person raising the
issue):
CC:

Ben Kraft (Terrestrial Biologist), Bryan Lamont (Terrestrial
Biologist), Jeromy Huntington (DWM Area 9)
Revised/updated by Brad Petch

B. Petch, J.T. Romatzke, Area 9, Area 1, S. Schaller, M.
Leslie
APPROVED FOR FURTHER CONSIDERATION BY:
ROMATZKE
REQUIRES NEW SPACE IN THE BROCHURE?
☐YES ☒ N O
ARE ADEQUATE STAFF AND FUNDING RESOURCES
☒YES ☐ N O
AVAILABLE TO IMPLEMENT?
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
Terrestrial
RECOMMENDED FOR CONSENT AGENDA?
☐YES ☒ N O

35

 ISSUES SUBMITTAL FORM
Date:
10/9/2019
ISSUE:
Should GMU 471 be opened for mountain lion hunting and should GMUs 47 and 471 be
added to the valid GMUs for hunt code LE043O1R, and GMU 45 be added to the valid
GMUs for hunt code LE044O1R?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
Lion DAU L-6 currently has 8 hunt codes for its 12 GMUs. The harvest limit in 2019 for each of these hunt
codes varies between 1 and 9 (Table 1).
Table 1. Current hunt codes in Lion DAU L-6 and proposed changes in valid GMU groupings.
Hunt code
2019
Current
Proposed valid
harvest valid
GMUs, starting in
limit
GMUs
2020
LE015O1R
5
15
15
LE025O1R
7
25, 26,
25, 26, 34
34
LE035O1R
9
35, 36,
35, 36, 361
361
LE043O1R
5
43
43, 47, 471
LE044O1R
6
44
44, 45
LE045O1R
1
45
(group with 44 hunt
code)
LE047O1R
1
47
(group with 43 hunt
code)
LE444O1R
6
444
444
The two hunt codes with harvest limits of 1 lion each, LE045O1R and LE047O1R, are higher elevation
units that only fill their small limits in some years (Figure 1). The adjacent GMUs 44 (next to 45) and 43
(next to 47) have harvest limits that are set higher because of greater opportunity for lion harvest and
higher incidence of human-lion conflicts. Distribution of lions, and thus lion harvest, can vary annually,
both because lions are wide-ranging animals with large individual home ranges and because differences
in winter snowpack among years will shift the distribution of some of their key prey species (deer and elk).
GMU 471, another high elevation unit, has not been open to mountain lion hunting historically.
In certain years, while GMUs 45 and 47’s harvest limits remained unfilled, neighboring GMUs 44 and 43
either filled or came close to filling, which then limited where lion hunters were able or likely to hunt. We
propose grouping GMU 45 into the GMU 44 hunt code, and grouping GMU 47 and a newly opened GMU
471 into the GMU 43 hunt code. These changes will allow potential lion harvest to be distributed across a
larger area per hunt code and not be limited to single GMUs. This issue paper is an attempt to provide
additional harvest in portions of DAU L-6 south of Interstate 70, where human/lion conflicts have
increased markedly in the past several years.
GMU 471 is currently the only GMU on the western slope that is not open for lion hunting. It was not
opened in the past due to its relatively high elevation and limited big game winter range. Additionally, lion
activity appears to be occurring at increasingly high elevations. There is no longer rationale for keeping
this small GMU closed.

36

 Figure 1. History of harvest limit and actual harvest by sex for selected hunt codes in lion DAU L-6.

37

 STATE LAW REQUIRES CPW TO SOLICIT INPUT FROM STAKEHOLDERS THAT MAY BE
AFFECTED POSITIVELY OR NEGATIVELY BY THE PROPOSED RULES. THE FOLLOWING
STAKEHOLDERS HAVE BEEN ADVISED OF AND INVITED TO PROVIDE INPUT ON THE
REGULATORY CHANGES PROPOSED IN THIS ISSUE PAPER:
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
L-6 lion hunters and citizens in southern portions of L-6. No formal public input has been solicited but
CPW staff have had repeated contact with citizens in southern portions of the DAU as human-mountain
lion conflicts have increased.
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):

38

 1. *Preferred Alternative*: Open mountain lion hunting in GMU 471 and consolidate DAU L-6’s
current 8 hunt codes into 6 hunt codes. Hunt codes that would change are:
a. LE043O1R – add GMUs 47 (currently in its own hunt code) and 471 (currently not open
for lion hunting) as valid GMUs
b. LE044O1R – add GMU 45 as a valid GMU
c. LE045O1R and LE047O1R – remove these hunt codes because the GMUs will be
moved under other existing hunt codes (see a and b)
2. Status quo
Issue Raised by:
Julie Mao (Wildlife Biologist) and Area 8 DWMs
Author of the issue paper
Revised by Brad Petch
(if different than person raising the
issue):
CC:
APPROVED FOR FURTHER CONSIDERATION BY:
ROMATZKE
REQUIRES NEW SPACE IN THE BROCHURE?
☐YES ☒ N O
ARE ADEQUATE STAFF AND FUNDING RESOURCES
☒YES ☐ N O
AVAILABLE TO IMPLEMENT?
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
Terrestrial
RECOMMENDED FOR CONSENT AGENDA?
☐YES ☒ N O

39

 ISSUES SUBMITTAL FORM
10/9/2019
ISSUE:

Should the combined mountain lion quota for GMUs 76 and 79/791 be split between
the two units so that each GMU has its own mountain lion quota?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
Mountain lion hunting in GMUs 76 and 79/791 have been managed under a combined mountain lion
quota for at least 20 years. In 1994, the quota was one mountain lion. In 2014, the quota was five
mountain lions. As this population has grown, most lion harvest has occurred in GMU 79. However,
lion harvest is highly dependent on weather, especially snowy weather. During the 2014-15 lion
season, 4 of the lions were harvested in GMU 76 due to the total lack of snow in GMU 79.
Splitting the lion quota between GMU 76 and 79/791 would allow CPW to better manage lion harvest
and hunting opportunity. This would be particularly important during those years of sparse or heavy
snowfall. It would also disperse lion hunters and lion harvest more equitably over the landscape.
STATE LAW REQUIRES CPW TO SOLICIT INPUT FROM STAKEHOLDERS THAT MAY BE
AFFECTED POSITIVELY OR NEGATIVELY BY THE PROPOSED RULES. THE FOLLOWING
STAKEHOLDERS HAVE BEEN ADVISED OF AND INVITED TO PROVIDE INPUT ON THE
REGULATORY CHANGES PROPOSED IN THIS ISSUE PAPER:
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
Internal – This issue has been raised by DWM Brent Woodward and DWM Jeremy Gallegos. It has
been discussed with Area 17 Terrestrial Biologist Brent Frankland, Area 17 AWM Rick Basagoitia and
SW Senior Terrestrial Biologist Scott Wait.
External – Local hunters and outfitters have expressed support of this issue.
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. *Preferred Alternative*: Split the quota between GMUs 76 and 79/791. This gives CPW the
ability to better manage lion harvest and provide hunting opportunity in a more equitable
manner.
2. Status quo – This would continue a shared mountain lion quota between GMUs 76 and 79/791.

Issue Raised by:

Brent Woodward, DWM Creede; Jeremy Gallegos, DWM
South Fork

Author of the issue paper
(if different than person raising the
issue):
CC:
Rick Basagoitia, Brent Frankland, Scott Wait
APPROVED FOR FURTHER CONSIDERATION BY:
Cory Chick
REQUIRES NEW SPACE IN THE BROCHURE?
YES
NO
ARE ADEQUATE STAFF AND FUNDING RESOURCES
YES
NO
AVAILABLE TO IMPLEMENT?
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
Field Operations
RECOMMENDED FOR CONSENT AGENDA?
YES
NO

40

 ISSUES SUBMITTAL FORM

Date:

10/9/2019

ISSUE:

Should list B private-land-only (PLO), mule-deer-only antlered rifle licenses be issued
in a subunit of game management unit (GMU) 951?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
In northeast Colorado, the South Platte River deer herd, D-44, consists of game management units
(GMUs) 91, 92, 94, 96 and 951. Land ownership is 98% private land and 2% public land and the deer
herd is comprised of approximately 15% mule deer and 85% white-tailed deer. Mule deer are not evenly
distributed across the DAU, hunting access on private land varies, and the majority of the mule deer are
concentrated along the South Platte River corridor and associated uplands on private lands. Over the
past 3 years, the proportion of mule deer being harvested in D-44 has declined from 36% in 2016 to 22%
in 2018, even though the number of mule deer classified during annual aerial flights has remained stable
to slightly increasing over that time. The D-44 sex ratio estimate is above the objective range of 35-40
bucks:100 does and is higher for mule deer than for white-tailed deer in the DAU. The 2018 deer surveys
resulted in a mule deer sex ratio estimated at 51 bucks:100 does and a white-tailed deer sex ratio at 42
bucks:100 does. In 2018, mandatory testing for Chronic Wasting Disease (CWD) in D-44 for adult bucks
estimated the prevalence of CWD at 26% in mule deer bucks and 12% in white-tailed bucks with a
combined prevalence of 25% in GMU 951. The decline in mule deer harvest has likely resulted in an
increase in the number of adult mule deer bucks in this herd and is likely a contributing factor to high
CWD prevalence in this DAU. Per Colorado’s Statewide CWD Response Plan, management actions are
recommended when CWD prevalence in adult males is at or above 5% prevalence.
Currently, all deer licenses valid in D-44 are “deer licenses” and allow for harvest of either deer species
(e.g., a mule deer or a white-tailed deer) and all buck deer licenses are list A licenses. With the current
license type, a hunter may only harvest one buck deer and can choose to harvest a mule deer or whitetailed deer. The majority of hunters in this DAU prefer to hunt white-tailed deer along the South Platte
River on the buck deer licenses in D-44. With the sex ratio estimate above the objective range and high
CWD prevalence in D-44, there is a need to increase buck harvest in this DAU. Increasing license
allocations for bucks in D-44 with the current available licenses will not result in harvest levels that are
needed to manage this herd toward the objective range. There is management need to expand our ability
to achieve buck deer harvest in this DAU with other buck license options.
We propose offering a private-land-only (PLO), list B, mule-deer-only rifle license in a subunit of GMU 951
to incentivize and increase mule deer buck harvest. This license type would be valid for both the regular
and late-plains rifle seasons. The proposed subunit of GMU 951 would include a large portion of the
South Platte River corridor and some of the adjacent uplands on the south end of the GMU (Figure 1).
This proposed subunit encompasses the geographic area within GMU 951 where targeted PLO mule
deer harvest is most needed because the mule deer sex ratio is significantly higher than the objective
range and mule deer harvest is minimal. We propose creating the subunit of GMU 951 and offering the
PLO, list B, mule-deer-only license as pilot program. This license type is a first of its kind and staff will
evaluate the harvest along with landowner feedback of this license type annually to inform the efficacy of
this license type for continued implementation.
This recommendation to create a subunit within GMU 951 and add PLO, list B, mule-deer-only buck
licenses in the subunit will increase mule deer buck harvest by allowing a hunter to hunt for more than
one buck deer with a list B license type and direct that harvest toward mule deer bucks. The objective of
this license type recommendation is to reduce the high sex ratio and to reduce CWD prevalence rates
within this DAU. Local CPW staff have met with property managers within this subunit and discussed the
need to increase buck harvest. They were supportive of the creation of a list B mule deer only buck
license.

41

 Figure 1: Proposed GMU 951 subunit hunt area outlined in red for the northern and western boundaries
within GMU 951.

WHO ARE THE EXTERNAL PUBLICS IMPACTED BY THIS ISSUE? WHAT PUBLIC INPUT PROCESS
HAS OCCURRED, IF ANY?
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
Landowners and deer hunters in GMU 951. Local CPW staff have contacted landowners in this proposed
subunit and they support list B mule deer only licenses.

ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. *Preferred Alternative*:
• Create a subunit of GMU 951 bounded on the north by Riverside Inlet Canal, south bank
of Riverside Reservoir, and Riverside Outlet, on the east by Morgan CR 2 and Colo. 144,
on the south by I-76, and on the west by Weld CR 386, US 34, Weld CRs 69, 380, and
50 (Figure 1).
• Create a PLO, list B, mule-deer-only rifle buck hunt code valid only for the GMU 951
subunit.
2. Status Quo

42

 Issue Raised by:
Author of the issue paper
(if different than person raising the
issue):
CC:

Marty Stratman-Wildlife Biologist, Brandon Muller-DWM
Marty Stratman

T. Petersburg, A. Curtis, Area 4 DWMs, T. Schmidt, Area 3
DWMs, S. Schaller, M. Eckert, T. Kroening, M. Leslie
APPROVED FOR FURTHER CONSIDERATION BY:
Mark Leslie
REQUIRES NEW SPACE IN THE BROCHURE?
☒YES ☐ N O
ARE ADEQUATE STAFF AND FUNDING RESOURCES
☒YES ☐ N O
AVAILABLE TO IMPLEMENT?
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
Terrestrial
RECOMMENDED FOR CONSENT AGENDA?
☐YES ☒NO

43

 ISSUES SUBMITTAL FORM
Date:

10/9/2019

ISSUE:

Should early private-land-only (PLO), either-sex hunt codes be added to increase
harvest on deer within the Uncompahgre Valley in GMUs 62, 64, 65 and 411 to reduce
the prevalence of CWD within the identified CWD hotspots?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
The first documented case of CWD in southwest Colorado occurred in April 2016 in GMU 65 when a
deer died in a residential area on the southwest side of Montrose. Since then, 45 cases of CWD-infected
deer have been detected in the Montrose/Delta area (GMUs 60, 61, 62, 64, 65, and 411) via submission
of suspect deer, deer harvested from kill permits, deer harvested from damage hunts, deer harvested
through voluntary submission in 2016, and mandatory harvest submissions from the 2017 hunting
season. Results from the 2017 mandatory submission have documented a CWD prevalence rate of 4%
in D-19 and 1.5% in D-40. Using harvest locations from the 2017 mandatory harvest, we looked at the
prevalence rates for deer within the Uncompahgre River Valley versus deer harvested outside of the
Valley. Generally, deer residing within the Valley during hunting season are non-migratory/resident
deer, while deer harvested outside of the Valley are probably migratory deer that move to lower
elevations in proximity to and within the Uncompahgre Valley in the winter. The table below provides
prevalence rates from the 2017 mandatory harvest depicting where deer submissions came from in
DAUs D-19 and D-40, by GMU and whether or not the location occurred within or outside of the
Uncompahgre Valley. The table also provides CWD prevalence estimates for deer within the Valley and
outside of the Valley.

Location

2017 Harvest
Samples (>1 yo
males)

Negative

Positive

Prevalence

Valley 62/64/65

143

131

12

8.39

Valley 62

75

66

9

12.00

Valley 64

28

25

3

10.71

Valley 65

40

40

0

0.00

Mountain 61/62/64/65

368

366

2

0.54

Mountain 61

48

48

0

0.00

Mountain 62

120

119

1

0.83

Mountain 64

19

19

0

0.00

Mountain 65

181

180

1

0.55

Mountain D19

168

167

1

0.60

Mountain D40

200

199

1

0.50

All D19

243

233

10

4.12

All D40

268

264

4

1.49

The map below illustrates where submissions came from across DAUs D-19 and D-40 and using a point
density analysis, illustrates where the hotspots are for CWD prevalence within the Valley. These Valley

44

 hotspots will be the focus for proposed actions to reduce CWD prevalence through the reduction in deer
densities.

45

 Area 18 Wildlife Managers believe that a multi-faceted attempt to confront the threat of CWD in the
Uncompahgre Valley is crucial to reducing prevalence of the disease. As stated in the legislative
declaration of Colorado Revised Statutes 33-1-101(4), public hunting shall be the primary management
tool to attain desired harvests of mule deer. Area 18 intends to issue the following public deer license
opportunities:
●
●
●
●
●

General antlered,
PLO antlered/either-sex including
o Existing structure and
o *Proposed new early Uncompahgre Valley only either-sex licenses,
Antlerless,
Game damage antlerless, and
Disease management.

The proposed early season rifle PLO hunt code would run from August 15th to August 25th. The 10-day
season will allow for some flexibility with farmers who may be irrigating or harvesting crops during that
time, but will still be a short enough season to focus harvest prior to the regular archery and rifle
seasons starting up. Also, focusing harvest in the Uncompahgre Valley early in the fall minimizes the
chance of harvesting migratory deer and focuses harvest on the identified hotspots of CWD prevalence
and hopefully minimizes the spread of CWD to migratory deer. Input collected from a public meeting,
recommended making these licenses available to youth, with 15% of licenses allocated to youth
preference. The recommended season dates will occur before school and most fall sports allowing youth
time to hunt.
The season will be restricted to the Valley and licenses will be allocated by DAU with 3 different hunt
codes, one for GMU 62 (D-19), one for GMUs 64/65 (D-40), and one for GMU 411 (D-51). The GMU 62
hunt will be bounded by the unit boundary on the east and then on the south by the South Canal and
West Canal, on the west by the West Canal and CQ Lateral Canal and Roubideau Creek and Gunnison
River to G50 Road to Hwy 50, and on the north by Hwy 50. The GMUs 64/65 hunt code will be bounded
on the west and north by the unit boundary, on the east by 22.00 Rd, F.00 Rd, Peach Valley Road, Selig
Canal, Loutsenhizer Canal, Landfill Road, AB Lateral Canal, and South Canal. The GMU 411 hunt code
will be bounded on the south by the unit boundary, on the west by 1550 Road, on the north by the North
Delta Canal to Tongue Creek then Fairview Road, and then on the east by Highway 65.
The season will be implemented until it is determined that it is not needed or effective. The season will
be removed if there is no harvest.
STATE LAW REQUIRES CPW TO SOLICIT INPUT FROM STAKEHOLDERS THAT MAY BE
AFFECTED POSITIVELY OR NEGATIVELY BY THE PROPOSED RULES. THE FOLLOWING
STAKEHOLDERS HAVE BEEN ADVISED OF AND INVITED TO PROVIDE INPUT ON THE
REGULATORY CHANGES PROPOSED IN THIS ISSUE PAPER:
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
A public meeting was held August 26th in Montrose from 6:00 pm to 8:00 pm to provide the public with
information about CWD, to collect input for the upcoming Herd Management Plan revisions, and to notify
the public about the proposed early rifle PLO season in the Uncompahgre Valley. The public was
notified through press release and local farmers, outfitters, and meat processors were invited via letter
or phone call. Twenty-six people attended the meeting including outfitters, meat processors, BHA
representative, and hunters. There was a lot of support for the early PLO Valley season. An outfitter and
other hunters encouraged CPW to make the license available for youth hunters. Twenty-three people
filled out survey cards at the meeting. Only 2 people were not aware that CWD had been detected in our
local herds. When asked how concerned people were about CWD, 0 reported that they were not
concerned at all, 4 were somewhat concerned, 7 were moderately concerned, and 13 were very
concerned.

46

 ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. *Preferred Alternative*: Create hunt codes DE062P*R, DE064P*R (valid in GMUs 64 and 65),
and DE411P*R to run from August 15th – August 25th and allocate 15% of licenses to youth
preference. Hunt boundaries will be:
● DE062P*R will be bounded by the unit boundary on the east and then on the south by the
South Canal and West Canal, on the west by the West Canal and CQ Lateral Canal and
Roubideau Creek and Gunnison River to G50 Road to Hwy 50, and on the north by Hwy 50.
● DE064P*R will be bounded on the west and north by the unit boundary, on the east by
22.00 Rd, F.00 Rd, Peach Valley Road, Selig Canal, Loutsenhizer Canal, Landfill Road, AB
Lateral Canal, and South Canal.
● DE411P*R will be bounded on the south by the unit boundary, on the west by 1550 Road,
on the north by the North Delta Canal to Tongue Creek then Fairview Road, and then on the
east by Highway 65.
2. Status quo
Issue Raised by:

DWMs Matt Ortega, Mark Richman, Natalie Renneker,
and Wildlife Biologist Brad Banulis

Author of the issue paper
(if different than person raising the
issue):
CC:
Renzo DelPiccolo, Scott Wait
APPROVED FOR FURTHER CONSIDERATION BY:
Cory Chick
REQUIRES NEW SPACE IN THE BROCHURE?
☒YES ☐ N O
ARE ADEQUATE STAFF AND FUNDING RESOURCES
XYES ☐ N O
AVAILABLE TO IMPLEMENT?
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
Terrestrial and SW Region
RECOMMENDED FOR CONSENT AGENDA?
☐YES xNO

47

 ISSUES SUBMITTAL FORM
Date:
10/9/2019
ISSUE:
Should second and third season rifle female deer hunt codes DF055O2R, DF055O3R,
DF551O2R, DF551O3R, DF066O2R, DF067O3R) in D22 (GMU 55 & 551) and D25 (GMU
66 & 67) be added?
DISCUSSION (FACTS AND FIGURES, EXPLANATION OF ISSUE):
The deer population size of the Gunnison Basin deer herds are very dynamic. Since an extreme winter 12
years ago (2007 – 2008), the deer population has increased. Doe licenses (female deer hunt codes) were
administered in response to this increasing population size. The population increased rapidly until
approximately 2012. However, fawn survival rates showed a declining trend from 2013 – 2016. Then, in
the winter of 2017/2017, a harsh winter obstructed the recruitment of nearly all fawns to adulthood. Adult
female survival rates during this winter were also lower than average. The mule deer populations in mule
deer DAU’s D22 and D25 was predicted to decline below the population size objective established in the
2013 herd management plans. Doe licenses were removed as a cautionary strategy. Immediately after
the doe hunt codes were removed, D22 and D25 showed a rapidly rebounding population in the past two
years due to a combination of conditions that reversed the negative growth trend anticipated just two
years ago. These contributing factors include: (1) a higher than expected buck survival rate in the hard
winter of 2016/2017 that was not identified until new survey data was collected a year later (2017 posthunt surveys), (2) a near-average fawn survival rate in the most recent hard winter of 2018/2019, (3)
record high fawn production in summer/fall 2018 (based on 2018 post-hunt surveys), and (4) higher than
average adult and fawn survival rates in the mild winter of 2017/2018. D22 and D25 are now exceeding
their population size management objectives, established in their commission approved herd
management plans, by ~25-40%.
These doe licenses are intended to maintain the herd management objectives outlined in the 2013 herd
management plans. Allowing the mule deer population size to remain over objective will lead to: 1)
increased risk of degrading rangeland, 2) increased buck tag allocations in the future to maintain buck
ratios that will have an unintended consequence of increasing hunter crowding during all buck hunt
codes, 3) increasing risk of establishing CWD in the Gunnison Basin.
Additionally, these doe hunt codes provide a large opportunity to youth hunters in the Gunnison Basin
that otherwise would not be able to draw a license during the buck hunting seasons given the high
number of preference points required. All prior regulations (Ch. W-2, Art I, #206, B, 4, d, 2) regarding the
50% allocation of antlerless deer licenses to youth in these GMUs would remain.
STATE LAW REQUIRES CPW TO SOLICIT INPUT FROM STAKEHOLDERS THAT MAY BE
AFFECTED POSITIVELY OR NEGATIVELY BY THE PROPOSED RULES. THE FOLLOWING
STAKEHOLDERS HAVE BEEN ADVISED OF AND INVITED TO PROVIDE INPUT ON THE
REGULATORY CHANGES PROPOSED IN THIS ISSUE PAPER:
*IT IS ASSUMED THAT ALL NECESSARY INTERNAL PARTIES HAVE BEEN NOTIFIED*.
A public meeting was held in Gunnison March 25, 2019 in which information on the increasing population
trend was presented. A second public meeting was held in Gunnison on August 14th 2019 to present this
issue of adding the doe hunt codes. An article was presented in the local newspaper describing the
changes and calling for any public comment. Contact information for the local biologist was provided in
the article. To date, no comments or objections have been received.
ALTERNATIVES: (POSSIBLE OUTCOMES or POSSIBLE REGULATIONS):
1. *Preferred Alternative*: Add hunt codes DF055O2R, DF055O3R, DF551O2R, DF551O3R,
DF066O2R, DF067O3R.
2. Status quo.
Issue Raised by:
Author of the issue paper

Kevin Blecha, Area 16 staff

48

 (if different than person raising the
issue):
CC:

J Wenum, Scott Wait, Cory Chick, Craig McLaughlin,
Lucas Martin, Nick Gallowich, Chris Parmeter, Brandon
Diamond
Cory Chick
APPROVED FOR FURTHER CONSIDERATION BY:
REQUIRES NEW SPACE IN THE BROCHURE?
XYES NO
ARE ADEQUATE STAFF AND FUNDING RESOURCES
☒YES ☐ N O
AVAILABLE TO IMPLEMENT?
Terrestrial/Field Ops
REGION, BRANCH, OR SECTION LEADING IMPLEMENTATION
RECOMMENDED FOR CONSENT AGENDA?
YES X NO

49