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DRAFT NORTH PARK PRONGHORN HERD MANAGEMENT PLAN

DATA ANALYSIS UNIT PH-3

GAME MANAGEMENT UNITS 6, 16, 17, 161, & 171

PREPARED FOR PARKS AND WILDLIFE

BY

JEFF YOST

THIS PLAN WAS APPROVED BY THE COLORADO PARKS AND WILDLIFE COMMISSION ON XXXXXX

DRAFT PH – 3 HERD MANAGEMENT PLAN

EXECUTIVE SUMMARY North Park Pronghorn Herd (DAU PH-3) GMUs: 6, 16, 17, 161, & 171 Posthunt Population: Previous Objective: 1,500–1,600 pronghorn; 2019 Estimate: 1,496 pronghorn. Preferred Alternative: 1,400–1,600 pronghorn Posthunt Sex Ratio (Bucks: 100 Does): Previous Objective: 30-40; Prehunt 2019 observed: 51.9; modeled: 35.3. Preferred Alternative: 30-40 bucks: 100 does

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PH-3 modeled population estimate and objective range, 1995 – 2019. 350 300 250 200 150 100 50

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1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 YEAR Bucks Doe & Fawn Total Harvest

PH-3 Harvest Estimates, 1995 - 2019.

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PH-3 Observed Prehunt, Modeled Posthunt, and Sex Ratio Objective Range, 1995 - 2019.

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Background Information Pronghorn DAU PH-3 is located in north- and includes Game Management Units (GMUs) 6, 16, 17, 161, and 171. The area is commonly known as North Park and is comprised of nearly all of Jackson . The Wyoming border is the northern boundary of the DAU. PH-3 encompasses 1,618 square miles and is a mix of public and private land. Cattle ranching and grass hay production have historically been, and continue to be, primary land uses in North Park. This high elevation, cold, semi-desert habitat has a strong agricultural base of irrigated hay meadows and cattle grazing. These conditions also provide productive wildlife habitat for big game, sage grouse, waterfowl and numerous nongame species. Timber harvest is also an important land use. Hunting and fishing provide significant revenue and jobs to the local economy. In recent years, oil and gas exploration and production have been increasing with potential to expand exponentially. The pronghorn population in North Park was very high in the late 1880’s but was completely eliminated by unregulated hunting by the 1930’s. The population was re-established by natural immigration from nearby herds in Wyoming in the 1950’s and limited harvest began in 1968. By the mid 1970’s, the population was estimated at approximately 500 animals and, by 2004, was roughly 1,500 pronghorn. The current modeled post hunt population is at the low end of the current objective of 1,500 to 1,600 pronghorn in the post-hunt population with a pre-season sex ratio of 51.9 bucks per 100 does. CPW manages the North Park pronghorn population for a quality hunt; not just for trophy class bucks but for limited doe hunting with minimal hunter crowding. Licenses are limited for all methods of take (archery, muzzle loading and rifle). In years when the pronghorn population is at or above objective licenses may need to be increased, to the point where some hunters feel crowded, in order to keep the population within the objective ranges. Significant Issues There are few significant issues with pronghorn in North Park. The herd is generally at a sustainable and tolerable size and there are very few conflicts. Access to good public land pronghorn hunting is available in all units in North Park and harvest success rates are very good for hunters on both public and private land. Management Alternatives Three post-hunt population objective ranges were considered: (1) decrease from the current objective to 1,200–1,400 pronghorn, (2) an objective of 1,400–1,600 pronghorn similar to the current objective of 1,500-1,600, (3) increase the objective to 1,600-1,800 pronghorn. Three post-hunt sex ratio objectives were considered: (1) 20-30 bucks:100 does to maximize recruitment, (2) 30-40 bucks:100 does which would allow good recruitment and trophy potential, or (3) 40-50 bucks:100 does to maximize trophy production. Through the DAU planning process and public input, a post hunt population of 1,400–1,600 pronghorn and a sex ratio of 30-40 bucks: 100 does were selected as future management objectives. This preferred population range represents a wider range than the current population objective.

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CONTENTS EXECUTIVE SUMMARY ...... i Background Information...... ii Significant Issues ...... ii Management Alternatives ...... ii INTRODUCTION AND PURPOSE ...... 1 NORTH PARK PRONGHORN DATA ANALYSIS UNIT DESCRIPTION ...... 3 Location ...... 3 Physiography ...... 3 Land Status ...... 5 HABITAT RESOURCE AND CAPABILITIES ...... 7 Habitat Distribution ...... 8 Habitat Condition and Capability ...... 9 Conflicts with Agriculture ...... 9 HERD MANAGEMENT HISTORY, ISSUES AND STRATEGIES...... 10 Overview of Procedures to Estimate Population Size ...... 10 Post-hunt Population Size ...... 11 Pre-hunt Herd Composition ...... 11 Harvest and Licenses ...... 13 Past Management Strategies ...... 15 Current Issues ...... 15 PUBLIC INVOLVEMENT ...... 16 PREFERRED ALTERNATIVES AND NEW OBJECTIVES ...... 17 LITERATURE CITED ...... XVIII APPENDIX I: POPULATION DYNAMICS, MAXIMUM SUSTAINED YIELD, AND DENSITY DEPENDENCE...... XIX APPENDIX II: PUBLIC MEETINGS ANNOUNCEMENT ...... XXI APPENDIX III: PUBLIC SURVEY & RESULTS ...... XXII APPENDIX IV: HPP COMMENT LETTER ...... XXVI

DRAFT PH – 3 HERD MANAGEMENT PLAN

FIGURES FIGURE 1. CPW'S MANAGEMENT BY OBJECTIVE PROCESS TO MANAGE BIG GAME POPULATIONS BY DATA ANALYSIS UNIT...... 1 FIGURE 2. LOCATION OF DAU PH-3...... 3 FIGURE 3. AVERAGE MONTHLY TEMPERATURE, WALDEN, CO 1981-2010. US CLIMATE DATA, 2015) ...... 4 FIGURE 4. AVERAGE MONTHLY PRECIPITATION IN WALDEN, 1981-2010. US CLIMATE DATA, 2015) ...... 4 FIGURE 5. LAND OWNERSHIP IN PH-3...... 6 FIGURE 6. VEGETATION DISTRIBUTION IN PH-3...... 7 FIGURE 7. PRONGHORN RANGE IN PH-3...... 8 FIGURE 8. MODELED POPULATION SIZE ESTIMATE AND OBJECTIVE IN PH-3 1995 - 2019...... 11 FIGURE 9. OBSERVED PREHUNT FAWNS: 100 DOES & MODELED POSTHUNT POPULATION IN PH-3, 1995 - 2019...... 12 FIGURE 10. OBSERVED PREHUNT BUCKS: 100 DOES IN PH-3, 1995 - 2019...... 12 FIGURE 11. LICENSE NUMBERS BY METHOD OF TAKE IN PH-3, 1996 - 2020...... 13 FIGURE 12. MODELED POSTHUNT POPULATION ESTIMATE, HARVEST AND LICENSE NUMBERS IN PH-3, 1995 - 2019...... 14 FIGURE 13. PRONGHORN HARVEST IN PH-3, 1995 - 2019...... 14 FIGURE 14. SIGMOID GROWTH CURVE...... XIX FIGURE 15. MAXIMUM SUSTAINED YIELD...... XX

TABLES TABLE 1. LAND OWNERSHIP AND MANAGEMENT IN PH-3...... 5

DRAFT PH – 3 HERD MANAGEMENT PLAN

INTRODUCTION AND PURPOSE Colorado Parks and Wildlife (CPW) manages wildlife for the use, benefit, and enjoyment of the people of the state in accordance with the CPWs Strategic Plan and mandates from the Parks and Wildlife Commission and the Colorado Legislature. Colorado’s wildlife resources require careful and increasingly intensive management to accommodate the many and varied public demands and growing human impacts. CPW establishes general season structure guidelines statewide, known as Big Game Season Structure (BGSS). CPW uses BGSS as a standardized framework for annual big game hunting regulations to ensure predictability and consistency geographically and annually for big game seasons. This framework is updated every five years through a public process and establishes what types of hunting opportunities will be available, when opportunities will be available, where opportunities will be available, and how the opportunities will be divided amongst methods of take. Within these overarching frameworks, CPW manages big game populations as individual herds called Data Analysis Units or DAUs. A DAU is the geographic area that represents the year- around range of a big game herd and delineates the seasonal ranges of a specific herd that naturally experiences little interchange with adjacent herds. A DAU includes the area where the majority of the animals in a herd are born, live, and die. Each DAU usually is composed of several game management units (GMUs) which are designed to distribute hunters within the DAU. In some cases, only one GMU makes up a DAU. CPW uses a “management by objective” approach (Figure 1). With this approach, CPW manages big game populations to achieve population and sex ratio objective ranges established through an intensive public process that culminates in Herd Management Plans (HMPs). The purpose of an HMP is to provide a process to integrate the plans and intentions of CPW with the concerns and ideas of land management agencies and interested publics in determining the management practices of each big game herd.

Figure 1. CPW's Management by Objective Process to manage big game populations by Data Analysis Unit.

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In preparing an HMP, CPW personnel strive to balance the biological capabilities of the herd and its habitat with the public's demand for wildlife recreational opportunities. Primarily, the HMP process produces objectives for the number of animals in the DAU, the population performance, and the desired sex ratio (e.g., the number of males per 100 females). These numbers are referred to as the DAU population and herd composition objectives, respectively. Secondarily, the HMP process identifies strategies and techniques to reach the population size and herd composition objectives. Population and sex ratio objectives drive important decisions in the big game season setting process, namely, how many animals need to be harvested to maintain or move toward the objectives, and what types of hunting seasons are required to achieve the harvest objectives. Various publics and constituents, including the U.S Forest Service, the Bureau of Land Management, sports persons, guides and outfitters, private landowners, local chambers of commerce and the general public, are involved in the determination of DAU population and composition objectives and related issues. During the HMP process, public input is solicited, collected, and incorporated through surveys, public meetings, and written comments to the Parks and Wildlife Commission. The purpose of this herd management plan is to set population and harvest objectives for the North Park pronghorn herd (PH-3; GMUs 6, 16, 17, 161, and 171). The herd management plan will be in place from 2020-2030 with the expectation that it will be reviewed and updated in 2030.

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NORTH PARK PRONGHORN DATA ANALYSIS UNIT DESCRIPTION Location Pronghorn DAU PH-3 is located in North Central Colorado and comprises all of Jackson County, commonly called North Park (Figure 2). The largest town in North Park and the county seat is Walden (population 734), Cowdrey, Gould, and Rand are much smaller but well-known towns. PH-3 consists of Game Management Units 6, 16, 17, 161, and 171. North Park is an intermountain park on the east side of the Continental Divide. The North Park watershed begins at the headwaters of the North Platte River. Major tributaries that make-up the North Platte drainage in Colorado are Grizzly Creek, the Illinois River, the Michigan River, the Canadian River, and the North Fork of the North Platte. Popular fishing lakes in the area include Delaney Buttes, Lake John, and Big Creek Lakes among others. The DAU is bounded on the west by the , on the south by the Rabbit Ears Range, to the east by the Medicine Bow and Never Summer Ranges, and Independence Mountain and the Wyoming border on the north. DAU PH-3 encompasses 1.036 million acres or 1,618 square miles.

Figure 2. Location of DAU PH-3.

Physiography Topography Elevations in North Park range from 7,800 feet at Northgate to 12,951 feet at Clark’s Peak. The average elevation of the open, sagebrush-grassland park is 8,000 feet. North Park is a relatively flat, sagebrush grassland with numerous wetlands interspersed with wide, willow

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dominated drainages. The mountains that surround the park rise rapidly to the alpine zone above timberline. The montane zone is dominated by lodgepole pine stands and to a lesser extent aspen and spruce-fir stands. Climate Winters are windy, cold, and snowy. The summers are short, cool, and dry. The average temperature measured at Walden is 37.8 degrees F, with a temperature range between -50 degrees F and 90 degrees F (Figure 3).

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Figure 3. Average Monthly Temperature, Walden, CO 1981-2010. US Climate Data, 2015)

The growing season averages 33 days, mostly in the month of July with between 15 and 45 frost free days annually. The average annual precipitation is 12.4 inches which includes 50 inches of snowfall that comes in a few large snowstorms (Figure 4). Moderate to severe winds are common in North Park prevailing to the northeast.

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Figure 4. Average Monthly Precipitation in Walden, 1981-2010. US Climate Data, 2015)

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Land Status Land Ownership The public owns much of the land in PH-3; the DAU is approximately 36% private land, 12% state land and 52% federal land (Table 1). The Routt National Forest covers 32% of the DAU and most of the mountainous areas that surround the park. The Bureau of Land Management (BLM) property, 18.2%, is primarily sagebrush habitat in the center of the park where a majority of the private land is also located. The Colorado State Forest, which comprises 6.8% of PH-3, is found on the east side of PH-3. The Arapaho National Wildlife Refuge, 1.7%, manages important pronghorn habitat in the center of the Park. State Trust Lands, 4.9%, are primarily sagebrush habitat with some aspen and mixed conifer.

OWNER MANAGER ACRES BLM BLM 189,222 BLM CPW 11,168 FWS FWS 23,458 PRIVATE PRIVATE 357,295 SLB SLB 52,080 SLB CPW 69,760 USFS - ARNF USFS - ARNF 2,113 USFS - ROUTT USFS - ROUTT 330,972 TOTAL 1,036,067 Table 1. Land Ownership and Management in PH-3.

Most of the private lands are found in the center of the DAU and are a patchwork with BLM- managed lands. Much of the lands at higher elevations, which form the periphery of the unit, are managed by the USFS and the state of Colorado (Figure 5). .

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Figure 5. Land Ownership in PH-3.

Land Use Cattle ranching and grass hay production have historically been, and continue to be, the primary land uses in North Park. This high, cold, semi-desert habitat has a strong agricultural base of irrigated hay meadows and cattle grazing. These conditions also provide productive wildlife habitat for big game, sage-grouse, waterfowl and numerous non-game species. Large expanses of live and beetle-killed lodgepole pine provide opportunity for timber harvest. Hunting and fishing are an important part of the local economy providing roughly 51 jobs in Jackson County with hunting generating $4,533,000 of revenue in the county annually (Southwick Associates 2018). In recent years, oil and gas exploration and production have been increasing with potential to expand exponentially.

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HABITAT RESOURCE AND CAPABILITIES Vegetation varies throughout PH-3 with sagebrush lining the valley floor, a variety of willow species along stream courses, and mountain shrub, lodgepole pine, aspen, and spruce-fir at higher elevations. The dominant vegetation types present are coniferous forest, sagebrush mix, and irrigated grass hay fields (Figure 6). Pronghorn habitat is the sagebrush grassland in the center of North Park along with mixed sage/aspen/mountain shrub along the fringe areas.

Figure 6. Vegetation distribution in PH-3.

Optimum pronghorn habitat is comprised of a matrix of Wyoming big or silver sagebrush, Douglas rabbitbrush, and associated forbs. Highest fawn: doe ratios are correlated with the above and in areas averaging 11” of annual precipitation, vegetative cover of 40-60% with average height of plant cover 18”, 10-20% sage species, 5-15% browse, 25-35% forbs, and 40- 60% grass. Grasses are of minor importance in pronghorn diets. Pronghorn need an arrangement of habitats that provide irregular topography that protects them from cold winds, windblown areas that expose forage, and access to sufficient water (Sundstrom, 1973). Although free water is an important component of pronghorn habitat in arid regions of the desert southwest, where they may consume a gallon or more of water daily, pronghorn in PH- 3 get the majority of the water they need from succulent forage. Pronghorn will, and do, use free water when it is available but forage quality related to amount and timing of rainfall has a greater influence on fawn: doe ratios than available surface water (Bristow et al. 2006). Pronghorn are considered “concentrate selectors” in that they feed by selecting the most succulent and nutritious forbs and browse. In Utah, pronghorn only used free water when succulent forage species were not available (Beale and Smith 1970). With abundant streams, ponds and irrigated fields and pastures in North Park lack of succulent forage and available surface water would rarely be an issue here even for lactating does.

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Habitat Distribution Pronghorn Range The pronghorn overall range in North Park encompasses 485,000 acres, 757 square miles. The sagebrush grasslands used by pronghorn make up 46% of the total land area in North Park. The winter concentration areas for antelope encompass 40,000 acres or only 8% of the overall range (Figure 7). A subset of the PH-3 population migrates to Wyoming in some winters. Pronghorn are dependent on the forb and browse components of the sagebrush plant community. Pronghorn are the only truly native species that evolved exclusively in the grasslands of North America over the last 50 million years. Pronghorn use wet meadows where forbs are available, but the majority of pronghorn use the drier sagebrush areas. Sagebrush makes up the majority of pronghorn diet in the winter. Sagebrush is high in protein, equaling alfalfa. Sagebrush is also high in volatile oil, which makes it less palatable to other browsers, but not to pronghorn. Forbs are the most important part of pronghorn diet in the spring and summer.

Figure 7. Pronghorn Range in PH-3.

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Habitat Condition and Capability The productivity of the sagebrush-grassland community has declined across much of the western U.S. with a corresponding decrease in three wildlife species dependent on the sagebrush community (mule deer, sage grouse, and pronghorn). In North Park the capability of the sagebrush habitat may be reduced due to a reduction of disturbances such as fire and historic trampling by bison. Numerous projects over the years have been implemented to set back older decadent sagebrush through mostly mechanical means. However, North Park also provides critical habitat to Greater Sage-grouse, which are a federal species of concern. Impacts to sage-grouse must be carefully considered prior to treatment of sagebrush to benefit pronghorn in PH-3. Currently, the sagebrush habitat in North Park is in good condition and currently provides high quality pronghorn forage without need for manipulation or enhancement Conflicts with Agriculture Game Damage Unlike lower elevations in Colorado, climatic conditions in North Park are not conducive to small grain farming such as winter wheat. Typically agricultural damage situations arise when pronghorn congregate on wheat fields potentially reducing yields and spreading weeds. Pronghorn are minor competitors with livestock for forage in North Park, so there are few local concerns of damage. There have been not been damage claims or major conflicts attributed to pronghorn in PH-3.

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HERD MANAGEMENT HISTORY, ISSUES AND STRATEGIES Overview of Procedures to Estimate Population Size Estimating population size of wild animals over large geographic areas is a difficult and inexact exercise. A complete count of each individual animal in a population is prohibitively expensive and inherently inaccurate. Multiple research projects have attempted to count a known number of animals in large fenced areas. All of these efforts have failed to accurately count all of the animals. In most cases, fewer than 30% of the animals may be observed and counted. The most accurate method of estimating population size available at this time is through computer modeling using known biological parameters and the most accurate biological and harvest data for a given population. Pre-hunt coordinated ground classification surveys are employed in North Park to provide accurate data to inform population models. These surveys are not a census of the population and are at best a very coarse index of population trend. They are simply a snapshot of the composition of the herd prior to hunting seasons. CPW then incorporates the observed age and sex ratios, along with hunter harvest, estimated survival rates of adults and juveniles, and wounding loss rates into population models developed by (White and Lubow 2002). These population modeling methods represent CPW’s current best estimate of population sizes. It is important to note that these models are subject to revision and improvement as further wildlife management research provides more accurate modeling techniques. As better information becomes available, such as new estimates of age-specific or sex-specific survival rates, wounding loss, sex ratio at birth, density estimates, or new statistical modeling techniques, better population estimates may be derived in the future. In PH-3, population estimates have been based on a variety of methods. Production counts have been completed since 1972. Pojar and Guenzel (1999) compared helicopter quadrats and fixed-wing aircraft line-transects for pronghorn in North Park, Colorado and Big Creek, Wyoming. The helicopter quadrat census was the more accurate method of determining total population size. The population estimates for 1997 and 1998, from Pojar and Guenzel’s study, are used to anchor the PH-3 spreadsheet population model. These helicopter-based estimates, although more accurate, were prohibitively expensive, so fixed-wing aircraft were then used. CPW staff were concerned that fixed-wing flight classification failed to observe many of the younger bucks that were not with the does and fawns. To verify if ground classification is indeed an acceptable way to obtain sex and age data both helicopter aerial and coordinated ground classification were conducted in late August of 2006. Results of the comparison yielded similar results with 1052 total pronghorn observed from the ground and 1109 observed from the air. Additionally, aerial helicopter classification using a pilot and two observers costs approximately 2 ½ times more than coordinated ground count using eight CPW employees. Since 2002, CPW personnel observe annual sex and age ratios with annual ground classification surveys. Modeled estimates of the number of pronghorn in PH-3 have changed over time with the type and complexity of the models used. The population size is estimated from population models using observed values from classification flights, harvest numbers from hunter surveys, survival rates, and winter severity. As new knowledge develops, models are improved to make the model more accurate in estimating the population.

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Post-hunt Population Size The PH-3 pronghorn population was quite large in the 1800’s. In 1868, it was reported the Ute Indians killed 4,400 pronghorn in North Park by “using a surround technique” and a herd estimated at 5,000 individuals wintered near Walden in 1885 (Warren 1942). Market hunting reduced the population and by the early 1900’s, pronghorn were scarce. By the 1930’s pronghorn were extirpated from North Park. In the mid-1950s pronghorn immigrated to North Park from Wyoming. CPW initiated annual population counts in the mid-1960s, and limited harvest was established in 1968. In the mid- 1970s the winter pronghorn population was approximately 500 animals. In 1996 and 1997 Pojar and Guenzel (1999), estimated 1,909 and 1,420 pronghorn in PH-3, respectively. Since that time, the population has been relatively stable, fluctuating between roughly 1,000 and 1,500 pronghorn (Figure 8). The current posthunt population objective is 1,500 – 1,600 pronghorn.

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Figure 8. Modeled Population Size Estimate and Objective in PH-3 1995 - 2019. Pre-hunt Herd Composition The composition of the pronghorn population in PH-3 is monitored annually with coordinated ground surveys on summer range. Observed pronghorn are classified as adult females, young, yearling males, and adult males. This is not a count of the population, but a snapshot of the current condition of the population. Fawn: doe ratios Fawn: doe ratios in PH-3 have been consistently low in North Park, but have been increasing steadily (Figure 9). Fawn: doe ratios of less than 40 fawns: 100 does are common in this DAU and have a substantial impact on population size estimates. Though these fawn to doe ratios seem quite low Ellis (1970) found fawn: doe ratios reported across the Intermountain West averaged 30-50:100. The PH-3 population quickly rebounds when fawn: doe ratios are above 40 fawns per 100 does for several consecutive years. Low fawn: doe ratios likely limit the population size and are largely a result of severe winters and habitat conditions that decrease doe pregnancy rates and fawn survival. Snow depths greater than 10-12” combined with prolonged freezing temperatures or freeze/thaw cycle negatively influence age ratios the following year (Lee et al. 1998) Montana considers a recruitment rate of less than 40 fawns: 100 does as very poor and Arizona decreases permit numbers when the recruitment rate falls below 30 and raises permit numbers when it goes above 40 (Lee et al. 1998). Wyoming pronghorn on high quality range consisting of big and silver sagebrush have long-term age ratios averaging between 79 and 100

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fawns: 100 does in areas averaging approximately 11 inches of annual precipitation (Sundstrom 1973). Annual average precipitation recorded at Walden Colorado from 1981 through 2010 is 12.37” (Figure 4).

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2010 2014 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2011 2012 2013 2015 2016 2017 2018 YEAR Modeled Population Estimate Prehunt Observed

Figure 9. Observed Prehunt Fawns: 100 Does & Modeled Posthunt Population in PH-3, 1995 - 2019.

Buck: doe ratios A minimum of 20 bucks:100 does is necessary to make sure all does are bred and maximum recruitment of pronghorn into a population generally requires buck: doe ratios of 25:100, which increases production of younger age class animals (Lee et al. 1998). Low hunter crowding and buck: doe ratios of at least 50 bucks: 100 does are the foundation of a quality hunt. The post-hunt buck: doe ratio objective for PH-3 is 30-40 bucks: 100 does. The buck: doe ratio was quite low until 2001 when public demand for older age class bucks increased and buck harvest was reduced. Since then the number of posthunt bucks has increased to 30 or more bucks: 100 does and is consistently above the objective range (Figure 10).

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Figure 10. Observed Prehunt Bucks: 100 Does in PH-3, 1995 - 2019.

The North Park pronghorn herd has been managed for quality buck hunting for many years and part of that quality experience is low hunter numbers and a fair chance at a trophy size animal. However, severely limiting buck hunter opportunity may not provide a significantly higher number of trophy class bucks since they mature early in life and decrease in Boone and

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Crockett score as they age. “Stock piling” bucks for next year simply decreases opportunity and drives up preference points required to draw. Unlike deer or elk that reach peak antler growth in their mid to later years, pronghorn bucks reach maximum horn growth size by 2-4 years of age (Mitchell and Maher 2004). Pronghorn bucks attain adult-sized horns at 2-3 years of age, and these two age classes produce the largest horn measurements by length, basal circumference, widest spread, and symmetry (Mitchell and Maher 2001). Furthermore, horns of bucks 7+ years old are significantly smaller than younger animals (Kitchen and O’Gara 1982). This suggests that managers can manage pronghorn populations for a younger age structure and still provide for maximum yield with trophy quality harvest. Harvest and Licenses The PH-3 population is currently managed to provide a quality hunt through the opportunity to harvest mature bucks, limited doe hunting and reduced hunter crowding. License numbers are manipulated annually to maintain the population size within the objective range. North Park is comprised of significant expanses of high-quality public lands and pronghorn success rates are very good on both public and private lands. License Allocation Hunting licenses in PH-3 are specified both by GMU and by method of take. Licenses are allocated to three distinct geographic areas: GMU 6 is separate, GMU 161 is separate and GMU 16, 17, and 171 are combined. Pronghorn distribution can vary across the DAU as winter severity and habitat conditions change between the units. Drought has probably had some influence in shifting pronghorn to areas with more water and better vegetation. In years with high license numbers there can be problems with pronghorn moving to private land during the hunting season reducing their availability to public land hunters. Ninety percent of harvest typically occurs during the opening weekend of rifle seasons. Licenses are available for rifle, archery and muzzleloader seasons. Archery and muzzleloader licenses are valid for the entire DAU (GMUs 6, 16, 17, 161, and 171), while rifle licenses are specified by GMU. In addition, Silver Spur Ranch participates in the CPW Ranching for Wildlife Program and provides public opportunity for access to high-quality hunts on private land annually. Licenses numbers have declined over the years as success rates increased (Figure 11).

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1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 YEAR Rifle Archery Muzzleloader Total Licenses Linear (Total Licenses) Figure 11. License Numbers by Method of Take in PH-3, 1996 - 2020.

. Preference Points Demand for buck licenses in PH-3 has increased dramatically in recent years. In 2001, the maximum number of preference points required to draw an antlered rifle license was 4 points, and most licenses required only 1 point. In 2019, all antlered licenses in PH-3

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required a minimum of 2 preference points, and the either-sex license valid on Silver Spur Ranching for Wildlife (AE006W1R) required 22 preference points. Trophy harvest, combined with uncrowded, quality hunting opportunities have increased demand for these licenses. Harvest Annual pronghorn harvest in PH-3 has decreased steadily since the mid-1980’s when the population was over objective. As the population decreased and reached objective, then fell below objective, there was a corresponding decrease in license numbers and harvest (Figure 12). Now that the population has recovered to within the objective range, license numbers have begun to increase.

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1999 2016 1995 1996 1997 1998 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2017 2018 2019 YEAR Modeled Population Estimate Population Size Objective Total Licenses Total Harvest

Figure 12. Modeled Posthunt Population Estimate, Harvest and License Numbers in PH-3, 1995 - 2019.

Pronghorn harvest in PH-3 has declined since 1995 as the population has declined. An average of 100 bucks and 75 does and fawns are harvested annually (Figure 13).

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1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 YEAR Bucks Doe & Fawn Total Harvest Figure 13. Pronghorn harvest in PH-3, 1995 - 2019.

Economic Benefits Hunting provides a significant economic contribution to Colorado and to North Park. Hunters in Jackson County spend over 65,000 hunter-days annually pursuing big game, small game, and waterfowl (Southwick Associates 2018). Hunter expenditures in Jackson County on lodging, equipment sales, meals, and supply purchases contribute over $2 million dollars to the county GDP, provide 51 jobs and over $600,000 in state and local taxes (Southwick Associates 2018)

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Past Management Strategies Like all big game DAUs in Colorado, PH-3 is managed under general guidelines set out every five years in statewide Big Game Season Structure (BGSS). For a further explanation of BGSS, see INTRODUCTION AND PURPOSE. Under the BGSS, the complexity of license structure in PH- 3 has increased somewhat over the years in response to the progressively more complex management issues facing this herd and pronghorn across the state of Colorado. Generally, license numbers are managed more intensively and are less liberal in recent years as the pronghorn population size has decreased and buck harvest quality and demand for licenses have increased. Additionally, muzzleloader and archery licenses were not limited until the late 2000’s. Prior to 2007, muzzleloader licenses were unlimited and included in the Over-the-Counter (OTC) statewide license. Rifle licenses required a minimum of six preference points and there was a real issue of unequitable opportunity. In 2007, a regulation was approved by the Parks & Wildlife Commission to limit all muzzleloader licenses in PH-3. Prior to 2009, archery licenses were unlimited and included in the Over-the-Counter (OTC) statewide license. Rifle licenses required a minimum of seven preference points and again there was a real issue of unequitable opportunity. In 2009, a regulation was approved by the Parks & Wildlife Commission to limit all archery licenses in PH-3.

Current Issues Balancing Trophy Management and Hunting Opportunity The main issue brought up by meeting attendees is the long wait and difficulty in drawing pronghorn licenses in PH-3 because those folks want to hunt more often. See APPENDIX III: PUBLIC SURVEY & RESULTS for the full text of written public comments. The balance between hunting opportunity and high quality harvest could be optimized by balancing the number of licenses in relation to the population’s ability to produce young but physically mature bucks. In order to achieve this certain metrics of hunter-harvested bucks would need to be known such as age and horn measurements. Hunters could submit teeth of harvested animals for aging along with simple horn measurements of bucks. Disease There have not been any significant known disease issues in PH-3. Epizootic hemorrhagic disease (EHD) and blue tongue virus (BTV) are transmitted by biting midges and have been implicated in large scale pronghorn and deer die offs in western states but such events have not been detected in North Park. Although chronic wasting disease (CWD) is known to occur in all game management units in PH-3 in deer, elk, and moose, CWD has never been detected in pronghorn.

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PUBLIC INVOLVEMENT In order to gather public input on pronghorn management in PH-3 several multiple methods were employed ranging from soliciting ideas from individuals to public meetings to comments via the CPW website (APPENDIX II: PUBLIC MEETINGS ANNOUNCEMENT and APPENDIX III: PUBLIC SURVEY & RESULTS). Public meetings were held in Walden on July 14, 2017 and in Fort Collins on July 17, 2017 to obtain comments on both deer and pronghorn management in North Park. Local and state agricultural groups, sportsmen, government agencies, and citizens were notified of the meetings and other opportunities to provide input through local media, mailings, the CPW website, and direct contact by CPW employees. Public attendance at the Walden meeting consisted of four individuals representing a mix of sportsmen, business owners, agency personnel, and local media. Public attendance at the Fort Collins meeting consisted of two individuals representing sportsmen and landowners. A public survey (APPENDIX III: PUBLIC SURVEY & RESULTS) was provided on the internet and to those attending public meetings. From the questionnaires and issues brought up and documented at the public meetings the following were identified as being important to North Park pronghorn management. In addition to the questionnaires turned in at public meetings a total of five questionnaires were returned by mail mostly from those who read the plan on the CPW website. The main issue brought up by meeting attendees is the long wait and difficulty in drawing pronghorn licenses in PH-3.

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PREFERRED ALTERNATIVES AND NEW OBJECTIVES

Three post-hunt population objective ranges were considered: (1) decrease from the current objective to 1,200–1,400 pronghorn, (2) an objective of 1,400–1,600 pronghorn similar to the current objective of 1,500-1,600, (3) increase the objective to 1,600-1,800 pronghorn. Three post-hunt sex ratio objectives were considered: (1) 20-30 bucks:100 does to maximize recruitment, (2) 30-40 bucks:100 does which would allow good recruitment and trophy potential, or (3) 40-50 bucks:100 does to maximize trophy production.

The majority (60%) of public comments preferred the current population and sex ratio objectives of 1,400 –1,600 pronghorn and 30-40 bucks: 100 does. There is significant concern among hunters about more hunting opportunity and less wait time to draw licenses. Consequences of increasing licenses in order to make it easier for hunters to draw a license are that; when the population is near the lower end of the objective too much doe harvest will lower the population below the objective and too much buck harvest will reduce the buck: doe ratio under the objective. If the population is above the upper end of the objective a substantially higher number of licenses will be required to lower the population and hunt quality will be diminished. Future management will focus on license numbers that maximize opportunity on does during good production years when the herd is within the population objective range and minimizing harvest when below objective. Buck harvest should be set to manage toward the lower end of the sex ratio objective range to provide increased hunter opportunity when compared to managing for the upper end of the objective range. This buck harvest strategy will allow for good herd production and still provide ample numbers of quality two-three year old bucks for hunters.

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LITERATURE CITED Bartmann RM, White GC, Carpenter LH. 1992. Compensatory Mortality in a Colorado Mule Deer Population. Wildlife Monographs. 121:3–39.

Beale DM, Smith AD. 1970. Forage Use, Water Consumption, and Productivity of Pronghorn Antelope in Western Utah. Journal of Wildlife Management. 34(3):570–582.

Bishop CJ, White GC, Freddy DJ, Watkins BE, Stephenson TR. 2010. Effect of Enhanced Nutrition on Mule Deer Population Rate of Change. Effect of Enhanced Nutrition on Mule Deer Population Rate of CHange. 172:1–28.

Bristow KD, Dubay SA, Ockenfels RA. 2006. Correlation between free water availability and pronghorn recruitment. In: Managing Wildlife in the Southwest. South-west Section of The Wildlife Society. Tucson, AZ: Southwest Section of The Wildlife Society. p. 55–62.

Kitchen DW, O’Gara BW. 1982. Pronghorn (Antilocapra americana). In: Wild mammals of North America: biology, management, economics. Baltimore, MD, USA: John Hopkins University Press. p. 960–971.

Lee RM, Yoakum JD, O’Gara BW, Pojar TM, Ockenfels RA. 1998. Pronghorn management guides : biological and management principles and practices to sustain pronghorn populations and habitat from Canada to Mexico. In: Proceedings of the 18th Pronghorn Antelope Workshop. Prescott: AZ.

Mitchell CD, Maher CR. 2001. Are Horn Characteristics Related to Age in Male Pronghorns? Wildlife Society Bulletin. 29(3):908–916.

Mitchell CD, Maher CR. 2004. 21st Biennial Pronghorn Workshop. In: Selection for early horn growth in pronghorn (Antilocapra americana) males. Bismarck, North Dakota, USA: Western Association of Fish and Wildlife Agencies. p. 54–63.

Pojar TM, Guenzel RJ. 1999. Proceedings of the Biennial Pronghorn Antelope Workshop. In: Comparison of fixed-wint line transect and helicopter quadrat pronghorn surveys.

Southwick Associates. 2018. Economic Contributions of Outdoor Recreation in Colorado: A Regional and County-Level Analysis. , CO, USA: Colorado Parks & Wildlife.

Sundstrom C. 1973. Abundance, Distribution and Food Habits of the Pronghorn. Cheyenne: Wyoming Game and Fish Commission.

Warren ER. 1942. Mammals of Colorado, Their Habits and Distribution. Norman, OK: University of Oklahoma Press.

White G, Lubow B. 2002. Fitting Population Models to Multiple Sources of Observed Data. Journal of Wildlife Management. 66(2):300 – 309.

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APPENDIX I: POPULATION DYNAMICS, MAXIMUM SUSTAINED YIELD, AND DENSITY DEPENDENCE Numerous studies of animal populations, including bacteria, mice, rabbits, and white-tailed deer have shown that the populations grow in a mathematical relationship referred to as the "sigmoid growth curve" (Figure 14). There are three distinct phases to this cycle. The first phase Sigmoid Growth Curve occurs while the population level is still very low 10,000 and is characterized by a slow growth rate and a high mortality rate. This occurs because the populations may have too few animals and the loss 8,000 of even a few of them to predation or accidents can significantly affect population growth. 6,000 The second phase occurs when the population number is at a moderate level. This phase is 4,000 characterized by high reproductive and survival rates. During this phase, food, cover, water and Animals of Number space are not a limiting factor. During this phase, 2,000 for example, animals such as white-tailed deer have been known to successfully breed at six 0 months of age and produce a live fawn on their 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 first birthday and older does have been known to Year produce 3-4 fawns that are very robust and healthy. Figure 14. Sigmoid Growth Curve. Survival rates of all sex and age classes are also at maximum rates during this phase. The final or third phase occurs when stocking rate increases causing the habitat to become crowded or habitat conditions become less favorable. During this phase the quantity and quality of food, water, cover and space become scarce due to the competition with other members of the population. These types of factors that increasingly limit productivity and survival at higher population densities are known as density-dependent effects. During this phase, for example, white-tailed deer fawns can no longer find enough food to grow to achieve a critical minimum weight that allows them to reproduce; adult does will usually only produce 1-3 fawns; and survival of all deer (bucks, does and fawns) will decrease. During severe winters, large die-offs can occur due to the crowding and lack of food. The first to die during these situations are fawns, then bucks, followed by adult does. Severe winters affect the future buck to doe ratios by favoring more does and fewer bucks in the population. Also, because the quality of a buck's antlers is somewhat dependent upon the quantity and quality of his diet, antlers development is diminished. If the population continues to grow it will eventually reach a point called "K" or the maximum carrying capacity. At this point, the population reaches an "equilibrium" with the habitat. The number of births each year equal the number of deaths, therefore, to maintain the population at this level would not allow for any "huntable surplus." The animals in the population would be in relatively poor body condition, habitat condition would be degraded from over-use, and when a severe winter or other catastrophic event occurs, a large die-off is inevitable. What does all this mean to the management of Colorado's big game herds? It means that if we attempt to manage for big game herds that are at high stocking rates they are being limited by density-dependent effects, we should attempt to hold the populations more towards the middle of the "sigmoid growth curve." Biologists call this point of inflection of the sigmoid growth curve the point of "MSY" or "maximum sustained yield." In the example below, MSY, which is approximately half the maximum population size or "K", would be 5,000 animals. At this level, the population should provide the maximum production, survival, and available surplus animals for hunter harvest. Also, at this level, range habitat condition should be good to excellent and range trend should be stable to improving. Game damage problems should be lower and economic return to

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the local and state economy should be higher. This population level should produce a "win - win" situation to balance sportsmen and private landowner concerns. A graph of a hypothetical deer population showing sustained yield (harvest) potential vs. population size is shown (Figure 15). Notice that as the population increases from 0 to 5,000 deer, the harvest also increases. However, when the population reaches 5,000 or "MSY", Maximum Sustained Yield food, water and cover becomes scarce and the harvest potential decreases. Finally, when the 1,600 population reaches the maximum carrying 1,400 capacity or "K" (10,000 deer in this example), the harvest potential will be reduced to zero. 1,200 Also, notice that it is possible to harvest 1,000

exactly the same number of deer each year 800

with 3,000 or 7,000 deer in the population. Sustained Yield This phenomenon occurs because the 600 population of 3,000 deer has a much higher 400 survival and reproductive rate compared to the 200 population of 7,000 deer. However, at the 0 3,000 deer level, there will be less game 0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000 9,000 10,000 damage and resource degradation but lower Population Size watchable wildlife values. Figure 15. Maximum Sustained Yield. Managing deer and elk populations for MSY on a DAU basis is difficult if not impossible due to the amount of detailed biological information about habitat and population size required. Additionally, carrying capacity is not static, the complex and dynamic nature of the environment cause carrying capacity to vary seasonally, annually, and trend over time. In most cases we would not desire true MSY management even if possible because of the potential for overharvest and the number of mature of bulls and bucks is minimized because harvest reduces recruitment to older age classes. However, the concept of MSY is useful for understanding how reducing densities and pushing asymptotic populations towards the inflection point can stimulate productivity and increase harvest yields. Knowing the exact point of MSY is not necessary if the goal is to conservatively reduce population size to increase yield. Long-term harvest data is a gauge of the effectiveness of reduced population size on harvest yield. Several studies in Colorado have shown that density-dependent winter fawn survival is the mechanism that limits mule deer population size because winter forage is limiting (Bartmann et al. 1992; Bishop et al. 2010) . Adult doe survival and reproduction remain high but winter fawn survival is lower at higher population sizes relative to what the winter habitat can support. The intuition to restrict, or even eliminate, female harvest in populations where productivity is low and when populations are below HMP objectives is counterproductive and creates a management paradox. In that, for populations limited by density dependent processes, this “hands-off” type of management simply exacerbates and perpetuates the problem of the population being resource limited, and countermands the goals and objectives of the HMP. As (Bartmann et al. 1992) suggest, because of density-dependent processes, it would be counterproductive to reduce female harvest when juvenile survival is low and increase harvest when survival is high. Instead, a moderate level of female harvest helps to maintain the population below habitat carrying capacity and results in improved survival and recruitment of fawns. Increased fawn recruitment allows for more buck hunting opportunity and a more resilient population, as half of fawns recruited to adults are bucks. Thus, the key for Herd Management Planning and management by objective is to set population objectives in line with what the limiting habitat attributes can support. A suitable population objective range must be below carrying capacity.

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APPENDIX II: PUBLIC MEETINGS ANNOUNCEMENT Have a question or comment about North Park deer and pronghorn herds? Now is your chance to let CPW know. STEAMBOAT SPRINGS, Colo.- In continuing efforts to offer the public a convenient way to work with Colorado Parks and Wildlife's managers and biologists, the agency will host two herd management meetings in July, one in Walden and another in Ft. Collins. The gatherings will give citizens the opportunity to express their preferences as the agency forms future management strategies for mule deer and pronghorn herds in North Park. The first gathering will take place in Walden, July 14, 6:30 p.m., at the U.S. Forest Service office, 100 Main Street. The second opportunity will take place July 17, 6:30 p.m., in the Harmony Library at Community College, 4616 S. Shields Street in Ft. Collins.

Approximately every 10 years, CPW updates management strategies for the state's big game species. Known as Data Analysis Unit, or DAU plans, they are the blueprints establishing overall big game population objectives, including the goals for male-female ratios within those populations. "Science and biology are the cornerstones of responsible wildlife management, but the public's input is very important," said Jeff Yost, terrestrial biologist for the Steamboat Springs area. "It is very difficult to manage wildlife without the participation our citizens, whether they are hunters, wildlife watchers, landowners, business owners or land management agencies, we encourage everyone to get involved in the management of their natural resources." CPW manages deer populations in North Park in accordance with the DAU D-3 plan, including Game Management Units 6, 16, 17, 161 and 171. Pronghorn fall under DAU PH-3 plan, including Game Management Units 6, 16, 17, 161 and 171. For more information about DAU plans, visit the CPW website. During each meeting, managers will present several management alternatives, including increasing or decreasing overall herd size and male-female ratios, or leaving the populations and gender ratios at their current levels. "Some of the questions and discussion will focus on whether the public wants larger herds for increased opportunity or managing for bigger bucks but with less hunting opportunity," said Yost. "In some cases, the public may prefer larger herd to help with tourism, hunters may want larger bucks but with less opportunity, and landowners concerned about game damage will have their own concerns. We look forward to a lively discussion."

Walden Meeting Date: Friday, July 14, 2017 Location: US Forest Service Building Conference Room 100 Main Street, Walden 6:30 p.m. - 8

Ft. Collins Meeting Date: Monday, July 17, 2017 Location: Front Range Community College, Harmony Library - Community Room (H) 4616 S Shields Street Meeting Time: 6:30 p.m. - 8

For more information, contact Steamboat Springs Area Biologist Jeff Yost at 970-871-2843.

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APPENDIX III: PUBLIC SURVEY & RESULTS

OPPORTUNITY FOR PUBLIC COMMENT ON PRONGHORN MANAGEMENT IN NORTH PARK, COLORADO

DATA ANALYSIS UNIT (DAU) PH-3 GAME MANAGEMENT UNITS 6, 16, 17, 161, 171 July-August 2017

Colorado Parks and Wildlife is currently updating pronghorn management plans for North Park and is requesting your input. Your opinion can help shape the future of pronghorn management in this area. Please fill out the following questionnaire and mail or return it to:

COLORADO PARKS AND WILDLIFE DAU PLAN COMMENTS PO Box 775777 STEAMBOAT SPRINGS, COLORADO 80477

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QUESTIONAIRE - PRONGHORN DAU PLAN PH-3 NORTH PARK COMMENTS MUST BE RECEIVED BY AUGUST 18, 2017

Survey results will be included in the finalized plan and posted on the CPW website http://cpw.state.co.us/ pending plan approval by the Colorado Parks and Wildlife Commission

Please answer the following questions regarding Pronghorn management specific to DAU PH-3, North Park Game management Units 6, 16, 17, 161, and 171 by placing an X in the appropriate space next to your chosen answer mark all that apply.

Please mark all that apply.

1) Meeting Attended: __2_ Internet Only – did not attend a meeting __4_ Walden – July 14, 2017 __2_ Fort Collins - July 17, 2017

2) Are you? __2_ Landowner ____ Livestock Operator ____ North Park Business Owner ____ North Park Guide/Outfitter __3_ Hunter __4_ Viewer __4_ Resident ____ Non Resident

3) Have you experienced or have knowledge of any of the following caused by pronghorn in North Park? If so explain. ____ Habitat damage ____ Crop damage ____ Competition with livestock

4) Do you primarily hunt bucks or does? ___2_Buck Hunter ___1_Doe hunter

5) If you are a buck hunter are you more interested in buck hunting opportunity (drawing tags more often) or harvesting a trophy? ___4_Opportunity _____Trophy

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6) Which opportunity is most important to you? ___1_Hunting pronghorn regardless if it is a buck or a doe _____Hunting for a trophy buck even if it means waiting 5-10 years or more to hunt? ___3_Hunting more often with less chance at a trophy buck

7) Rank which experience is more important to you (3=highest, 1=lowest) ___6_Having the opportunity to hunt pronghorn as often as possible ___3_Spending time with family, friends, or alone in the field ___3_A high quality experience without feeling crowded by other hunters

8) If successful in drawing a pronghorn license for PH-3 are you willing to send in a tooth from your harvested animal for aging? ___4_Yes _____No

9) If successful in drawing a BUCK pronghorn license for PH-3 are you willing to take some simple measurements of horn length, spread, and circumference and send in the measurements from your harvested animal? ___4_Yes _____No

10) If successful in drawing a pronghorn license for PH-3 are you willing to participate in a hunt satisfaction survey to help us evaluate your experience? ___4_Yes _____No

11) If you drew a license for PH-3 which method would you prefer for submitting information on buck horn measurements or hunt satisfaction surveys? ___4_ Electronic entry form - Internet submission ___1_Paper form - Mail in

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PREFERRED ALTERNATIVE 12) Of the options presented for the total post-hunt pronghorn Population objective which do you prefer? __1_ 1. 1,200–1,400 pronghorn - A decrease from the current objective. __3_ 2. 1,400-1,600 pronghorn - Similar to the current objective. __1_ 3. 1,600-1,800 pronghorn – An increase the current objective.

13) Of the options presented for the post-hunt pronghorn Sex Ratio objective which do you prefer? Sex Ratio Objective Alternatives (Post-Season Observed) ___2_ 1. Sex Ratio of 20-30 bucks:100 does to maximize recruitment into the population keeping the age ratios lower with fewer trophy bucks ___3_ 2. The current Sex Ratio of 30-40 bucks:100 does to allow for good recruitment and provide good trophy potential _____3. Increase Sex Ratio to 40-50 bucks:100 does to maximize trophy production

ADDITIONAL WRITTEN COMMENTS In the space provided please write down any addition thoughts, comments, or suggestions pertinent to pronghorn management in North Park. (Use back if necessary)

1. Thanks for holding the informative and well-presented meeting. Wish more people had attended, but happy that I did.

2. I am not a hunter. I enjoy wildlife viewing. I see hunting licenses at my place of employment. I want to be knowledgeable to assist hunters. Thank you for the presentation.

3. Hunting antelope bucks in North Park, with a rifle, is turning into a once-in-a-lifetime opportunity! I think this is very unfortunate with the relatively large number of antelope bucks in North Park! More hunters will still result in acceptable harvest percentages, with the best hunters still being able to harvest trophy size bucks, and the non-trophy hunters and poorer hunters will still have opportunity for a successful buck hunt, which may or may not include the harvesting of a buck. It is impossible to have a “successful buck hunt”, when you can’t obtain a license!

4. Jeff, Thanks for the informative presentation!

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APPENDIX IV: HPP COMMENT LETTER

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