BLM NV Hunting-Fishing Outfitter and Guide Multi-Jurisdictional SRP Policy

BLM Nevada will issue joint permits to outfitters and guides licensed by NDOW as Master Guides. The licensed Master Guide applies to the District Office where they estimate most of their business will be conducted. That District Office will become the Lead Office for the processing and administration of the SRP. The applicant should file their application in the office where the primary activity will occur. Consideration should be given if a guide lives closer to a different BLM office than the one where the primary activity will occur. However, an applicant cannot file an application in an office where no activity will occur. The Las Vegas Field Office will be excluded from this policy as administration of Outfitter and Guide Special Recreation Permits in the area are complicated by local regulations and require special attention. Permission for Outfitter and Guide SRPs in the Southern Nevada District Office should be submitted directly to that office.

Process:
New Permits/Renewals: New applicants will provide the following documents to the Lead Office by May 31st annually:

• Form 2930-1, Special Recreation Application and Permit • Copy of current NDOW Master Guide License
•  Annual Operating Plan and/or business plan
•  Proof of Insurance/Certificate of Liability
•  Minimum $110 annual permit fee or estimated use fees

The Lead Office will review the application, operating plan, and related documents for completeness and contact the applicant if any deficiencies are found. Once the application package is accepted, the Lead Office will post the required documents to the NV 930 Recreation SharePoint site (or its equivalent) at: Recreation & NLCS Sharepoint and notify each affected Nevada District Office by June 7th annually. The Lead Office will serve as the primary contact with respect to all actions associated with the permit except for Southern Nevada District Office (SNDO) portions of the permit, which will be coordinated directly between staff at SNDO and the permittee.

Each affected District Office will review the documents on the Sharepoint site and verify that the use complies with their Resource Management Plan and that the National Environmental Protection Act (NEPA) documentation is completed for the proposed use. A CX may be used in other special areas such as National Monuments or National Conservation Areas per section B.3 of WO-IM-2018-078. The IM can be found here: https://web.blm.gov/internal/wo-500/directives/dir-18/im2018-078.html

Note: The use of a CX is not authorized for Designated Wilderness. A separate authorization may be required from each District Office with these areas. For more information on NEPA requirements in WSAs please consult pages 1-43 and 1-44 of BLM Manual 6330.

Due to the complexity involved with the coordination of a single SRP involving multiple District Offices, it is crucial that the application be processed by each affected District Office in a timely manner. Each supporting District Office will have their review completed and their authorization letter uploaded to the Sharepoint site with any office specific special stipulations by July 7th annually. This allows a month of review and processing time for each supporting office.

To reduce the number of signatures for this process, each affected District Manager will sign a letter of authorization documenting Field Office Manager concurrence, NEPA compliance and any additional stipulations for the affected District Offices. The letter of authorization from each District Office, will serve to allow use by the Guide under the SRP issued by the Lead Office. After the Lead Office receives all authorizations, the Lead Office will issue the SRP and send an authorization letter permitting the Master Guide and any listed sub-guides to take clients on all lands managed by BLM that have been approved. This would include the SRP form (2930-2), the statewide outfitter and guide stipulations and stipulations for all offices for which the permit is authorized. The application must be processed by July 15th at the latest to allow outfitters time to prepare for the hunting season. Authorizations for each year may be batched to increase efficiency.

The Lead Office will ensure all electronic copies of the permit, authorization letters, approval letter and Special Stipulations are posted on the SharePoint site. Each office will be responsible for providing the Lead Office with any additional information regarding the permit including telephone conversation records, monitoring, field contacts, etc., which will become part of the permanent file.

A new permittee will be authorized initially for two seasons. After two seasons, the permittee may be authorized for a ten-year permit provided they have an acceptable or better performance rating. A ten-year permit is preferred to encourage efficiency.

Guides are REQUIRED to notify the Lead Office prior to guiding trips in the field. When possible, guides should notify the Lead Office of a trip at least two weeks in advance. Email is the preferred method to ensure documentation. However, it is not uncommon for clients to contact guides on short notice, so some flexibility is necessary. The use of the Individual Trip Plan is no longer required.

The Lead Office will ensure other affected offices are notified and will post the latest information on the SharePoint site so ORPs and law enforcement officers are aware of the activity and the location. All information relating to the trip, such as extensions of the 14 day stay limit, will be posted to the SharePoint site. All information regarding the permit posted on the SharePoint site can be viewed by anyone authorized to access the site.

If the District Office does not have an Outdoor Recreation Planner (ORP) assigned at the District Level, an ORP at the Field Office level will be assigned to process O&G SRPs for the District.

Annual Validation for Existing Permits: Once permitted, each guide will be required to provide annual validation information to the Lead Office by May 31st annually. Lead ORPs should send letters to guides early in the year requesting validation information by the due date. Depending upon the result of the annual evaluation, the permit may be validated for another year, placed on probation, or denied, based upon compliance or violations noted. The term “validate” is used in handbook H-2930-1, to mean the paperwork provided on a yearly basis by a guide to update their permit. To have a current permit validated, the permit holder is required to provide the following documents to the Lead Office by May 31st:

• An updated Annual Operating Plan if necessary
• Copy of the current NDOW Master Guide License
• Post Use Report form with attached copies of the NDOW Client Record Forms
• Proof of Insurance/Certificate of Liability for the upcoming year
• Commercial Use Fee of 3% of Gross Receipts or the annual minimum permit fee of $110.00 (Discounts for activities off Public Lands may apply.)

The minimum annual permit fee or commercial use fee must be paid each year. The $110.00 minimum permit fee may not be carried forward from one year to the next. However, overpayment of any estimated fees may be applied to the following year’s use. If the permit holder is found in compliance, the Lead Office will send a validation letter to notify the Guide that all pertinent materials have been received and the permit is validated for another year. The validation letter should be sent so that it is received by the Guide no later than July 15th annually. This date is established to ensure the Guide is up to date prior to the upcoming hunting season beginning in August. The validation letter along with any additional authorizations must be kept with the original permit and carried with the Guide while conducting activities in the field. Contact information for each District Office will also be attached to the letter.

Overview of Timeline:

May 31st: Due date for all required documents from permittees for both new/renewed permits and annual validations*

June 7th: Lead office must have all documents uploaded to Sharepoint site including completed previous year annual evaluations.

July 7th: Supporting offices must have their letters of authorization uploaded to the Sharepoint

July 15th: Due date for permit/annual validation being issued including letters of authorization from each district. Must be received by the guide by this date.

*If the outfitter submits a complete permit application (including all documents) later in the year, the permit timeline may be adjusted.

Approved Guide List: In addition to sending the validation letter/permit, the Lead Office will compile a list with the status of each guide indicating if their permit has been authorized. The list will be added to the Statewide Yearly Authorized Guide List on the SharePoint site in the folder for the upcoming season by August 1st. Each Lead Office will update the spreadsheet with the status of each Guide’s permit. The NVSO project lead with share this list with NDOW prior to each hunting season. It is imperative it is kept accurate to facilitate NDOW’s monitoring of NV BLM permits.

Standard Stipulations: Standard and statewide stipulations are included as part of the Permit. If affected District Offices have special stipulations in addition to the standard stipulations, they will provide those to the Lead Office by posting them on the Sharepoint site prior to authorization.

Fees: Commercial Guides are required to pay the minimum $110.00 annual permit fee or 3% of their total gross receipts minus any deductions or discounts whichever is greater to the Lead Office, per guidance in the Recreation Permit Administration Handbook (H2930-1).

Fee Calculations: If the final commercial fee calculation (gross x 3% minus and applicable deductions and discounts) is less than $110.00, the minimum annual permit fee of $110.00 will be retained. If the fee is greater than the $110.00 minimum, the $110.00 will be deducted from the total.

Fee Distribution: The Lead Office would retain all recreation fees (L1232) for the permit. In past years calculations have been made to distribute fees proportionately.

Annual Evaluation: The Lead Office will complete an annual evaluation of each permit before the permit is issued on or before July 15th annually. The evaluation will be based on information provided by all District Offices regarding permit compliance as well as the required post use reports and documents provided by the permit holder. Each District Office is responsible for their own permit monitoring and for informing the Lead Office of any issues that may affect the annual validation.

Documentation of Annual Validation/Authorization: All letters authorizing use must be signed by the Authorized Officer (AO) for the Lead Office. This will include the original SRP and any subsequent letters of authorization. All letters must be received by the guide by July 15th.

Monitoring: The purpose of monitoring is to ensure the permittee is in compliance with all stipulations, terms and conditions of the permit. Monitoring will be accomplished administratively in the office and in the field. Administrative monitoring may include comparison of pre-trip notification reports to post use reports provided to BLM and NDOW and verification of their Master Guide License with NDOW. A current list of licensed Master Guides is available at the NDOW website at http://ndow.org/hunt/resources/guides/. Field monitoring will include contact by BLM resource staff and/or BLM and NDOW law enforcement officers. For more information please see page 1-52 in Handbook H-2930-1.

The lead O&G ORP in the NV State Office will provide NDOW a list of Master Guides that have current SRPs and annual validation letters by August 1st of each year. The Lead Office may contact NDOW with any information related to a Master Guide, their permit, or their operation.

Documenting letters of non-compliance, suspension/termination of permit privileges: A letter must be sent to the permittee documenting all decisions to suspend or revoke a Master Guide’s permit privileges and must be signed by the AO. The letter must indicate the specific period of time of the permit is suspended. Since letters of suspension/termination may be used in criminal or administrative proceedings they should be sent by certified mail. H-2930-1 BLM Recreation Permit and Fee Administration Handbook goes into detail on this subject on pages 1-52 through 1-57. Any Office considering a less than acceptable rating or issuance of a letter of non-compliance should consult this section in the manual.