Number one is the fact that Fort Niobrara as it is now called was established as a bird refuge more than one century ago. This was the single primary mandate. Refuge indicates it was a safe haven for many sorts of wildbirds including prominent game birds. It is very rare in North America to have a refuge place with such a legacy.
To revise management practices to allow the taking of many birds shows an obvious disrespect to the many people that have worked during the past century to protect the site’s natural values. Current mandates for one special use group should not have any priority over the original intent for this game reserve.
Draft Compatibility Determination for Resident Game and Migratory Bird Hunting
“EO 1461 established Fort Niobrara National Wildlife Refuge (NWR) on January 11, 1912, as the “Niobrara Reservation . . . a preserve and breeding ground for native birds.” EO 1642 expanded the refuge on November 12, 1913” ... [page 1]
What part of this executive order does US Fish and Wildlife Service staff not understand? It says preserve and the definition of that word is given in any dictionary. This is the initial indicated mandate and later attempts to revise management to enact preferential uses shows a lack of respect to this legacy. Ongoing revisionary efforts continue to divert from the original reasons the preserve was created and as indicated repeatedly by government documents. Late era documents such as those indicated for 1997 and more recently do not supersede the original order, no matter how bureaucrats make interpretations to suit demands made by special interest groups in more recent years.
“The Service is proposing to expand hunting opportunities for resident game and migratory birds on the refuge in accordance with the Fort Niobrara NWR Comprehensive Conservation Plan.” [page 2]
This is a seemingly false statement as the CCP plan of 1997 has this reference to hunting opportunities: “Hunting Objective: Offer a limited, strictly controlled hunting opportunities for elk and bighorn sheep to facilitate removal of herd excess.” Another statement under a Public Use topic option is: The Refuge is closed to hunting” according to one alternative.
There is apparently nothing in the CCP plan that refers to the hunting of migratory birds. Now it seems to be an essential.
A January, 1998 supplementary document for the refuge CCP, further states: “Preserve, restore and enhance the ecological diversity and abundance of migratory and resident wildlife with emphasis on native birds.” The current status for public use hunting was indicated as being closed. One alternative would be to allow guided hunts for elk, deer, bison and bighorn sheep. Once again, no mention made in regards to wild birds hunting or hunting of furbearers.
“Hunting is allowed in the current open hunt area of the refuge; the NGPC established hunting.” [page 3]
How can the Nebraska Game and Parks Commission establish hunting on a federal refuge? Doubtful statement? Besides, the proposed regulation revisions could probably be beneficial to them through the sale of more licenses as they will have an opportunity to convey there are more hunting opportunities.
“As described above, this alternative will expand hunting opportunities in the current open hunt area on the refuge to include hunting of pronghorn, badger, beaver, bobcat, coyote, fox, longtailed weasel, mink, muskrat, opossum, prairie dog, porcupine, rabbit and hare, raccoon, skunk, squirrel, woodchuck, greater prairie chicken, grouse, partridge, pheasant, quail, turkey, waterfowl, dove, crow, rail, snipe, and woodcock. In addition, the refuge hunting program will better align with NGPC hunting regulations. The potential take of most resident and migratory wildlife species open to hunting on the refuge is likely negligible in proportion to regional or state harvest numbers and will not add significantly to the cumulative effects on the various species.” [page 4]
Refuge management should focus on improving conditions for species locally so they can contribute to population status on a regional or national level. The refuge should not be managed to reduce local numbers based upon regional or national numbers. To manage based upon a larger geographic indicates that local populations can be impacted. If everyone managed on a basis of this intent, local populations could be reduced and eventually populations of a large extent would be impacted and likely reduced. Disingenuous rationale prevails here.
Draft Environmental Assessment for Resident Game and Migratory Bird Hunting
“2.1 Alternatives Considered” [page 5]
The reason for the current actions to expand hunting on the refuge is a direct result of a directive by the Secretary of Interior as determined by news reports. It is seemingly not being done at the request of the NGPC, though they may have made requests previously to which the USFW interpreted as to require some compliance.
“State-permitted shotguns shooting non-toxic shot, archery, and muzzleloader weapons are allowed for badger, bobcat, coot, crow, dark geese, dove, duck, fox, furbearer, greater prairie chicken, grouse, long-tailed weasel, light geese, mink, opossum, partridge, pheasant, quail, rabbit and hare, raccoon, rail, skunk, snipe, squirrel, teal, turkey, woodcock, coyote, porcupine, prairie dog, and woodchuck.” [page 6]
It is a federal decision to allow this hunting. New regulations are obviously being modified to comply with state hunting rules season. The EA seems to try to implicate the state agency as being the source of the requested change.
Why does the environmental assessment not indicate the source of given informational details? Any authoritative details need to be attributed to a credible source.
Table 1 indicates a completely problematic potentiality: “Given the near of the refuge’s hunt area to the City of Valentine and limited availability of other public lands in area, we would expect a possible 50 percent reduction in the existing wild turkey population and 50 percent reduction in the northern bobwhite population within the hunt area. Gunfire and associated hunter activity would disrupt bird activity and likely cause dispersal.”
What does “given the near of the refuge’s” statement mean? No decision can be made on these words because they are nonsensical, and which makes the entire statement erroneous.
This is not managed hunting but a decimation. There is no sustainability indicated here. A 50% reduction! Just extirpate local populations. Certainly there are lots of wild turkeys locally, but that does not mean there should be a diminution that could lead to an overall population decline, and which might be detrimental to adjacent landowners.
As for Northern Bobwhite, there is only a limited population in the local area. This is based on particular, documented records of occurrence for Valentine and its immediate vicinity, including just south of FNNWR. To reduce the population to the extent indicated would be a travesty. The proposed alternative has nothing to do with sustainability though the mis-named purpose for sustainability was given in a press release announcing this of a change as issued in public newspapers and online. The expected outcome would be one of the worse instances ever seen locally in regards to acceptable wildlife management practices. Management intents are meant to maintain or increase population of a species … not destroy a local population. Quail deserve protection not destruction.
There are no known records for the Grey Partridge on the refuge. There is only one instance of occurrence in the local region along the Niobrara River of Cherry county and that is from 1982. It is not acceptable for so-called managers of a bird preserve to allow shooting of a particular bird type that is so rare, and actually unexpected. There needs to be a prohibition on hunting this species.
As for the American Woodcock, there is a single known instance on the refuge from 2006 near Buffalo Bridge and in the wilderness area by a bird watcher of intent. Including this species would be another instance where the changes to promote hunting could destroy the very rare occurrence locally. There needs to be a prohibition on hunting for this species.
The environmental assessment is not adequate as it does not even the majestic Trumpeter Swan. It is a species of concern and can occur at the refuge ponds, just to the east at a local pond on private property and also along the Niobrara River. This shows another instance how the EA is not acceptably adequate.
An increase in hunting of game birds can result in accidental killing by hunters. Mistakes are made in the moments when birds flush, resulting in a wrong shot. Hunters will not say anything about this but just ignore it and continue to find a suitable target. This is another reason that there should be no increase in wildbird hunting at Fort Niobrara NWR, a supposed refuge.
What is a “hare” referred to in the proposal. There are no hares in Cherry county nor in Nebraska. This is another false indication given in the indication for a pending regulation change.
There is no indication given for the potential impact of taking by hunting of furbearers. How will the local population be affected? No details given indicate conjecture. This is no acceptable in making any suitable evaluation for the pending regulations.
“While effects to wilderness values and character would be expected to increase because of expanded hunting opportunities and no longer requiring a refuge access permit, refuge visitors would still be required to abide by wilderness area rules, such as the prohibition of motorized vehicles and bicycles.” [page 19]
Effects expected and they would be more than temporary. No passive hiking during hunting season because of the noise and honestly, the threat of being shot. A bird watcher on a hike should not need to wear a hunter orange vest and cap. The expected decision would continue the decline in features of this special area as officially recognized and designated. Once again, refuge management continues the ruination of a place where particular values were known more than a century ago.
A doubling of the number of hunters [page 21]. This would mean reasons for visitors appreciating other recreational activities would be diminished.
“As a result, changes or additions to hunting on the refuge would have minor effects on migratory birds in Nebraska. Although the proposed action alternative would increase hunting opportunities compared to the current action alternative, the slight increase in hunter activity would not rise to a significant level.” [page 30]
This statement is based upon opinion. If there are one or two American Woodcock on the refuge and both are killed by a blast from a shotgun, it would be a long time until a single view of this beautiful bird might be seen again by a bird watcher or someone on a hike. The result does not conform with the requisite bird preserve mandate.
“Expanded hunting opportunities on the refuge could alleviate hunting pressure to wildlife populations on nearby public lands.” [page 31]
Is this a comment based not on fact but rather presumption? What are nearby hunting lands where there are Greater Prairie-Chicken within ten miles? Birds have a home range and upon which they are dependent for their survival. To what other public land species does this apply.
Are these state or federal property? The nearest federal property is miles away so the USFWS seems to want to start making decisions that will influence state or private property where they have no basis for decision making.
“The Service would work with the NGPC to use an adaptive management approach for the hunting program on the refuge.” [page 31]
Hunting has an immediate impact. How shooting sport relate to management is another faux statement. Climate change is related to habitat management, not recreational activities, though of course all facets of concern need to be considered in detail. The EA provides statements which are grasping for pertinence but are included to just convey required regulatory requirements.
“3.4 Mitigation Measures and Conditions Refuge staff would work in close cooperation with the NGPC to share, evaluate, and discuss available population and harvest data, make recommendations for regulation changes, and take any other actions necessary to make sure that viable populations of resident and migratory game species are maintained on the refuge.”
When and how? Statements of this sort need to indicate what is to happen and when. When will the details for this be provided to the public? How has the NGPC said that they agree to this precept.
“3.5 Monitoring inventory and monitoring of wildlife and their habitats would be done on the refuge in conjunction with our state and federal partners.”
Did the refuge staff conduct a migratory bird survey in 2019? When have surveys been done so that information can be indicated that the service is actually doing the survey they claim are being done? Does a survey once every five or ten years suffice?
Please provide further details on the 2018 consultation with NGPC on their request for more hunting opportunities on service lands? Show the facts.
Summary
The proposed regulatory changes should be rejected in their entirety. The proposal as personally considered does not indicate any respect for the legacy of the Niobrara Game Reserve created so long ago by people with vision.
If management trends continue, it seems that the USFWS should bring in center-pivot systems because then maybe could increase populations of preferred species so there can be more taking through hunting. Maybe plant some corn fields to attract pheasants or deer and maybe some elk. Deplorable options.
The proposed change in regulations would open land to taking while other decisions have been made to prevent bird watchers from taking a hike because some refuge spaces are closed to the public. Why? The word that might apply here is paradox.
There has already been enough diminution of the wildbird resources and other natural values through recent years at this first of bird refuges in the U.S.A.
When will the USFWS get back to the basics and take a long-term view that conforms to the original intent of the refuge? It is a necessity that should now be the norm, but alas it is not.
Respect the legacy is impossible since the USFWS has already decided what is going to happen according to information in the Federal Register. The situation is indicative how the agency proclaims a mission statement which does not reflect reality because of false language.
Regulatory action to promote more taking by hunting needs to be delayed until public hearings can be held. It is not acceptable that the proposed changes for the regulations are already issued in the federal register before public comments have been considered.
The USFWS federales are forcing changes based upon false statements and lack of essential consideration.
Birds are a public asset and of great importance. To let some bureaucrats make decisions about our feathered friends is not acceptable because there is too much politics going on. How wrong!
That a decision has basically already been made with a readily apparent biased view does not respect the input of the public in the process. Any legal maneuver on a federal level should not occur until there is proper consideration given to any public comments. As federales, the USFWS is trampling on the resource and very ready to ignore public comment. There was not even any consideration given to postpone any decisions until a public meeting is properly held at a later time because of this troubling pandemic.
It is very obvious that the measures to be enacted will not be beneficial to the refuge and the reasons for which it was established. For the service to claim it is being done for the sustainability of wildlife populations is a bunch of bureaucratic propaganda. This is simply a ploy to benefit a single group, shootists, some who are like fleas on a hound, pests both not welcomed and not wanted. The preferential attention and consideration being given shows how prejudice is blatantly obvious.
Some associated with a federal whatever service are not focused on sustainable conservation management but will open more lands to the taking of wildlife from refuges that myriads of conservationists consider to be havens for all sorts of flora and fauna. The FWS is absconding the public trust in changing the regulations and simply should not have any role in caring for refuges because of their ignoring the inviolate mandate to ensure an essential resource legacy of all American citizens.