Performance audit, Arizona Game and Fish Commission and Department, Wildlife Management Program

              State of Arizona
Office
of the
Auditor General
PERFORMANCE AUDIT
WILDLIFE MANAGEMENT
PROGRAM
Report to the Arizona Legislature
By Debra K. Davenport
Auditor General
ARIZONA
GAME AND FISH
COMMISSION AND
DEPARTMENT
May 2001
Report No. 01-08
The Auditor General is appointed by the Joint Legislative Audit Committee, a bipartisan committee
composed of five senators and five representatives. Her mission is to provide independent and impar-tial
information and specific recommendations to improve the operations of state and local government
entities. To this end, she provides financial audits and accounting services to the state and political
subdivisions and performance audits of state agencies and the programs they administer.
The Joint Legislative Audit Committee
Senator Ken Bennett, Chairman
Representative Roberta L. Voss, Vice-Chairman
Senator Herb Guenther Representative Robert Blendu
Senator Dean Martin Representative Gabrielle Giffords
Senator Tom Smith Representative Barbara Leff
Senator Randall Gnant (ex-officio) Representative James Sedillo
Representative James Weiers (ex-officio)
Audit Staff
Melanie Chesney—Manager
and Contact Person (602) 553-0333
Natalie Coombs—Team Leader
Cathleen Akers—Team Member
Nancy Cameron—Team Member
Jay De Pree—Team Member
Copies of the Auditor General’s reports are free.
You may request them by contacting us at:
Office of the Auditor General
2910 N. 44th Street, Suite 410
Phoenix, AZ 85018
(602) 553-0333
Additionally, many of our reports can be found in electronic format at:
www.auditorgen.state.az.us
2910 NORTH 44th STREET • SUITE 410 • PHOENIX, ARIZONA 85018 • (602) 553-0333 • FAX (602) 553-0051
DEBRA K. DAVENPORT, CPA
AUDITOR GENERAL
STATE OF ARIZONA
OFFICE OF THE
AUDITOR GENERAL
WILLIAM THOMSON
DEPUTY AUDITOR GENERAL
May 9, 2001
Members of the Arizona Legislature
The Honorable Jane Dee Hull, Governor
Mr. Duane Shroufe, Director
Arizona Game and Fish Department
Transmitted herewith is a report of the Auditor General, A Performance Audit of the Arizona
Game and Fish Commission and Department—Wildlife Management Program. This report
is in response to a June 16, 1999, resolution of the Joint Legislative Audit Committee. The
performance audit was conducted as part of the Sunset review set forth in A.R.S. §41-2951 et
seq. I am also transmitting with this report a copy of the Report Highlights for this audit to
provide a quick summary for your convenience.
As outlined in its response, the agency agrees with all of the findings and recommendations.
My staff and I will be pleased to discuss or clarify items in the report.
This report will be released to the public on May 10, 2001.
Sincerely,
Debbie Davenport
Auditor General
Enclosure
OFFICE OF THE AUDITOR GENERAL
Program Revenue: $41,360,600
(fiscal year 2001, estimated)
$0
$10,000,000
$20,000,000
$30,000,000
$40,000,000
$50,000,000
1999 2000 2001 (est.)
Other
Earnings on investments
Lottery proceeds
Intergovernmental
Licenses and permits
Program Fact Sheet
Arizona Game and Fish Commission
and Department
Wildlife Management Program
Services: The Wildlife Management Program, which consists of Game Management, Non-game
and Endangered Wildlife, and Sportfish Management, offers the following services: 1)
Providing wildlife hunting and recreational opportunities to the public; 2) Assessing habitat
conditions and enforcing regulations to conserve and restore nongame and endangered wild-life
populations; 3) Producing, stocking, and maintaining sportfish in Arizona lakes and
streams; 4) Issuing hunting and fishing licenses and tags; and 5) Providing wildlife education
programs to the public.
Personnel: 543.5 (fiscal year 2001)
Sportfish Management
subprogram (199)
Game Management
subprogram (238)
Nongame and Endangered
Wildlife subprogram (106.5)
Facilities:
Wildlife Management Program Mission:
“To provide fish and wildlife benefits and
compatible public uses through diverse and
cooperative wildlife management, while
avoiding adverse impacts to habitat. To pro-tect
wildlife populations, habitats, and public
safety, and to increase public awareness and
understanding of wildlife resources and the
Department.”
PHOENIX
 
OFFICE OF THE AUDITOR GENERAL
Summary of Program Goals (fiscal years
2000-2001):
1. To maintain and/or restore the natural
diversity of Arizona’s game, nongame,
and endangered wildlife populations.
2. To maintain or enhance distribu-tion/
abundance of cold and warm water
sportfish.
3. To increase public awareness of Ari-zona’s
sportfishing resources and non-game
and endangered fish and wildlife.
4. To provide recreational opportunities.
Adequacy of Performance Measures:
The Wildlife Management Program’s 18 per-formance
measures appear to be reasonably
aligned with its mission and goals. How-ever,
the Program currently does not have
performance measures to address all aspects
of its subprograms’ mission statements. For
example, new performance measures are
needed to address:
  Game-wildlife habitat and diversity un-der
the Game Management subprogram;
  Non-game wildlife and fish habitat and
recreational opportunities under the
Nongame and Endangered Wildlife
subprogram; and
  Distribution, abundance, and diversity of
cold and warm water sportfishes and
their habitats under the Sportfish Man-agement
subprogram.
Trucks worth approxi-mately
$8.9 million
Radios worth approxi-mately
$1.3 million
Boats worth approxi-mately
$1.2 million
Trailers worth approxi-mately
$863,000
Tractors worth approxi-mately
$561,000
Aircraft worth approxi-mately
$399,000.
Equipment:
The Wildlife Management Program’s assets
total more than $75.6 million. Included in
this amount are the Program’s six largest as-sets:
Other assets: all-terrain vehicles, generators,
guns, microscopes, snowmobiles, and tools.
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OFFICE OF THE AUDITOR GENERAL
SUMMARY
The Office of the Auditor General has conducted a Sunset review
of the Arizona Game and Fish Commission and Department and
a performance audit of the Arizona Game and Fish Depart-ment’s
Wildlife Management Program pursuant to a June 16,
1999, resolution of the Joint Legislative Audit Committee. This
audit was conducted as part of the Sunset review set forth in
Arizona Revised Statutes §41-2951 et seq. This Sunset review of
the Commission and Department was conducted in conjunction
with a separate performance audit of the Commission Heritage
Fund (Auditor General Report No. 01-09). The Heritage Fund
provides a substantial amount of revenue to the Wildlife Man-agement
Program and these monies are used to support a num-ber
of activities, including endangered species protection and
reintroduction efforts. Although the Heritage Fund itself is not
subject to Sunset laws, Heritage Fund management is a critical
Department function and was assessed as part of this Sunset au-dit.
Therefore, this report includes information about the Heri-tage
Fund in the Sunset Factors (see pages 25 through 34).
The Arizona Game and Fish Department (Department) and
Commission were established in 1929 to set hunting and fishing
regulations and manage wildlife. The Commission oversees the
Department and is responsible for setting wildlife regulations
and policies. The Department implements Commission policies
and carries out day-to-day activities such as wildlife manage-ment
and research, law enforcement, and public information and
education.
This audit includes two findings, one with recommendations di-rected
toward the Legislature, and the other with recommenda-tions
to improve Department operations.
Summary
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OFFICE OF THE AUDITOR GENERAL
Specific Decisions Needed to
Help Address Elk Population
and Habitat Concerns
(See pages 9 through 17)
Because no single agency is responsible for managing both elk
population numbers and habitat in Arizona, conflicts arise over
the number of elk the Department manages in the State, and the
impact those animals have on lands owned and managed by
others. Higher elk numbers can lead to increased hunting oppor-tunities
and license revenues. However, elk numbers concern
ranchers because elk compete with cattle for available forage, or
food, on federal, state, and private lands. In addition, when for-age
conditions are poor, the U.S. Forest Service, which manages
most elk habitat in Arizona, can reduce or eliminate cattle on
Forest lands, but cannot influence wildlife numbers. Private
landowners also have concerns because elk can damage fences
and crops.
Efforts by various interest groups to resolve these inherent con-flicts
have not yet resulted in a comprehensive approach for
managing forage resources. Consequently, the Legislature
should consider formally bringing together key decision-makers
from all interest groups, and charging them with addressing
critical problems and reaching consensus on specific decisions
needed to manage the issues. This task force’s activities should
include:
  Developing comprehensive forage management plans that
establish forage use objectives for wildlife and cattle in sum-mer
and winter habitats, and during drought conditions;
  Establishing forage measurement and monitoring methods
that are acceptable to both land managers and the Depart-ment;
  Forging agreements for actions to take when there is insuffi-cient
forage;
  Developing a mechanism for cooperatively identifying areas
that may need time to recover from either livestock or wild-
Summary
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OFFICE OF THE AUDITOR GENERAL
life use, and establishing responsibility for rehabilitating
those areas; and
  Recommending to the Legislature appropriate tools to ad-dress
depredation on private property, and feasible methods
for addressing competition for forage between livestock and
wildlife on federal and state trust lands.
Department Needs to Better
Manage Dealer License Sales
(See pages 19 through 24)
The Department needs to better manage retail sales of hunting
and fishing licenses to ensure that it collects all monies owed to it
in a timely manner. Retail sales of hunting and fishing licenses
and hunting tags are a critical source of revenue for the Depart-ment,
generating approximately 23 percent of its $41 million
Wildlife Management Program budget. However, the Depart-ment’s
procedures for managing retail, or license dealer sales, are
inadequate in the following areas:
  Recordkeeping—The Department lacks comprehensive,
readily available information about the amount license deal-ers
owe or have paid the Department, and whether dealers
have met statutory deadlines for reporting sales and return-ing
unsold expired licenses. Further, the information the De-partment
has is often conflicting. For example, depending on
which of the billing records auditors reviewed for one dealer,
he owed either $171 or $266. However, a manual payment
log shows this dealer has a “zero balance,” but does not indi-cate
how much was paid or when. To resolve these prob-lems,
the Department needs to develop a single source of ac-cessible,
up-to-date payment and billing information.
  Year-end dealer audits—The Department audits dealers
annually to ensure that they pay for or return all licenses is-sued
to them for sale. However, the Department allows some
dealers to delay making final payments for months. For ex-ample,
one dealer who owed $10,000 in January 1999 was al-lowed
to delay paying in full for eight months. To help en-sure
prompt reporting on both a monthly basis and at year-
Summary
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OFFICE OF THE AUDITOR GENERAL
end, the Department should seek enforcement options, such
as penalties and late fees.
  Collections—When dealers do not pay, the Department is
sometimes slow to initiate collection efforts. For example, one
dealer should have returned approximately $9,500 worth of
licenses in January 1999. The dealer did not respond to an
April 1999 request for payment, but the Department let seven
months pass before sending a follow-up letter. In the mean-time,
the Department sent this dealer licenses to sell for the
next license year, which the dealer also failed to return. When
the Department finally initiated collections action in April
2000, this dealer owed more than $15,600. To ensure timely
collections in the future, the Department needs to establish a
time frame for initiating collections action efforts against
dealers who fail to return licenses or report sales, improve its
ability to identify these dealers, and initiate collection actions
in a timely manner.
Sunset Factors
(See pages 25 through 34)
The Sunset Factors include some additional recommendations to
improve Department operations, and also assess the Depart-ment’s
management of the Game and Fish Heritage Fund. The
Heritage Fund provides substantial revenues to the Department
to fund a variety of wildlife-related activities and projects. Con-sequently,
the Department’s management of the Fund is as-sessed
in the Sunset Factors, even though the Fund itself is not
subject to Sunset laws (see also Auditor General Report No. 01-
09).
Recommendations to improve other Department operations in-clude
a listing of rules the Department should develop to help it
better implement wildlife management, and off-highway vehicle
and watercraft statutes. Also, the Department needs to ensure
that it fully complies with its current administrative rule for issu-ing
licenses to retail sales outlets in a timely manner.
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OFFICE OF THE AUDITOR GENERAL
TABLE OF CONTENTS
Page
Introduction and Background........................... 1
Finding I: Specific Decisions Needed
to Help Address Elk
Population and Habitat Concerns................ 9
Competing Interests Lead
to Conflicts over Elk............................................................... 10
Despite Efforts of Department
and Others, Key Issues
Still Not Resolved ................................................................... 11
Recommendations.................................................................. 17
Finding II: Department Needs to
Better Manage Dealer
License Sales ................................................. 19
License Dealers Generate
Significant Revenues.............................................................. 19
Efforts to Manage Retail Sales and
Collect Revenue Are Inadequate........................................ 20
Recommendations.................................................................. 24
Sunset Factors.................................................... 25
Table
Table 1 Arizona Game and Fish Department
Wildlife Management Program
Statement of Revenues and Expenditures
Years Ended or Ending June 30, 1999,
2000, and 2001 (Unaudited)............................. 6
Table of Contents
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OFFICE OF THE AUDITOR GENERAL
TABLE OF CONTENTS (Concl’d)
Page
Figure
Figure 1 Elk Habitat Ownership
(Estimated)........................................................... 12
Photos
Photo 1: Black-footed Ferret............................................. 3
Photo 2: Rocky Mountain Elk.......................................... 9
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OFFICE OF THE AUDITOR GENERAL
INTRODUCTION AND BACKGROUND
The Office of the Auditor General has conducted a Sunset review
of the Arizona Game and Fish Commission and Department and
a performance audit of the Arizona Game and Fish Depart-ment’s
Wildlife Management Program pursuant to a June 16,
1999, resolution of the Joint Legislative Audit Committee. This
audit was conducted as part of the Sunset review set forth in
Arizona Revised Statutes (A.R.S.) §41-2951 et seq.
In the early 1880s the Territorial Legislature established the Ari-zona
Fish Commission in response to growing concerns over the
unrestricted depletion of wildlife. The Arizona Fish Commission
initially consisted of three commissioners charged with enforcing
the few existing conservation laws as well as stocking desirable
species of fish. At the time, the Territorial Legislature established
fishing and hunting laws, as well as seasons and harvest limits.
As these laws grew more complex, it became apparent that the
State needed a specialized agency with the authority to establish
hunting and fishing regulations and manage wildlife. Conse-quently,
in 1929, the Legislature established the present-day Ari-zona
Game and Fish Department (Department) and Commis-sion.
Arizona Game and Fish Commission
and Department Responsibilities
The Arizona Game and Fish Commission is the oversight body
responsible for setting regulations and policies designed to pro-vide
Arizona’s citizens with quality hunting, fishing, and wild-life-
related recreational activities. The Department implements
the Commission’s policies, and assists the Commission in fulfill-ing
its statutory responsibilities, including:
  Developing broad policies and long-range programs for
wildlife management, preservation, and harvest;
Introduction and Background
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OFFICE OF THE AUDITOR GENERAL
  Establishing hunting, trapping, and fishing rules and meth-ods
for taking wildlife;
  Enforcing laws that protect wildlife;
  Establishing programs for the management of nongame,
endangered, and threatened wildlife; and
  Providing educational programs for the general public.
The Commission and Department share a common mission:
“To conserve, enhance, and restore Arizona’s diverse
wildlife resources and habitats through aggressive pro-tection
and management programs, and to provide
wildlife resources and safe watercraft and off-highway
vehicle recreation for the enjoyment, appreciation, and
use by present and future generations.”
Organization and Staffing
The Commission is composed of five members appointed by the
Governor pursuant to A.R.S. §38-211. Commissioners serve
staggered five-year terms, set policy, and hire a director to su-pervise
the Department and ensure that Commission policies are
implemented. The Department is divided into three main pro-gram
areas: Wildlife Management, Off Highway Vehi-cle/
Watercraft Management, and Administration. This perform-ance
audit reviewed the Wildlife Management Program only,
which employs approximately 91 percent of the Department’s
600 total full-time equivalent (FTE) employees.
The Wildlife Management Program has three subprograms:
  Game Management (238 FTEs)—This subprogram pro-vides
wildlife hunting and recreational opportunities to the
public. In doing so, it manages animals that are actively
hunted, such as deer, bear, elk, turkey, quail, and duck.
Game management includes inventorying game populations,
enforcing hunting rules and regulations, and assessing habi-tat
conditions. Additionally, it is involved in evaluating for-
Wildlife Management
Program employs ap-proximately
544 FTEs.
Introduction and Background
3
OFFICE OF THE AUDITOR GENERAL
merly occupied habitat for potential reintroduction of game
species.
  Nongame and Endangered Wildlife (106.5 FTEs)—This
subprogram’s activities include assessing habitat conditions
and enforcing regulations to conserve and restore wildlife
populations that are not
typically hunted. These
efforts serve reptiles,
amphibians, mammals,
birds, mollusks, and
crustaceans. This
subprogram also
oversees Department
projects for particular
species that the U.S. Fish
and Wildlife Service has
determined require special protection. One ongoing non-game
project involves re-establishing endangered Black-footed
ferrets in Arizona. These animals were eliminated
from the State in the 1930s.
  Sportfish Management (199 FTEs)—This subprogram
serves an estimated 515,885 anglers each year by producing,
stocking, and maintaining sportfish in Arizona lakes and
streams. To help accomplish this, its seven hatcheries pro-duce
an estimated 2.5 million fish each year, including trout,
bass, and catfish. In addition, it oversees an urban fishing
The U.S. Fish and Wildlife Service identifies species that require special
protection efforts based on population threats. Designations include:
Candidate
Species
A species with
known or suspected
habitat or popula-tion
threats.
Threatened
Species
A species that is not
in imminent danger
of being eliminated
from its range but is
likely to become
endangered in the
foreseeable future.
Endangered
Species
A species that it is in
imminent danger of
elimination from its
range.
Photo 1: Black-footed Ferret
Introduction and Background
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OFFICE OF THE AUDITOR GENERAL
program that involves stocking and maintaining fish in ur-ban
lakes, such as those in city parks.
Wildlife Management staff,
including approximately
150 commissioned peace
officers, are located
throughout the State in the
Department’s six regional
offices and the central
administrative office in
Phoenix. Regional offices, at
the locations shown on the
map, enable staff to become
familiar with the wildlife
and habitat in specific areas,
and to better enforce wildlife
and boating laws. In addition, these offices serve the public lo-cally
by selling hunting and fishing licenses, accepting and ad-dressing
complaints about issues such as nuisance wildlife, and
providing information about regional recreational activities.
Follow-Up to 1991
Sunset Review
This audit includes an assessment of whether the Department
has implemented recommendations made during the previous
review of Wildlife Management Program activities (Auditor
General Report No. 91-10). The 1991 report included recommen-dations
for changes to wildlife management efforts in the follow-ing
three areas:
  Controversial wildlife management issues—Auditors rec-ommended
that the Department strengthen its research on
nongame species to increase the amount of information
available to public land managers. The recommendation has
been implemented. Currently, the Department maintains a
database with information about special status nongame spe-cies
that is used to help assess whether public, state, and pri-vate
land projects need to include efforts to mitigate damage
to those species. In addition, auditors recommended that the
PHOENIX
 
Introduction and Background
5
OFFICE OF THE AUDITOR GENERAL
Department increase its efforts to address controversial wild-life
management issues. Although it has made efforts to re-solve
landowner and rancher concerns, conflicts relating to
elk continue. Because the Department alone cannot resolve
the issues, the Legislature should consider taking action to
involve all concerned parties in developing solutions (see
Finding I, pages 9 through 17).
  Planning and evaluation—At the time of the last audit, the
Department was working to implement a comprehensive
planning and evaluation process to govern its activities, and
the audit recommended that these activities continue. Since
then, the Department has worked to integrate its strategic
and operational plans. It has also centralized responsibility
for collecting and maintaining annual work plans developed
by program and regional staff. In addition, the Department
has implemented a Total Quality Leadership program that
involves teams who work to address specific operational is-sues.
  Staffing—The 1991 audit also found that the Department re-gional
supervisors were responsible for overseeing too many
staff, and the Department implemented the recommendation
to develop additional supervisor positions.
Funding and Budget
The Wildlife Management Program, like the Department as a
whole, does not receive any General Fund monies. Instead, in
fiscal year 2000 the program received approximately $16.4 mil-lion,
or nearly 40 percent, of its $41.8 million in revenues from
the sale of hunting and fishing licenses, tags, and stamps. A por-tion
of these monies, as well as most of the $13.7 million received
predominately from federal grants, was used to fund game and
sportfish management. Nongame projects receive funding
mainly through the Heritage Fund. The Heritage Fund, which
received approximately $8.1 million in fiscal year 2000, is derived
from state lottery revenues and is not appropriated. Other
sources of revenue include donations and income tax check-off
monies (see Table 1, page 6).
The program does not
receive any General Fund
monies.
Introduction and Background
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Table 1
Arizona Game and Fish Department
Wildlife Management Program 1
Statement of Revenues and Expenditures
Years Ended or Ending June 30, 1999, 2000, and 2001
(Unaudited)
1999 2000 2001
(Actual) (Actual) (Estimated)
Revenues:
Licenses and permits $15,631,766 $16,407,582 $18,940,000
Intergovernmental 11,810,061 13,733,304 12,403,900
Lottery proceeds to the Heritage Fund 8,706,250 8,096,800 7,340,600
Earnings on investments 1,337,334 1,523,392 1,100,400
Private gifts, grants, and donations 658,900 1,333,581 915,000
Sales and charges for goods and services 358,307 447,116 270,500
Fines and forfeits 200,849 154,162 166,000
Other 312,937 145,835 224,200
Total revenues 39,016,404 41,841,772 41,360,600
Expenditures:
Personal services 18,228,729 18,169,729 18,629,400
Employee related 5,097,518 4,797,968 4,857,600
Professional and outside services 2,837,997 2,143,900 1,682,500
Travel, in-state 800,619 711,063 725,800
Travel, out-of-state 197,270 198,665 142,200
Other operating 7,341,871 7,302,939 12,667,100
Equipment 7,215,507 7,150,862 2,144,100
Total expenditures 41,719,511 40,475,126 40,848,700
Excess of revenues over expenditures (2,703,107) 1,366,646 511,900
Net operating transfers in 781,863 562,312
Excess of revenues and transfers in over (under) ex-penditures
and transfers out (1,921,244) 2 1,928,958 511,900
Fund balance, beginning of year 25,707,310 23,786,066 25,715,024
Fund balance, end of year 3 $23,786,066 $25,715,024 $26,226,924
1 The Department does not entirely account for revenues and expenditures by program. Consequently, amounts for 1999,
2000, and 2001 includes Departmental administration costs (Administrative Program) and a portion of the Off-Highway
Vehicle/Watercraft Management Program. Revenues and expenditures for the Administration Program are estimated to be
$1,240,400; $1,362,600; and $1,590,200 for 1999, 2000, and 2001, respectively, and the portion of Off-Highway Vehicle Water-craft
Management Program revenues and expenditures included in the Statement is estimated to be $867,100; $1,893,300;
and $1,942,100, respectively.
2 In 1999 the Department used nearly $2 million of the available fund balance in the Game and Fish Fund to pay for 1999
operations; consequently, the Department experienced a significant excess of expenditures over revenues for that year.
3 Includes the Heritage Fund, which accounted for over $20 million of the ending fund balance for all years presented.
Source: Auditor General staff analysis of the Arizona Financial Information System (AFIS) Revenues and Expenditures by Fund,
Program, Organization, and Object and Trial Balance by Fund reports for the years ended June 30, 1999 and 2000, and the
Department’s fiscal year 2002 and 2003 Budget Request for the 2001 estimates.
Introduction and Background
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OFFICE OF THE AUDITOR GENERAL
Audit Scope and Methodology
During the course of this audit, auditors assessed several Wild-life
Management Program activities before focusing on two areas
involving elk management and retail license and tag sales. Other
activities reviewed included such things as the Department’s
current efforts to process big game tag applications, enforce
wildlife laws, conduct research, and manage its fisheries pro-gram.
These activities appear to be well managed, based on a
preliminary review. However, auditors did identify several is-sues
associated with the Department’s management of the Heri-tage
Fund, and these are reported in a separate audit (Auditor
General Report No. 01-09).
This audit report includes two findings:
  The need for the Legislature to establish a small formal task
force to help address concerns about the State’s elk popula-tion
(see Finding I, pages 9 through 17); and
  The need for the Department to more effectively and effi-ciently
manage retail license sales to ensure that it collects all
monies owed to it in a timely manner (see Finding II, pages
19 through 24).
  In addition, this report presents responses to the 12 statutory
Sunset factors (see pages 25 through 34), including informa-tion
about the Department’s management of the Heritage
Fund. Information about Heritage Fund management is in-cluded
as part of the Department’s Sunset Review since the
Fund provides substantial revenues to the Department and
pays for a number of wildlife-related activities and projects.
The Heritage Fund itself, however, is not subject to Sunset
laws.
Auditors used a number of research methods for this review.
Specifically,
■  To research issues and concerns relating to the State’s
elk population—Auditors interviewed Department man-agement
and staff to assess how the number of elk in the
State is estimated, and what it has done to mitigate concerns
Introduction and Background
8
OFFICE OF THE AUDITOR GENERAL
of land managers, private property owners, and interest
groups. Auditors also received input from legislators and
spoke with numerous outside interest groups and commit-tees,
including the U.S. Forest Service; Arizona State Land
Department; the legislative Natural Resources Discussion
Group; the Governor’s Rangeland Technical Advisory Coun-cil;
and the Arizona Cattle Growers about their elk manage-ment
concerns. In addition, information was obtained from
the Rocky Mountain Elk Foundation. Auditors also reviewed
statutes and rules from Arizona and other surrounding
states, including Colorado, New Mexico, Nevada, and Utah.
Finally, auditors contacted wildlife managers in some of
these states about their efforts to address land manager and
interest groups’ concerns.
  To determine whether the Department was appropriately
managing retail license sales—Auditors interviewed De-partment
staff responsible for managing and monitoring re-tail
license sales through license dealers. Auditors also re-viewed
statutes, rules, policies, and procedures governing
dealers, and reviewed records for a random sample of 29
dealers to determine whether these dealers had met these re-quirements.
In addition, to assess the accuracy of payment
records and the Department’s efforts to collect monies, audi-tors
reviewed available records for another 20 dealers who
appeared to either owe the Department money or be due a
refund for 1998 license sales, the most recent year for which
complete information was available.
This audit was conducted in accordance with government audit-ing
standards.
The Auditor General and staff express appreciation to the Ari-zona
Game and Fish Commission Chairman and members, the
Director of the Arizona Game and Fish Department, and staff for
their cooperation and assistance throughout the audit.
9
OFFICE OF THE AUDITOR GENERAL
FINDING I SPECIFIC DECISIONS NEEDED
TO HELP ADDRESS ELK
POPULATION AND
HABITAT CONCERNS
During the course of this audit, there was legislative and public
interest regarding the Department’s management of the State’s
elk population. The Department is responsible for managing
thousands of elk that inhabit federal, state, and private lands.
The number of elk in the State has been a long-time concern be-cause
of their impact on private property and forage, or food,
that is also used by cattle and other wildlife, such as deer. In an
attempt to address these concerns, numerous studies have been
conducted, and discussion groups and committees have been
established, but consensus has not been reached on key issues.
Consequently the Legislature should consider
establishing a small, formal task force with a
mandate to address specific resource management
issues.
Efforts to establish elk herds in Arizona began in
1913 when an initial herd of 86 Rocky Mountain elk
were transplanted from Wyoming to the Sitgreaves
National Forest. By 1935, the State’s elk herd was
successfully established and could support regular
elk hunts. Since then, the elk herd has continued to
grow. According to Department estimates, in the
late 1980s elk inhabited approximately 3.8 million
acres. Since then, the Department estimates that elk
have expanded their range to include approxi-mately
5 million acres of federal, state, and private
land in Arizona. Population estimates following the
1999 hunts ranged between 25,300 and 28,300 elk,
not including calves. The total population of elk
prior to the 2000 hunts was estimated at ap-proximately
38,000, which is reduced from a high of approxi-mately
48,000 in 1994, based on information provided by the De-partment’s
regional offices.
Photo 2: Rocky Mountain Elk
Arizona was originally inhabited by Mer-riam’s
elk, which became extinct in the late
1800s. A close relative, the Rocky Mountain
elk, was successfully introduced in 1913, and
now roams the State’s higher elevations.
Finding I
10
OFFICE OF THE AUDITOR GENERAL
Competing Interests Lead
to Conflicts over Elk
No single agency is responsible for managing both elk popula-tion
numbers and habitat, and this contributes to conflicts over
the number of elk in the State and their use of federal, state, and
private lands. For example, the Department is responsible for
managing the elk population and does this through public hunts.
However, other agencies and individuals manage and use elk
habitat, and they indicate that fewer elk could result in less dam-age
to private property and reduced competition between elk,
cattle, and other wildlife for forage on federal and state trust
lands.
Larger elk herds benefit sportsmen—The Department is respon-sible
for managing the State’s elk population through setting
hunting quotas and regulations. Currently, there is a high
level of interest in elk hunting in Arizona, and the De-partment
receives a substantial amount of revenue from
hunters. Between 1990 and 1999, the number of elk hunt-ing
permits available to sportsmen increased by ap-proximately
10,000; however, demand still far exceeds
the number of permits available. In 1999, approximately
95,000 sportsmen sought to obtain one of the 23,345 elk
hunting permits issued that year. Elk permit sales and
associated application fees generated approximately $1.9
million for the Department in 1999. Each permit allows
hunting in one or more designated parts of the State,
called management units. Most of the units where elk hunting is
allowed, shown at left in blue, are concentrated in the Apache-
Sitegreaves, Coconino, and Tonto National Forests.
Elk compete with other land users’ interests—Although the De-partment
is responsible for managing the elk population, it does
not manage most of the State’s elk habitat. This results in con-flicts
between the Department and other groups such as U.S.
Forest Service land users and private landowners because of the
negative impacts elk can have. For example, ranchers who use
U.S. Forest Service lands to produce livestock find that the size of
their herds is restricted when the amount of forage is not suffi-cient
to feed both the elk and livestock. The amount of available
Elk Hunting Areas
Finding I
11
OFFICE OF THE AUDITOR GENERAL
forage is impacted by a number of variables, including such
things as drought and the needs of endangered species.
When the Forest Service determines that available forage is low,
Forest Service managers direct ranchers to reduce the number of
cattle on the range, but cannot control the number of elk that also
use the land. Ranchers have expressed frustration with this situa-tion
because they perceive that they are required to take action
when forage is in poor condition, but the Department is not re-quired
to take action to reduce the elk population. For example,
in certain areas of the Tonto National Forest drought conditions
have caused cattle numbers to be reduced by 50 percent or more
in recent years. In other areas, cattle have been excluded entirely;
however, some of these areas still show heavy use, which is at-tributed
to elk.
Private landowners have also expressed concerns about the
damage elk cause to such things as fences, crops, and gardens.
Although most elk habitat is managed by the Forest Service,
there is the potential for significant elk numbers on state and pri-vate
lands that border or are interspersed with federal forest
lands. This is particularly the case in the winter, when snow
forces elk to move to lower elevations where a greater percent-age
of elk habitat is privately owned (see Figure 1, page 12). In
addition, numerous elk spend the summer on reservation land,
and the reservations may manage these elk herds with different
population goals than the Department. When these management
goals conflict, such as when reservation authorities manage for
higher elk populations, surrounding landowners may be ad-versely
affected.
Despite Efforts of Department and
Others, Key Issues
Still Not Resolved
In recent years numerous efforts have been made to address elk-related
concerns; however, these efforts have not yet resulted in a
comprehensive approach to managing forage. Over the past 12
years, the Legislature, the Department, the Governor, the Ari-zona
State Land Department, and others have initiated a
Elk can damage property.
Finding I
12
OFFICE OF THE AUDITOR GENERAL
number of committees and activities focused on elk and habitat
issues. However, consensus has not yet been reached on issues
such as how to measure or allocate forage in the State. To resolve
these types of broad-based issues, key interest groups need to
reach a consensus on specific management goals and objectives
for areas heavily impacted by elk use.
Efforts have been made to address concerns—Since 1989, a num-ber
of studies have been conducted, and committees and groups
have been established to address habitat management and elk-related
concerns. The Department has been an active participant
in many of these groups, and has also established projects of its
own. Some studies and committees have been established to ad-dress
specific issues, and examples of these efforts include:
  The Big Game Ranching Study Committee, which was statu-torily
established in 1989 to study the feasibility of establish-ing
a program to help ranchers and landowners recover costs
Figure 1
Elk Habitat Ownership
(Estimated)
0
1,000
2,000
3,000
4,000
5,000
6,000
7,000
8,000
Summer Winter
U.S. Forest Service Private State Other
Source: Auditor General staff summary of information provided by the Depart-ment
from its Geographic Information System. The Department indicates
that numbers are based on 1988 mapping efforts.
Finding I
13
OFFICE OF THE AUDITOR GENERAL
associated with big game on their property. The Committee
recommendations specific to its charge included such things
as compensating landowners for setting aside habitat for big
game and establishing a special fund to help pay for fencing
or other items to prevent property damage by big game.
These recommendations have not been fully implemented,
and may require further study or legislative action;
  The Department is currently working in cooperation with the
U.S. Forest Service to study forage usage on 3 of the 29 elk
management units in the State. In one of these units, a formal
agreement has been established to allocate available forage
between cattle and wildlife. The Department is responsible
for managing wildlife numbers based on their use of allo-cated
forage;
  The Governor’s Rangeland Technical Advisory Council, es-tablished
in 1999, was charged with assessing how the Forest
Service measures and allocates forage throughout the State.
The report was completed in January 2001, and recom-mended
increased consistency in measuring and monitoring
forage usage on U.S. Forest Service lands;
  The Forage Resource Study Group, lead by the State Land
Department, has ongoing studies of forage availability on
approximately 450,000 acres of land that serve as elk winter
habitat. The State Land Department indicates that winter elk
habitat in Arizona is limited and is more likely to be privately
or state owned, and these factors need to be considered when
determining elk population goals; and,
  The University of Arizona has received limited funding to
assess Arizona’s plant production via satellite to help deter-mine
how much forage is available in the State.
In addition to efforts to address specific concerns, committees
have been formed to discuss broader-based habitat issues. For
example, the Department has established Habitat Partnership
Committees to identify and discuss local habitat concerns. Local
landowners and users can also use the committees as a forum to
provide input into the Department’s hunt recommendations. Al-though
the committees have identified several habitat improve-
Finding I
14
OFFICE OF THE AUDITOR GENERAL
ment projects, they do not generally appear to focus on issues
such as forage measurement and monitoring. Another group
created to address habitat issues is the Natural Resources Discus-sion
Group, which was informally established in the mid 1990s
by the Speaker of the House. The group includes members of
land management agencies, land users, the Department, and
sportsmen. While the group brings together key interest groups,
its discussions still indicate that there is distrust among these
groups about issues such as how the elk population in Arizona is
estimated.
Current efforts are important, but key issues remain unre-solved—
Although various groups have worked to address par-ticular
elk-related issues and have made progress in some areas,
conflicts over how to manage forage and depredation, or wildlife
damage, continue. One reason may be that although some of the
current study groups and committees represent various interests,
they may have a limited focus. In other cases, they may lack the
ability or authority to affect both elk and elk habitat manage-ment.
In addition, existing groups or committees have either not
been mandated to address key issues, or they have not success-fully
fulfilled their mandate. Key issues that still need to be re-solved
include:
  Comprehensive forage resource management—None of
the groups have been charged with reaching consensus on
how to manage the State’s forage resources. To manage for-age
comprehensively, land management agencies, land us-ers,
and the Department need to agree on matters such as
how to measure and monitor forage in both summer and
winter habitats, and during drought conditions. Specifically,
these groups need to set measurable objectives for managing
forage and reach agreements about actions ranchers and the
Department will take when there is insufficient forage. In ad-dition,
key interest groups need to agree on how to identify
areas that may need time to recover from livestock or wildlife
use and who should be responsible for rehabilitating those
areas.
  Depredation on private property—Committee efforts have
not significantly increased options for addressing wildlife
depredation on private property. One of the few existing op-tions
is a statutory provision that allows for a special depre-
Specific issues need to
be resolved.
Finding I
15
OFFICE OF THE AUDITOR GENERAL
dation hunt to remove animals in areas where they are caus-ing
problems. However, during the past ten years the Com-mission
has not successfully launched such a hunt. Further,
the Department’s ability to provide materials that may bene-fit
landowners, such as fencing to protect crops from wildlife,
is limited. This issue was discussed in the Big Game Ranch-ing
Study Committee’s recommendations, but it is not clear
whether the Committee considered how materials could be
provided in compliance with the Arizona Constitution.
The Constitution prohibits gifts of state money or property,
so materials such as fencing can only be provided to land-owners
if the Department identifies a corresponding benefit
to wildlife, or if it retains the title to the materials. For exam-ple,
in some cases, the Department has lent fencing materials
to landowners to protect crops for a limited time, but the ma-terials
must be returned. In addition, when a project can be
shown to benefit wildlife, the Department has helped land-owners
to develop water sources and has provided such
things as fertilizer to improve habitats.
Although the Constitution limits the types of compensation
the Department can offer landowners, this issue could be
revisited to determine whether other states’ programs could
be modified and adopted here. For example, Colorado,
Nevada, New Mexico, and Utah each allow landowners who
have experienced problems with elk on their private
property to receive hunting permits as compensation.
Nevada’s elk incentive tag program could potentially be
adapted for Arizona. Nevada landowners agree to “tolerate”
a particular number of elk on their property in exchange for
one or more hunting permits. One option for landowners,
which would not require a legislative change nor involve a
gift, would be to increase the quality or quantity of wildlife
on their property and then charge sportsmen a fee to hunt
there.
  Forage competition—A more comprehensive approach to
forage management may reduce the conflict of competition
between livestock and wildlife for forage on federal and state
trust lands. As part of any comprehensive management plan,
strategies that would enable livestock and wildlife to com-plement
rather than compete with one another should be
Finding I
16
OFFICE OF THE AUDITOR GENERAL
considered. For example, Colorado has begun a project on
one state grazing allotment where cattle are used to improve
the habitat for elk. The study involves using a rotational graz-ing
plan where cattle are allowed to graze portions of the al-lotment
early in the spring to remove old, dry forage that the
elk are unlikely to eat. Cattle are then moved to another pas-ture,
leaving the newly exposed plant growth available to
elk. This practice is designed to benefit cattle by allowing
them access to the range earlier, and to benefit elk by making
new plant growth more accessible and by encouraging new
plant growth. Another possibility that could be explored is
whether ranchers who agree to defer grazing on federal and
state trust lands could receive hunting permits as compensa-tion.
Consensus on critical habitat management issues is needed—
Interest group representatives, including those with ongoing
projects, agree that a formal legislative task force could help to
effectively resolve concerns about habitat and forage if it can
reach a consensus on key issues. These representatives indicate
that to be most effective, the task force should be kept small and
include key decision-makers so that agreements and commit-ments
can be made. In addition, any plans or formal recommen-dations
that the task force develops should incorporate the re-sults
of recent or ongoing studies where applicable. In addition,
the task force should obtain input from the interest groups that
are also working to address elk-related issues.
Task force members should include legislators and representa-tives
from the State Land Department, the Department, land-owners,
ranchers, sportsmen, and scientists. In addition, partici-pation
by key Forest Service decision-makers is critical to devel-oping
comprehensive, effective solutions. Another important
consideration would be to assign an Assistant Attorney General
to the task force to assess recommendations and advise mem-bers.
To perform its duties, the task force could also utilize the
services of legislative staff and agency staff in appropriate fields.
Finally, to give the task force sufficient time to reach consensus
and to address long-term issues, the Legislature should consider
establishing it on an ongoing basis.
Legislative task force
should include key rep-resentatives.
Finding I
17
OFFICE OF THE AUDITOR GENERAL
Recommendations
The Legislature should consider establishing a small, formal, on-going
task force mandated with developing a comprehensive
plan for managing forage with specific agreed-upon objectives,
and for recommending methods for mitigating private property
damages and forage competition between wildlife and cattle.
The task force’s membership could include legislators, represen-tatives
from the U.S. Forest Service, the State Land Department,
the Department, landowners, ranchers, sportsmen, and scien-tists.
The task force could also utilize the services of an Assistant
Attorney General, legislative staff, and agency staff in appropri-ate
fields, as well as the efforts of existing studies, groups, and
committees to complete its duties, which should include devel-oping
and reaching consensus on the following key issues:
  Comprehensive forage management plans that establish for-age
use objectives for wildlife and cattle on summer and win-ter
habitats, and during drought conditions;
  Forage measurement and monitoring methods that are ac-ceptable
to both land managers and the Department;
  Agreements for actions to take when there is insufficient for-age;
  A mechanism for cooperatively identifying areas that may
need time to recover from either livestock or wildlife use, and
establishing responsibility for rehabilitating those areas;
  Recommendations to the Legislature about adopting the ap-propriate
tools to address depredation on private property;
and
  Recommendations to the Legislature about feasible methods
for addressing competition for forage between livestock and
wildlife on federal and state trust lands.
18
OFFICE OF THE AUDITOR GENERAL
(This Page Intentionally Left Blank)
19
OFFICE OF THE AUDITOR GENERAL
  License—Required to hunt or fish.
Some, such as urban fishing li-censes,
are for specific locations or
times.
  Tag—Required, in addition to a
license, to harvest big game ani-mals,
including antelope, bear, big-horn
sheep, buffalo, deer, elk,
javelina, mountain lion, and turkey.
  Stamp—Validates a license for
particular purposes, such as hunt-ing
waterfowl, or fishing with two
poles.
FINDING II DEPARTMENT NEEDS TO
BETTER MANAGE DEALER
LICENSE SALES
The Department needs to better manage its process for issuing
fishing and hunting licenses, and hunting tags through retail out-lets.
Retail sales are a critical source of revenue for the Depart-ment,
generating approximately 23 percent of its $41 million
Wildlife Management Program budget. However, the Depart-ment’s
recordkeeping and other procedures for managing retail
outlet sales do not adequately ensure that the Department col-lects
all monies owed to it in a timely manner.
License Dealers Generate
Significant Revenues
The Department receives a substantial portion of its annual
revenues from license, tag, and stamp sales to sportsmen. Most
of those sales are through
approximately 400 retail
outlets known as license
dealers. These dealers
include large sporting
goods stores as well as
small “mom-and-pop”
convenience stores.
Together, these dealers
collect about $9.4 million
for the Department each
year by selling hunting
and fishing licenses and
stamps and tags for
particular big game species, including bear and mountain lion.1
1 The Department’s offices also sell licenses, and are the exclusive source of
big-game tags except for bear, mountain lion, and archery deer and turkey.
The Department’s offices annually collect over $5 million.
Finding II
20
OFFICE OF THE AUDITOR GENERAL
To receive and sell hunting and fishing licenses to the public,
dealers must apply for and receive a Department dealer license.
As part of their licensing agreement with the Department, deal-ers
receive a 5 percent commission on sales and must report sales
and remit monies monthly. In addition, dealers must return all
unsold, expired licenses by January 10th for the previous license
year, or pay the Department for the value of those licenses.
Hunting and fishing licenses are generally valid for one calendar
year, but the Department sends licenses to dealers in August to
allow for advance sales.
Efforts to Manage Retail Sales and
Collect Revenue Are Inadequate
The Department does not efficiently manage sales through deal-ers
although they contribute a significant portion of the Wildlife
Management Program’s revenues. Records indicating the
amounts that dealers owe or have paid are inadequate. In addi-tion,
the Department is slow to finalize its year-end audit proc-ess,
which can result in dealers delaying payments for several
months. Finally, when dealers are slow to pay, the Department
does not consistently initiate efforts through the Attorney Gen-eral’s
Office to collect monies.
Payment records are inadequate—Based on the Department’s
records, it is difficult to determine whether dealers have met
statutory reporting deadlines and whether they owe the De-partment
money. License dealers are statutorily required to remit
sales revenues to the Department by the 10th of each month, and
must return any unsold licenses annually. If unsold licenses can-not
be located, the dealer must treat them as if they were sold
and pay the Department for them. The Department keeps mul-tiple
records of dealers’ sales, payments, and monies owed, but
there is not a single source of comprehensive information. Fur-ther,
each of the Department’s records is problematic:
  Computerized data must be manually compiled into an-nual
billing statements—Usefulness of the Department’s
computerized data of the amount and type of license stock
sent to dealers and monthly payment records is limited. Spe-cifically,
the system does not enable managers to identify
Finding II
21
OFFICE OF THE AUDITOR GENERAL
which dealers have failed to report monthly sales. Staff com-pile
and maintain this information manually. In addition, the
system cannot compile a comprehensive year-end billing
statement for each dealer. Instead, the system produces two
separate statements: one showing how much dealers owe for
unreturned license stock; and a second showing how much is
due, or should be refunded, because dealers incorrectly re-ported
monthly sales or miscalculated payments. The De-partment
staff must manually compile both of these pieces of
information into a year-end billing statement for approxi-mately
400 dealers.
  Annual billing state-ments
do not clearly
show payments or
monies due—The
Department’s annual
billing statements are
compiled manually and
can be confusing. For ex-ample,
as shown at right,
when a dealer makes a
partial payment, or
returns some license
stock, Department staff
recalculate the new
amount due and write it
on the original statement
and send it back to the
dealer.
  Handwritten payment log lacks payment dates and
amounts—During the year-end billing process, Department
staff record payment information on a manual log. Staff indi-cate
that during the year-end process, this log is the most up-to-
date payment record available. However, this log appears
to be of little value since staff often do not record the dates
and amounts of payments in it.
Auditors reviewed records for 49 license dealers and identified
numerous recordkeeping problems and discrepancies. Some
problems were less serious, such as Department staff failing to
date-stamp monthly reports to show whether a dealer had re-
Finding II
22
OFFICE OF THE AUDITOR GENERAL
ported on time, or an out-of-business dealer still being listed as
active in the database. Other, more serious problems involved
cases where records were not sufficient to determine which deal-ers
still owed the Department money and how much was due.
For example, one dealer’s file showed a balance due of $266 for
1998 license sales. A computerized billing statement, which does
not include monies owed for unreturned licenses, showed that
the dealer owed $171. However, the manual payment log con-tradicts
both of these records, showing that this dealer has a
“zero balance.” The log’s accuracy cannot be verified, however,
since it does not include an amount paid or a payment date.
To resolve these problems, the Department needs to develop a
single source of accessible, up-to-date payment and billing in-formation.
The Department’s computer system currently ap-pears
to contain all of the information necessary to do this, but
some additional programming is needed to produce compre-hensive
billing reports. In addition, it needs to ensure that it ap-propriately
date-stamps and maintains any necessary manual
records, such as monthly dealer reports.
Dealers allowed to delay year-end payments—Although the
Department audits dealers annually to ensure that they either
return or pay for all licenses they receive, some dealers have been
allowed to delay making final payments for several months. Af-ter
the January 10th deadline for returning unsold licenses, the
Department begins its audit process and bills those dealers for
the value of all unreturned licenses. When a dealer returns a por-tion
of the unsold licenses or makes a partial payment, the De-partment
issues another bill and allows the dealer an additional
30 days to respond. Because the Department does not limit the
number of times that it recalculates and resubmits bills, some
dealers have delayed payments for several months. For example:
  One dealer who owed $10,000 in January 1999 was allowed
to delay paying in full for eight months. The dealer returned
unsold licenses and made partial payments until September
1999, when the audit process was finally completed.
  Another dealer who should have paid or returned licenses
worth $6,921 in January 1999 delayed making a final pay-ment
for at least ten months.
Finding II
23
OFFICE OF THE AUDITOR GENERAL
By statute, dealers’ license-selling privileges are automatically
canceled if they do not return all unsold and expired licenses
within 30 days of reporting deadlines. However, this statutory
provision does not provide a practical solution for late reporting.
To help ensure prompt reporting on both a monthly basis and at
year-end, the Department should seek amendments to A.R.S.
§§17-338 and 17-339 to allow for enforcement options, such as
penalties and late fees. In addition, the Department needs to im-plement
a policy limiting the total amount of time, or the number
of opportunities to respond, that a dealer will be allowed before
formal collection or revocation efforts are initiated.
Department does not always act quickly to collect monies due—
When dealers do not pay, the Department does not always refer
these cases in a timely manner to the Attorney General’s Office
for collection. One reason is that the Department has not estab-lished
deadlines for referring cases to the Attorney General’s Of-fice.
Another reason appears to be because the Department’s
computerized database does not enable staff to efficiently iden-tify
dealers who have not reported monthly sales or who have
not made final year-end payments or returned unsold licenses.
Instead, staff must review the dealers’ paper files to determine
whether an account is current. This manual process may not
identify all delinquent dealers and can result in costly delays. For
example:
  One dealer who failed to pay continued to receive licenses to
sell. The dealer should have returned approximately $9,500
worth of licenses in January 1999. The dealer did not respond
to an April 1999 request for payment, but the Department let
seven months pass before sending a follow-up letter. In the
meantime, the Department sent this dealer licenses to sell for
the next license year, which the dealer also failed to return.
When the Department finally initiated collections action in
April 2000, this dealer owed more than $15,600.
  Another dealer’s file indicates that the dealer still owes the
Department $324 for 1998 license sales. There is no evidence
of payment, and the only documented effort to collect the
money was a September 1999 letter the Department sent to
the dealer.
Finding II
24
OFFICE OF THE AUDITOR GENERAL
To help ensure collections efforts are initiated in a timely man-ner,
the Department needs to establish a time frame for initiating
collections efforts against dealers who fail to return licenses or
report sales, and improve its ability to identify these dealers. Fi-nally,
the Department needs to ensure that it initiates collection
actions in a timely manner through the Attorney General’s Of-fice.
Recommendations
1. The Department should further develop its computerized
licensing database into a comprehensive, accessible source of
up-to-date payment and billing information.
2. The Department should ensure that needed manual records,
such as dealers’ monthly sales reports, are appropriately
date-stamped and maintained.
3. The Department should seek amendments to A.R.S. §§17-338
and 17-339 to establish enforcement options, such as penal-ties
and late fees, to be assessed against dealers who do not
meet deadlines for reporting sales, remitting monies, or re-turning
unsold licenses.
4. The Department should establish and implement a policy
stating the total amount of time, or the number of opportuni-ties,
that a dealer will be allowed to submit unsold licenses or
payments before being referred to the Attorney General’s Of-fice
for collection of outstanding monies.
5. To help ensure delinquent dealers are identified quickly, the
Department should program its computerized licensing da-tabase
to identify dealers who have not submitted timely
monthly sales reports and who have not responded in a
timely manner to annual audits.
25
OFFICE OF THE AUDITOR GENERAL
SUNSET FACTORS
In accordance with A.R.S. §41-2954, the Legislature should con-sider
the information contained in the following 12 factors in de-termining
whether the Arizona Game and Fish Commission and
Department should be continued or terminated. These 12 factors
include information derived from this audit of the Arizona
Game and Fish Department (Department) Wildlife Management
Program, as well as information from a separate performance
audit of the Game and Fish Heritage Fund (see Auditor General
Report No. 01-09). Information about Heritage Fund manage-ment
is included as part of the Department’s Sunset Review
since the Fund provides substantial revenues to the Department
and pays for a number of wildlife-related activities and projects.
The Heritage Fund itself, however, is not subject to Sunset laws.
1. The objective and purpose in establishing the
agency.
The Arizona Game and Fish Commission and Depart-ment
were established in 1929 to oversee the manage-ment,
preservation, and harvest of wildlife in Arizona.
The Commission, which consists of five members, sets
wildlife management policies and hires a Department di-rector
to supervise the Department and ensure that
Commission policies are implemented. In carrying out
the Commission’s directives, the Department performs a
number of activities, including:
  Assisting the Commission with establishing hunting
and fishing seasons and determining the number of
public hunting permits to be issued each year;
  Enforcing hunting and fishing laws;
  Managing game, nongame, and fisheries programs;
Sunset Factors
26
OFFICE OF THE AUDITOR GENERAL
  Performing wildlife research and managing habitat
programs;
  Providing wildlife information to the public through
education programs and outreach efforts; and
  Enforcing watercraft and off-highway vehicle laws
and registering boats.
In addition, the Department administers the Arizona
Game and Fish Commission Heritage Fund, which is di-vided
into five programs: public access; urban wildlife;
environmental education; habitat evaluation and protec-tion;
and identification, inventory, protection, acquisition,
and management (IIPAM) of sensitive habitats. The Heri-tage
Fund was established by voter initiative in 1990 and
generates up to $10 million each year to benefit wildlife
and their habitats (for further information, see Auditor
General Report No. 01-09).
2. The effectiveness with which the agency has met its
objective and purpose and the efficiency with which
the agency has operated.
The Commission, through the Department, has generally
met its overall objectives and purposes. The Commission
manages wildlife that are considered big game animals
through public hunts that involved almost 131,000 sports-men
in 2000. The Commission and Department are also
involved in protecting and managing endangered and
threatened species. For example, the Department reintro-duced
the endangered Gila trout to Dude Creek near
Payson, Arizona. The Department also gained recogni-tion
for successfully breeding and releasing 63 endan-gered
Black-footed ferrets into the wild.
However, this Sunset review identified some areas where
the Department’s operations could be made more effec-tive
and efficient, including:
  License Sales—The Department could more effi-ciently
manage its process for issuing hunting and
Sunset Factors
27
OFFICE OF THE AUDITOR GENERAL
fishing licenses and permits through its retail outlets.
The Department sells hunting and fishing licenses
and permits through approximately 400 retailers,
known as license dealers. These dealers collect a sub-stantial
amount of revenue for the Department. How-ever,
the Department’s recordkeeping and other pro-cedures
for managing retail outlet sales do not ade-quately
ensure that it can determine how much
money it is owed and collect it in a timely manner (see
Finding II, pages 19 through 24).
  License Time Frames—Although the Department
appears to generally comply with its licensing time
frame rules, it needs to ensure that it renews dealer li-censes
in a timely manner. These licenses allow retail
sales outlets to sell fishing and hunting licenses, and
hunting tags, and should be issued by the Depart-ment
within 30 days of receiving a completed applica-tion.
However, auditors reviewed a random sample
of 29 dealer files and found that year 2000 renewal li-censes
were issued late in 17 cases. In 7 other cases,
timeliness could not be determined because staff did
not date-stamp the license applications.
3. The extent to which the agency has operated within
the public interest.
Although the Commission and Department have gener-ally
operated in the public interest, they need to be more
accountable to the public and the Legislature for Heritage
Fund expenditures and management. The Commission
and Department are responsible to the general public,
and also serve a large number of special interest groups,
including hunters, anglers, conservation and environ-mental
organizations, and other government agencies. To
gauge its progress, the Department regularly surveys the
general public, as well as hunters and anglers.
Projects that the Department and Commission have de-veloped
to serve the public include a variety of recreation,
information and education, and public safety programs.
Recreation and education programs include the Depart-
Sunset Factors
28
OFFICE OF THE AUDITOR GENERAL
ment’s Urban Fishing Program, wildlife viewing semi-nars,
fishing clinics, and its nationally recognized Hunter
Education Program. In addition, the Department helps to
ensure public safety by enforcing hunting laws and re-moving
potentially dangerous wildlife, such as bears,
from urban areas. The Department has also established a
watercraft registration, enforcement, and boating safety
program.
The Department and Commission need to take steps to
ensure that the Heritage Fund is managed in the public’s
interest (see Auditor General Report No. 01-09). Specifi-cally,
the Commission needs rules to guide its Heritage
Fund property acquisition program. It also needs to
adopt rules or other formal criteria, such as substantive
policy statements, to ensure the expenditure of other
Heritage Fund monies is appropriate. Since the Heritage
Fund was established in 1990, the Department has re-ceived
approximately $92.7 million, but has written rules
for spending only a small portion of these monies. With-out
rules or other formal criteria, it is difficult to deter-mine
whether expenditures meet the intent of the Heri-tage
Fund. For example, it is not clear whether a Depart-ment-
funded television program is an appropriate use of
monies designated to identify, inventory, protect, acquire,
and manage sensitive habitat.
In addition, the Department does not adequately account
for Heritage Fund monies. Currently, the Heritage Fund
has a total balance of approximately $20 million but the
amount of monies belonging to each of the five Heritage
Fund programs is uncertain. Further, the Department has
used these monies to pay for activities that should have
been paid for from other funding sources. Although these
loans have since been repaid, there is no statutory provi-sion
that allows Heritage Fund monies to be lent.
Finally, the Department could better enable the public
and Legislature to assess its efficiency and effectiveness
by increasing the amount of information presented in its
annual Heritage Fund report. The annual report currently
does not contain sufficient information to enable the pub-
Sunset Factors
29
OFFICE OF THE AUDITOR GENERAL
lic and Legislature to determine whether the Department
has complied with statutory spending limits, how much
was spent for various projects, and whether progress has
been made toward goals or objectives.
4. The extent to which rules adopted by the agency are
consistent with the legislative mandate.
According to the Governor’s Regulatory Review Council
(GRRC), the Commission has promulgated most, but not
all, of the rules necessary to carry out its statutory respon-sibilities.
GRRC determined that the following additional
rules are needed:
  Rules that clarify what proof of age and residency is
required for applicants requesting a lifetime license or
trout stamp pursuant to A.R.S. §17-335.01(E). Accord-ing
to GRRC, even though the Commission has not
experienced difficulties regarding proof of age and
residency, since Department employees routinely ask
applicants for identification that indicates age and ad-dress,
a rule covering clarification of type of proof
should be initiated.
  Rules that outline the requirements to obtain a fishing
license.
  Rules regarding the Commission’s decision to enter
into agreements with landowners or agencies. Ac-cording
to the Department, the only rule regarding
the expenditure of funds is R12-4-123, which is a gen-eral
rule applicable to the numerous funds under the
Department’s control.
  Rules that prescribe procedures for use of Department
personnel, facilities, equipment, supplies, and other
resources in assisting search or rescue operations at
the request of the Director of the Division of Emer-gency
Management.
Sunset Factors
30
OFFICE OF THE AUDITOR GENERAL
  Rules that provide directions for ensuring that a wa-tercraft
owner’s certificate of registration number
bears the holder’s correct address.
  Rules that determine which criteria the Department
will use to decide whether to revoke the numbers and
decals issued to a watercraft involved in a violation or
any other watercraft owned by a convicted person.
  Rules that prescribe grades, qualifications, and salary
schedules for Department employees.
Further, as mentioned previously, the Department should
promulgate rules or develop other formal criteria to
guide how it spends Heritage Fund monies.
5. The extent to which the agency has encouraged in-put
from the public before promulgating its rules and
regulations, and the extent to which it has informed
the public as to its actions and their expected impact
on the public.
According to Commission and Department officials, the
agency has encouraged public input in revising and de-veloping
its rules. For example, Commission meeting
agenda notices are mailed to individuals, groups, the
media, and other government agencies. The public is also
notified through print and electronic media such as news
releases, articles in publications such as Arizona Wildlife
Views, and through the Department’s Internet Web site.
During Commission meetings, time is also provided for
public input on proposed rules and other actions. Addi-tionally,
special public meetings are occasionally held
statewide to allow public input on specific issues.
6. The extent to which the agency has been able to in-vestigate
and resolve complaints that are within its
jurisdiction.
The Commission and Department have the authority to
investigate and resolve complaints that are within its ju-
Sunset Factors
31
OFFICE OF THE AUDITOR GENERAL
risdiction. Complaints involving serious violations, such
as wildlife poaching, are directed to Operation Game
Thief (OGT), a 24-hour telephone hotline. OGT has a
computerized complaint tracking system that enables the
Department to track the complaint from the initial phone
call to its final disposition. According to Department offi-cials,
this hotline has developed into one of the most suc-cessful
programs of its type in the nation. In 1999, accord-ing
to Department officials, OGT received 811 calls re-garding
wildlife violations, with the majority of calls re-porting
violations against big game animals, migratory
birds, aquatic and other wildlife, and small game animals.
Further, the Department reports that in 1999, OGT paid
32 cash rewards totaling $7,780. Department officials be-lieve
that OGT is successful because of its 24-hour avail-ability,
the caller’s ability to speak with someone immedi-ately,
and the fact that Arizona’s border states can also
use the hotline to report wildlife violations occurring in
Arizona.
The Department also receives a large variety of other
calls, including concerns about bears in urban areas or in-quiries
about how to remove nuisance wildlife, such as
skunks or javelinas. According to Department officials,
the Department accepts and handles these calls at the
lowest level possible throughout the agency.
7. The extent to which the attorney general or any other
applicable agency of state government has the au-thority
to prosecute actions under the enabling legis-lation.
The Department and Commission are currently repre-sented
by two full-time Assistant Attorneys General who
assist with enforcing the provisions of A.R.S. Title 17.
Under A.R.S. Title 17, the Commission can revoke hunt-ing
and fishing privileges and can assess fines and civil
penalties for persons convicted of violating its statutes. In
addition, County attorneys’ offices prosecute criminal ac-tions
outlined in A.R.S. Titles 5, 17, and 28, such as boat-ing
while intoxicated, poaching, and misusing firearms.
These titles also prescribe penalties for criminal actions.
Sunset Factors
32
OFFICE OF THE AUDITOR GENERAL
8. The extent to which the agency has addressed
deficiencies in the enabling statutes that prevent it
from fulfilling its statutory mandate.
Several legislative changes made over the past two years
have enabled the agency to better carry out its mission.
For example, legislation passed in 1999 and 2000 enabled
the Department to better compensate and retain staff
through salary increases and changes in retirement rules.
Other changes to statutes have included allowing parents
to transfer a hunting permit or tag to a child, license fee
increases, and provisions for protecting jaguars.
Legislative issues currently being studied by the Depart-ment
include:
  Amending A.R.S. §5-349(C) and (E) to provide a
minimum value of property damage before a water-craft
incident report must be filed with the Depart-ment;
and
  Amending A.R.S. §5-321(E) to allow outside vendors
to charge service fees for renewing watercraft registra-tions
by telephone and the Internet.
9. The extent to which changes are necessary in the
laws of the agency to adequately comply with the fac-tors
listed in the Sunset Laws.
This Sunset review and the Heritage Fund performance
audit identified several statutory changes that the Legisla-ture
should consider. This audit recommends that the
Legislature consider establishing a formal resource man-agement
task force to develop comprehensive manage-ment
objectives for wildlife, particularly elk, and wildlife
habitat. During the course of the audit, legislators and
outside interest groups indicated that the Department’s
efforts to manage the number of elk in the State through
public hunts have not addressed land manager and land
user concerns. Issues generally relate to the Department
being responsible for managing wildlife populations but
not their habitat. Those who manage or own land, or who
Sunset Factors
33
OFFICE OF THE AUDITOR GENERAL
share habitat with wildlife, have expressed concerns
about damage that elk cause to fences and crops, and
about competition between elk, cattle, and other species
for available feed. A formal legislative task force that
represents these interests, as well as the Department,
could help address these issues (see Finding I, pages 9
through 17).
In addition, the Department should seek amendments to
A.R.S. §§17-338 and 17-339 to establish enforcement op-tions,
such as penalties and late fees, to be assessed
against dealers who do not meet deadlines for reporting
sales, remitting monies, or returning unsold licenses.
Finally, a 1991 Auditor General Report (No. 91-10) rec-ommended
that the Legislature consider amending
A.R.S. Title 5 to require that watercraft be titled and to es-tablish
a fee to cover the cost. Although this change was
not implemented, it still should be considered since titling
establishes proof of ownership, discourages theft, and al-lows
for liens to be recorded. Currently, 36 states title wa-tercraft.
10. The extent to which termination of the agency would
significantly harm the public health, safety, or wel-fare.
Terminating the Commission and Department could
pose some harm to the public’s safety and welfare. The
Commission and Department conduct a number of activi-ties
designed to manage wildlife populations and regu-late
watercraft. By eliminating the Commission and
Department, the State would have no other entity to
oversee wildlife management, preservation, and harvest.
Without such an entity, wildlife may become
overpopulated, or, alternately, the viability of wildlife for
hunting, fishing, and other recreational activities, such as
bird watching, may be threatened.
In addition, no other agency regulates watercraft opera-tion,
with the exception of some limited county watercraft
enforcement. The Department currently registers boats,
Sunset Factors
34
OFFICE OF THE AUDITOR GENERAL
which helps protect owners’ interests. In addition, the
Department provides boater education courses, and its
officers patrol lakes to help ensure boater safety.
11. The extent to which the level of regulation exercised
by the agency is appropriate and whether less or
more stringent levels of regulation would be appro-priate.
The audit found that the current level of regulation exer-cised
by the Department and Commission is appropriate.
12. The extent to which the agency has used private con-tractors
in the performance of its duties and how ef-fective
use of private contractors could be accom-plished.
The Department uses private sector contractors for a vari-ety
of services. According to Department officials, the
Department contracts for maintenance and janitorial ser-vices,
major construction, security system monitoring,
heavy equipment repair, engineering and land surveys,
personal computer and copier maintenance, temporary
staff, printing and publications, mail services, fleet main-tenance,
and many other services. Auditors randomly se-lected
and reviewed six contracts, and these appeared to
have been properly developed, awarded, and renewed in
compliance with the Arizona State Procurement Code.
However, one of the contracts, which is for shooting
range management, has not been properly monitored ac-cording
to the contract’s provisions. This ten-year contract
is valid through 2006, and requires the Department to
conduct annual performance audits beginning in 1997.
However, auditors were able to locate only one such au-dit
that was completed in 1998.
OFFICE OF THE AUDITOR GENERAL
Agency Response
OFFICE OF THE AUDITOR GENERAL
(This Page Intentionally Left Blank)
April 20, 2001
Ms. Debra K. Davenport
Auditor General
2910 N. 44th Street, Suite 410
Phoenix, Arizona 85018
Dear Ms. Davenport:
We have reviewed the revised preliminary draft report of the performance audit of the
Wildlife Management Program at Arizona Game and Fish Department.
In reference to your letter of April 13, 2001, we have attached our preliminary written
response regarding the audit findings as outlined in the preliminary draft report.
Our response includes the required statements regarding each recommendation in the
report.
Should you have any questions or comments, please contact Steve Ferrell at (602) 789-
3276 or me at (602) 789-3278.
Sincerely,
Duane L. Shroufe
Director
DLS:bt
Attachment
Department Response to the
Report by the Auditor General’s Office
of the Wildlife Management Program at Arizona Game and Fish Department
RESPONSE TO RECOMMENDATIONS
FINDING:
BECAUSE NO SINGLE AGENCY IS RESPONSIBLE FOR MANAGING BOTH ELK
POPULATION NUMBERS AND HABITAT IN ARIZONA, CONFLICTS ARISE OVER THE
NUMBER OF ELK THE DEPARTMENT MAINTAINS IN THE STATE, AND THE IMPACT
THOSE ANIMALS HAVE ON LANDS OWNED AND MANAGED BY OTHERS
RECOMMENTATION:
The Legislature should consider establishing a small, formal, ongoing task force mandated
with developing a comprehensive plan for managing forage with specific agreed-upon
objectives, and for recommending methods for mitigating private property damages and
public land forage competition between wildlife and cattle. The task force’s membership
could include legislators, representatives from the U.S. Forest Service, the State Land
Department, the Department, landowners, ranchers, sportsmen, and scientists. The task
force could also utilize the services of an Assistant Attorney General, legislative staff and
agency staff in appropriate fields to complete its duties.
RESPONSE:
Since this finding and recommendation is to the Legislature the Department has no response. If
the Task Force is established the Department is prepared to participate in whatever capacity is
necessary. If the Task Force is established the Department recommends that their first task be to
evaluate all of the past work that has been accomplished so that they are “up to speed” on all
successes to date.
FINDING:
EFFORTS TO MANAGE RETAIL SALES AND COLLECT REVENUE ARE INADEQUATE
RECOMMENDATIONS:
The Department should further develop its computerized licensing database into a
comprehensive, accessible source of up-to-date and billing information. The audit finding is
agreed to and the audit recommendation will be implemented. The Department will have a
program written to combine all the records for each dealer into a comprehensive source of up-to–
date payment and billing information. The Department has the ability to run monthly billing
reports to determine if a dealer has not reported on a monthly basis.
2
The Department should ensure that needed manual records, such as dealers’ monthly sales
reports, are appropriately date-stamped and maintained. The audit finding is agreed to and
the audit recommendation will be implemented. Effective 07/01/00, the Department date stamps
all incoming documents and each manual dealer file is maintained properly.
The Department should seek amendments to A.R.S.§§17-338 and 17-339 to establish
enforcement options, such as penalties and late fees, to be assessed against dealers who do
not meet deadlines for reporting sales, remitting monies, or returning unsold licenses. The
audit finding is agreed to and the audit recommendation will be implemented. The Department
will seek amendments to A.R.S. § 17-338 and 17-339 to impose penalties to be accessed against
dealers who do not meet deadlines for reporting sales, remitting monies or returning unsold
inventory. The amendment should include a specific time period for the completion of audits.
The Department should establish and implement a policy stating the total amount of time,
or the number of opportunities, that a dealer will be allowed to submit unsold licenses or
payments before referring to the Attorney General’s Office for collection of outstanding
monies. The audit finding is agreed to and the audit recommendation will be implemented. The
Department now follows A.R.S.§ 17-338, 17-339 and A.A.C. 12-4-105 procedures and time
frames for handling delinquent dealers. If the dealer does not comply with the time frames set
forth and the amount owed is $500 or more, the account is sent to the Attorney General’s Office.
If the dealer owes less than $500, a consumer credit report is filed with Credit Data Southwest.
To help ensure delinquent dealers are identified quickly, the Department should program
its computerized licensing database to identify dealers who have not submitted timely
monthly sales reports and who have not responded in a timely manner to annual audits.
The audit finding is agreed to and the audit recommendation will be implemented. The
Department will have a program written to generate a consolidated informational report showing
the licenses outstanding and the monies owed to the Department The Department has the ability
to run monthly billing reports to determine if a dealer has not reported on a monthly basis. The
Department will program the computerized licensing system to identify dealers who have not
responded in a timely manner to annual audits.
Sunset Factors
The Department would also like to comment on the quality and completeness of the Sunset
Factors.
Sunset Factor 2
Our response to the first bullet in this factor has been answered in the findings and
recommendations above.
The Department agrees with the recommendation in the second bullet. All applications for
renewing license dealer licenses will be date stamped when they arrive and the date of the
renewal will be entered on the application. The Department will ensure that the 30-day deadline
is met.
3
Sunset Factor 3
Our response to the comments in this factor is contained in our response to the Heritage audit.
Sunset Factor 4
Rules that clarify what proof of age and residency is required for applications requesting a
lifetime license or trout stamp pursuant to A.R.S. § 17-335.01(E). According to GRRC,
even though the Commission has not experienced difficulties regarding proof of age and
residency, since the Department employees routinely ask applicants for identification that
indicates age and address, a rule covering clarification of type of proof should be initiated.
The Department agrees with this recommendation. GRRC suggested that the Commission should
initiate rulemaking to clarify what information is required from an applicant. A suitable model
appears to already exist in Article 2. Miscellaneous Licenses and Permits. Specifically, R12-4-
201 (B). Pioneer license. The next 5 Year Rule Review process involving Article 2. begins in
July 2002, with the report due to GRRC in December 2003. Potentially, the new rule that the
Auditor General report is recommending could be in place and effective on or about December
2004.
Rules that outline the requirement to obtain a fishing license. The Department does not
agree with this recommendation. The only requirements to obtain a fishing license are to pay the
fee and claim state of residency, which are already provided in rule and statute. Another rule
would be redundant.
Rules regarding the Commission's decision to enter into agreements with landowners or
agencies. According to the Department, the only rule regarding the expenditure of funds is
R12-4-123, which is a general rule applicable to the numerous funds under the
Department's control. The Department does not agree with this recommendation. Agreements
are not subject to rulemaking. Each agreement is unique with special features. Required
uniform provisions are already described by Statute; therefore, a special rule is not necessary to
reiterate statutory requirements.
Rules that prescribe procedures for use of Department personnel, facilities, equipment,
supplies, and other resources in assisting search or rescue operations at the request of the
Director of the Division of Emergency Management. The Department does not agree with
this recommendation. This issue involves the interaction with another state agency, and would
more appropriately be handled in the form of an Intergovernmental Agreement describing the
provisions of the agreement.
Rules that provide directions for ensuring that watercraft owner's certificate of
registration number bear the holder's correct address. The Department does not agree with
this recommendation. All of the requirements are delineated in Statute (A.R.S. 5-321(G) and any
rule would be duplicative. Department procedures for watercraft registration do not place
additional requirements on the public.
Rules that determine which criteria the Department will use to decide whether to revoke
the numbers and decals issued to a watercraft involved in a violation or any other
watercraft owned by a convicted person. The Department agrees with this recommendation.
4
The enabling statue is A.R.S. § 5-391(H). Administrative rules that relate to this general subject
matter are R12-4-505 and 506. The Governor's Regulatory Review Council, by written
memorandum on or about September 20, 2000, concluded that the Arizona Game & Fish
Commission has not made a rule on this subject. It may be important to note that GRRC did not
conclude that additional rulemaking was necessary. However, the way in which the language in
the statue is currently written (use of the word "may") allows the Commission discretion in
revoking a watercraft's numbers and decals. According to the Arizona Secretary of State, any
requirement or interpretive opinion that directly and substantially affects the public should be in
a rule. We feel this can best be accomplished as part of the ongoing Article 5. Boating and
Water Sports rulemaking activities that were presented to the Commission March 24, 2001.
Potentially, a new or amended rule section could be in place and effective on or about July 1,
2002.
Rules that prescribe grades, qualifications, and salary schedules for Department
employees. The Department does not agree with this recommendation. We feel this would be
unnecessary and a duplicative process. The Commission has made the decision to rely on the
Administrative Rules of DOA for personnel and in this way has complied with Statute. There
has not been any support from the Legislature or Governor’s Office for independent personnel
rules. Moreover, agency policies on internal management are exempt from rulemaking.
Sunset Factor 9
Please see the responses to elk issues above.
In regards to the recommendation for legislation requiring watercraft titling, as in 1991, the
Department questions the merits of watercraft titling as listed in the report recommendation. As
has been the case in the past, such legislation would create additional bureaucracy and regulation
upon watercraft ownership. The Department found there to be little receptivity in the legislature
for adding additional government regulation at the expense of the public when we offered this
recommendation in 1991. Additionally, such legislation would be subject to Proposition 108
requirements. Based on constituent feedback, our current watercraft registration system serves
the watercraft owners of Arizona well.
COMMENTS
PAGE 2 OF REPORT HIGHLIGHTS
At the top of the first column an interested party needs to be added as a fourth bullet under
“CONFLICTS”. The new bullet should read, “Hunters have expressed a need for a larger elk
population so that more permits can be issued”.
PAGE ii
The desire for recreational users of elk, either for viewing or hunting, is not adequately
considered. The monetary benefit to the State of Arizona from elk is tremendous. For instance,
in 2000 there were 24,996 elk permits sold which resulted in 110,988 elk hunter days (the
number of days that all hunters spent in the field elk hunting). Using a conservative economic
multiplier of $60/day the economic benefit to the State of Arizona (excluding tag fees) is
5
$6,660,000. In addition to this precise data the 1996 National Survey of Fishing, Hunting, and
Wildlife-Associated Recreation gives some general values associated with “Wildlife Watching”.
In Arizona resident and nonresident “Wildlife Watchers” annually spent over $681 million.
Certainly, only a small portion of this was spent specifically on elk but it is important to our
overall economy.
PAGE 8
When conducting the research for this Audit too few recreational user groups were contacted
resulting in an unbalanced analysis. The only recreational user group contacted was the Rocky
Mountain Elk Foundation (RMEF). RMEF is a national organization with state chapters in
Arizona. Most of the recreational users of elk in the state of Arizona will not be represented in
RMEF. There are in excess of 95,000 elk hunters in Arizona. Groups such as the Arizona
Wildlife Federation, Yuma Valley Rod and Gun Club, Arizona Sportsman’s Alliance, etc. should
have been contacted in order to gather a more accurate reflection of the Statewide needs and
conflicts. Without this data the Audit findings fall short of reflecting the entire resource issues,
and fails to illustrate the dichotomy/or full range of the issues surrounding elk management.
PAGE 11
When the auditor report discusses forage allocations the reader may get the impression that the
only issues surround cattle and other ungulate use. The following discussion of factors involved
in determining forage allocation on the Apache-Sitgreaves National Forest would be useful to the
reader.
The Apache-Sitgreaves National Forests and the Arizona Game and Fish Department have
cooperatively established an herbaceous forage distribution between domestic livestock and wild
ungulates on National Forest System lands in Game Management Unit 4A, and are presently
coordinating to conduct similar analyses in Game Management Unit 4B and a portion of 3C.
Prior to establishing the herbaceous forage distribution, the Forest Service determines the total
herbaceous forage production for the analysis area based on Jameson-Thill regression analyses.
These analyses relate forest type (ponderosa pine) and canopy closure to estimated herbaceous
forage production. The production estimates are validated in the field and modifications are
made if necessary. Then, appropriate allowable use levels are identified based on current range
conditions. For example, if an Interdisciplinary Team identifies an allowable use level of 25%
for a particular livestock pasture, this means that only 25% of the annual herbaceous forage
production is available for use by all grazing ungulates (wild and domestic). The remaining 75%
of available forage is unavailable for grazing ungulates, and represents the residual forage
production that must remain on the ground to meet other resource needs, such as non-ungulate
wildlife habitat needs (e.g., turkeys, black bears, prey species for raptors), including special
status species (threatened and endangered species and Forest Service sensitive species), plant
physiology needs, soils and watershed health.
The forage distribution analysis affects only a small portion of the total herbaceous forage
production in an area. For example, in GMU 4A, the allowable use level was 25%, so the
distribution affected only 25% of the total herbaceous forage production. The 50:50 forage
distribution resulted in half of the 25% allowable use, or 12.5% of the total herbaceous forage
6
production, being distributed to wild ungulates (i.e., elk). Likewise, the other half of the 25%
allowable use, or 12.5% was distributed to domestic livestock. The remaining 75% was
unavailable for all grazing ungulates, wild or domestic.
PAGE 15
Following is some additional information that was not available for the auditors but may be of
value in understanding how the Department and Commission are continuing to deal with elk
issues.
Subsequent to the fall 2000 hunting seasons, Arizona Game & Fish Department wildlife
managers began evaluating the effect of elk harvest objectives throughout Arizona.
Additionally, the Department was receiving stakeholder feedback on the current distribution and
abundance of elk in various areas of the state. As an example, the Department had received
concerns from the Forage Resource Study Group in Flagstaff of expanding resident elk herds in
areas of traditional winter range. The Department also heard from local farmers and sportsmen
concerning the presence of elk in Game Management Units 28 and 31. These exploratory herds
were becoming established as resident elk populations.
On January 3, 2001, the Commission conducted a special meeting in Holbrook to take testimony
from private landowners concerning damage to their private property due to the presence of elk.
Department wildlife managers were finding that previous harvest strategies designed to reduce
some of these exploratory and establishing resident herds were not meeting objectives. Some
isolated, local elk populations were continuing to grow since hunter harvest was not meeting
annual recruitment.
Therefore, in January 2001, the Director ordered an internal team of experienced elk managers to
be established. The Team was comprised of veteran elk managers from the Pinetop, Flagstaff,
Kingman, Mesa, and Yuma regional offices, as well as Game Brach personnel. Collectively,
there were over two centuries of elk management experience from the members of the team. The
Team was charged with two objectives. First, they were to look at existing rules and Department
systems, then develop harvest strategies that could be brought to the Commission for the fall
2001/02 public review process that would begin to meet management objectives for these non-traditional
elk herd management areas. Second, the Team was to develop long-term strategies
that may require amendment to Commission rules or Department systems to meet management
objectives on expanding elk herds and that would have minimal impact on Arizona’s elk hunters.
Non-traditional elk herds, defined as those that were either expanding into previously
unoccupied habitat, establishing resident populations in winter range, or becoming mostly reliant
on private land, account for less than 5% of the state’s elk population. In addition, the large
amount of time spent managing these isolated elk herds was not commensurate with the overall
value these small populations contribute to the integrity of traditional, statewide elk populations.
It had become obvious that the need to develop both short and long-term harvest management
strategies for these non-traditional elk herds was immediate. The Team also recognized that not
only did the management need exist, but also the need to ensure that the Department’s and
Commission’s public review process be followed to determine the social acceptance of any short
or long-term management proposal.
7
The Team developed both short and long-term management recommendations, which were
presented by the Department to the Commission at the March Commission meeting. These
recommendations consisted, in the short term, of developing “Limited Elk Population Hunts.”
These hunts will take place in areas of low density, expanding elk herds where hunt success is
expected to be low. Many of these hunt areas have existed in previous hunt structures.
However, to better inform sportsmen of the conditions of these hunt areas, the “Limited
Population Hunt” will be displayed separately from traditional elk hunt areas in the annual hunt
proclamations and regulations booklet. In addition, because of the probability of low hunter
success and the difficulty of the hunt, they will not be included in the weapons hunt allocation
formulas or be considered for “Junior Only” hunts.
The Department also recommended that the Commission consider raising the bag limit on elk to
two per year, if permit tags were available after the second draw and first-come, first-serve when
permit tags become available over the counter. The Commission authorized the Department to
include these harvest strategies in the 2001/02 hunt recommendations that will be presented at
the April 21-22, 2001, Commission meeting where public comment could be taken and the
recommendations acted on in public session.
The Team also developed recommendations for long-term strategies to provide maximum
flexibility for elk management in Arizona to meet the challenges of traditional elk management
and improve our ability to manage herds expanding into non-traditional habitats. These
recommendations include developing standardized habitat descriptions that would place elk
populations into one or more management zones. These include a Standard Elk Management
Zone, a Winter Elk Management Zone, and a Limited Elk Management Zone. The Standard Elk
Management Zone consists of the traditional forest and meadow habitats where the vast majority
of Arizona’s elk herds are found. These are traditional hunt areas and would receive traditional
harvest strategies. The Winter Range Elk Management Zone is an area within the Standard Elk
Management Zone that is occupied primarily by wintering elk herds. These habitats would be
managed for winter elk, and resident, yearlong elk herds would be reduced through specific
harvest strategies. The Limited Elk Population Zones are defined as areas of non-traditional elk
habitat where priority wildlife management is not "elk use" as defined by the team report.
Each elk management zone will have to be defined and have specific management objectives, as
well as harvest alternatives that can be selected from to meet management objectives. Harvest
objectives that are proposed within the report range from traditional permit tag allocation, to
spring permit tag draws, to unlimited non-permit tags in some areas to meet management
objectives. These long-term recommendations will require evaluation of Commission rules and
will involve considerable public involvement in determining management zone areas,
appropriate management objectives, and harvest alternatives.
The Team also developed an “Outreach Plan” designed to inform all constituents of the rationale
behind these recommendations. The net results of these proposals will be a reduction in
substantiated elk depredation complaints and enhanced management for other wildlife species,
while maintaining the top-quality elk herds for which Arizona has become famous.
Other Performance Audit Reports Issued Within
the Last 12 Months
Future Performance Audit Reports
Arizona Game and Fish Commission—Heritage Fund
Department of Public Safety’s Licensing Bureau
00-9 Arizona Naturopathic Physicians
Board of Medical Examiners
00-10 Arizona Department of Agricul-ture—
Food Safety and Quality As-surance
Program and Non-Food
Product Quality Assurance Program
00-11 Arizona Office of Tourism
00-12 Arizona Department of Public
Safety—Scientific Analysis Bureau
00-13 Arizona Department of Agricul-ture—
Pest Exclusion and Manage-ment
Program
00-14 Arizona Department of Agricul-ture—
State Agricultural Laboratory
00-15 Arizona Department of Agricul-ture—
Commodity Development
00-16 Arizona Department of Agricul-ture—
Pesticide Compliance and
Worker Safety Program
00-17 Arizona Department of Agricul-ture—
Sunset Factors
00-18 Arizona State Boxing Commission
00-19 Department of Economic Security—
Division of Developmental Disabili-ties
00-20 Department of Corrections—
Security Operations
00-21 Universities—Funding Study
00-22 Annual Evaluation—Arizona’s Fam-ily
Literacy Program
01-01 Department of Economic Security—
Child Support Enforcement
01-02 Department of Economic Security—
Healthy Families Program
01-03 Arizona Department of Public
Safety—Drug Abuse Resistance
Education (D.A.R.E.) Program
01-04 Department of Corrections—
Human Resources Management
01-05 Arizona Department of Public
Safety—Telecommunications Bureau
01-06 Board of Osteopathic Examiners in
Medicine and Surgery
01-07 Department of Corrections—
Support Services