User days are a discretion of the authorized officer of that field office, depending on goals set in management plans, etc. Permit transfers can be limited to historical use, but that is also at discretion of the office. Our office does not limit user days, even upon transfers; an adjoining office does. So for my office, you do not speak a "truth". And I have been here for 4 seasons and still going, trying to get better and better at learning the rules and helping outfitters understand them. Following government rules is never "fun" but I would like to think that most of the outfitters that work with me for their permit administration don't feel like I'm a rat. If they do, I hope they tell me, so I increase my standing to dog.
p.s. If you call the BLM office where you are interested in buying a rafting company, I'm sure they will tell you the rules so you can make a good decision.
Rec Asst, BLM Kremmling
tparvin at blm.gov