Dept of Interior issues proposed changes to wildlife refuges and hatcheries

[DLJeff]

The U.S. Dept of Interior has published a proposed change to regulations that would open up several million acres of wildlife refuge and fish hatchery land to hunting and fishing.

https://www.regulations.gov/document...2020-0013-0001

It's interesting (and mind numbing) to read the text. On the one hand the Administration Act tasked the D of I with managing these Federally owned lands "first and foremost that we focus our Refuge System mission on conservation of fish, wildlife, and plant resources and their habitats." Then the Improvement Act was tacked on:"The Improvement Act requires the Secretary, before allowing a new use of a refuge, or before expanding, renewing, or extending an existing use of a refuge, to determine that the use is compatible with the purpose for which the refuge was established " I doubt these lands would have been given the title "Refuge" if hunting and fishing were the purpose for which they were established. The Improvement Act established six covered uses - hunting, fishing, wildlife observation and photography, and environmental education and interpretation. Then the Recreation Act was tacked on to allow "public recreation as an appropriate incidental or secondary use only to the extent that doing so is practicable and not inconsistent with the primary purpose(s) for which Congress and the Service established the areas. The Recreation Act requires that any recreational use of refuge or hatchery lands be compatible with the primary purpose(s) for which we established the refuge and not inconsistent with other previously authorized operations."

That all sounds good, especially the part about conservation of fish and wildlife and plants being the foremost mission. It seems to me there should always be some land and water that is closed to allow the fish and wildlife a refuge to replenish, restore itself to natural behaviors, etc. And that in turn benefits all hunters and fishermen and wildlife observers and photographers, etc. So if they're going to open a bunch of space, shouldn't there also be a similar amount of space that is closed to allow those areas and associated fish and wildlife to recover. Kind of a system where areas are rotated - some opened for awhile, others closed for awhile.

I'm also thinking about "why". Is there a good reason to open these lands and fisheries now? I don't give a crap about a political reason so don't even go there. I'm talking about a is there a need? Are there adjacent areas that are over loaded and so there is a need to open more space? Are there deer herds that need culling in an area? I don't see a lot of explanation "why" these changes are needed. In fact, the explanatory material in the proposed rule making states "If the stations establishing new programs were a pure addition to the current supply of those activities, it would mean an estimated maximum increase of 24,763 user days (one person per day participating in a recreational opportunity; see Table 2). Because the participation trend is flat in these activities since 1991, this increase in supply will most likely be offset by other sites losing participants. Therefore, this is likely to be a substitute site for the activity and not necessarily an increase in participation rates for the activity." If the usage is flat, why make any changes at all? And if the proposed openings will result in less usage in other areas, why not implement the rotational system I mentioned earlier and officially close off an equal amount of area? The posting goes on to detail the economic benefits of increasing hunting and fishing but managing and helping the economy isn't the mission or focus of the NWR Admin Act. And I suspect that other than the local hotels, restaurants and bars, the majority of people in these areas would prefer the opposite. So again I ask "why"? There is no reason to make the changes.

The language also details the cost associated with opening up more land and water. For example, they estimated 5,114 more man hours just to collect, check, authorize and catalog the permits and associated paperwork. If the agencies (and government in general) need to tighten up on expenses, why add more for no good reason? And last, if wild land fires are now one of the top priorities, why would you allow more people to access more remote, rugged land, introducing the camp fires and smoking into areas that currently have little or no risk associated with fires and smoking?

I think this has to be big "No vote" from me.