Special Recreation Permit Administration and Predator Hunting Contests

UNITED STATES DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
WASHINGTON, D.C. 20240
http://www.blm.gov/

June 18, 2014

In Reply Refer To: 

2930 (250) P

EMS TRANSMISSION 06/25/.2014

Instruction Memorandum No. 2014-105

Expires: 09/30/2015

To:                   All Washington Office and Field Office Officials

From:               Assistant Director, Resources and Planning

Subject:           Special Recreation Permit Administration and Predator Hunting Contests

Program Area:  Recreation and Visitor Services

Purpose:  The purpose of this Instruction Memorandum (IM) is to re-emphasize agency requirements for the administration of special recreation permits for commercial, competitive use, and organized group activities and events, including predator hunting contests.

Policy/Action: Officials are directed to 43 CFR Part 2930, the BLM Manual 2930, and the H-2930-1 Recreation Permit Administration Handbook.

The Bureau of Land Management (BLM) is committed to enforcing the 43 CFR 2932 regulations to their fullest extent.  For any group of events, including predator hunting contests, it is impossible to make a blanket determination on whether or not a special recreation permit (SRP) is required.  Each event is different and is analyzed as a unique place and time-based individual event, not as a category of use.  The SRPs are a discretionary action and are issued out of the local BLM offices in which recreational activities occur.  Once an application is filed and it is determined an SRP is needed, a National Environmental Policy Act review would follow.  Offices may want to consider a programmatic approach if multiple events/applications are expected.

In evaluating predator hunting or similar events of this type, several factors will determine whether or not an SRP is required.  These include advertising or promoting the use of public lands while charging an entry fee that is not an equal sharing of expenses; a person, group, or organization attempting to make a profit from participants; or awarding of cash prizes.

The narrow exemption criteria for waiving SRP fees found at 43 CFR 2932.34 should be strictly adhered to, as well as the criteria for waiving the requirement to obtain a permit, found at 43 CFR 2932.12.

Based on the unique characteristics of each event, if a determination is made that an SRP is required but not enough time is available to process, organizers should be informed that use of public lands is not authorized.  Organizers should also inform their participants of that exclusion.  Field officials should monitor the public lands for unauthorized activities to the extent practicable.

Timeframe:  Effective immediately.

Budget Impact:  Processing SRPs is a routine function of the field office recreation workload and paid for by base funding.  Offices should refer to guidance for cost-recovery collection, if applicable (for permit processing and monitoring in excess of 50 hours of staff time).

Background:  The BLM issues SRPs as a means to manage visitor use, protect natural and cultural resources, achieve the goals and objectives of the field office recreation program as outlined in a land use plan, and to provide for the health and safety of visitors.  Commercial SRPs are also issued as mechanisms to provide a fair return to the United States for the commercial recreational use of public lands. 

More than 98 percent of public lands are open to hunting and the BLM works in partnership with state game and fish agencies, the primary entities responsible for hunting regulations (both seasons and species).   

In no way is this policy intended to interfere or impinge upon states’ rights when it comes to the permitting and regulation of hunting.  This policy is intended to cover those events and activities taking place on public lands that are competitive or commercial in nature, regardless of the activity being engaged in.

Manual/Handbook Sections Affected:  None.

Coordination:  Development of this IM was coordinated between the Division of Recreation and Visitor Services (WO-250) and the deputy state directors.

Contact:  Any questions or concerns regarding this policy, please contact Andy Tenney, Division Chief, Recreation and Visitor Services by email at atenney@blm.gov, or by telephone at 202-912-7094, or David Ballenger, Outdoor Recreation Planner by email at dballeng@blm.gov, or by telephone at 202-912-7642.

Signed by:                                                       Authenticated by:

Edwin L. Roberson                                         Robert M. Williams

Assistant Director                                           Division of IRM Governance,WO-860

Resources and Planning

1 Attachment

       1 – Special Recreation Permits for Predator Hunting Contests - Questions and Answers (5pp.)