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The Arizona Game and Fish Department is proposing a significant rule change that would repeal the Crossbow Permit (R12-4-216), effectively eliminating the ability for individuals with disabilities who cannot draw and hold a bow to use a crossbow during archery-only hunts. The Department claims this change is necessary due to concerns over permit abuse, an unfair advantage granted by crossbows, and the impact on wildlife management. However, these arguments appear to be largely speculative, contradictory, and ultimately discriminatory against disabled hunters.
The primary argument for eliminating the crossbow permit is that some individuals have been issued permits despite allegedly not qualifying. However, the Department has no way to truly assess an individual’s medical condition beyond a diagnosis and a doctor’s note. There is no required testing or documentation beyond what a licensed medical professional provides, and there is no practical way for Game and Fish to determine whether a person is “misusing” a crossbow permit in the field. To suggest that there is widespread abuse of the system, without any hard evidence, unfairly targets disabled individuals and assumes that those with valid medical conditions are being dishonest. Furthermore, not all crossbow permit holders would qualify for the Challenged Hunter Access/Mobility Permit (CHAMP), meaning some disabled individuals could be completely excluded from archery season under this new rule.
The Department also argues that crossbows provide an unfair advantage during archery-only hunts, particularly because archery season coincides with the rut, when big game animals are more vulnerable. However, this argument is inherently flawed and contradictory. The entire purpose of scheduling archery hunts during the rut is to give archers an advantage, as animals are more likely to be active and less wary. If fairness is truly the concern, then the entire structure of archery season should be reconsidered, rather than singling out disabled hunters who rely on crossbows. Additionally, the success rate of archers using crossbows is only marginally higher than those using traditional or compound bows, and it does not fundamentally disrupt the balance of hunting opportunities.
The claim that crossbow permit numbers have increased at an alarming rate is also misleading. The Department states that permanent crossbow permits increased by 15.8% from 2014-2018 to 2019-2023. However, the actual increase is 18.7%, with a total of 1,098 crossbow permits issued in a state that has 349,554 paid hunting license holders and issued 617,898 total licenses, tags, permits, and stamps in 2023 alone. In reality, crossbow permit holders make up a tiny fraction of Arizona’s hunting population—less than 0.3% of total license holders. This minor increase hardly justifies a sweeping rule change that removes an essential accommodation for disabled hunters.
Another argument for the repeal is that crossbows are contributing to early closures of archery season due to higher success rates. However, this ignores a more pressing issue: Arizona Game and Fish’s active recruitment of out-of-state hunters who, led by professional guides, are rapidly filling tags and leaving. Additionally, the Department has decreased the number of available tags for many big game species while simultaneously implementing predator protection programs and reintroducing wolves, which further impacts big game populations. If the concern is truly about game management, the Department should focus on these larger-scale issues rather than scapegoating crossbow hunters.
Lastly, the argument that technological advances in crossbows make them function more like firearms is inconsistent and hypocritical. If this logic is applied, then compound bows—which offer significant advantages over traditional longbows and recurves—should also be banned. Similarly, modern firearms, optics, and other advancements in hunting equipment should be outlawed under the same reasoning. Taken to the extreme, this argument would suggest we are returning to primitive hunting methods such as spears and blowguns. The reality is that all hunting technology evolves over time, and crossbows remain well within the realm of archery equipment, especially when used by individuals who physically cannot operate a compound or traditional bow.
Ultimately, this proposed rule change unfairly targets disabled hunters by eliminating a necessary accommodation without sufficient justification. The arguments in favor of repeal rely on opinion rather than concrete evidence, ignore larger contributing factors to wildlife management challenges, and contradict the very nature of archery season. Instead of removing opportunities for hunters with disabilities, the Department should be working to ensure that less advantaged hunters have a level playing field and access to hunting regardless of physical ability.
Find more information relating to the Crossbow permit on the Arizona Game and Fish website and the Arizona Register.
Send your comments to the Arizona Game and Fish using the form below or send to rulemaking@azgfd.gov
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