Number one, why would a 2400 acre refuge that has been closed for public use for a multitude of years and still is, allow hunting but not other recreational pursuits including bird watching, photography, hiking, perhaps scientific research, etc. A changed situation for one group would obviously be discriminatory and violate my civil rights as a citizen.
The public has been prohibited to visit public property since the US Fish and Wildlife Service took control has failed in its management by not preparing a site management plan to allow multiuse activities. Yet the agency goes through the process for a single special use.
Draft Compatibility Determination for Hunting on John W. and Louise Seier National Wildlife Refuge
“’The refuge was established pursuant to The John W. and Louise Seier Living Trust. The primary purpose of the refuge is “. . . for the development, advancement, management, conservation, and protection of fish and wildlife resources . . .” (16 U.S. Code a 742fl:[a][4]) ‘. . . for the benefit of the United States Fish and Wildlife Service, in performing its activities and services.” [page 1]
This is an indicative comment of error as the refuge was not established to the benefit of the USFWS but for the benefit of the natural resources of sandhills land held in trust for the American public.
“The purpose of this proposed action is to provide compatible wildlife-dependent recreational opportunities on the refuge. The need of the proposed action is to meet the Service’s priorities and mandates as outlined by the National Wildlife Refuge System Administration Act of 1966 to “recognize compatible wildlife-dependent recreational uses as the priority general uses of the NWRS” and “ensure that opportunities are provided within the NWRS for compatible wildlife dependent recreational uses” (16 U.S. Code 668dd[a][4]). [page 2]
“Direct impacts on refuge populations of some species (for example, turkey and deer) will not be known until the hunting program is implemented.”
These impacts should be known before they occur. This is a key tenet to prevent any unwanted consequences and threats to natural resources.
Draft Environmental Assessment for Hunting on the John W. and Louise Seier National Wildlife Refuge
“The Service is proposing to open hunting opportunities for game species on the John W. and Louise Seier National Wildlife Refuge (Seier NWR) in accordance with the refuge’s conceptual management plan.” [page 3]
There is no management plan yet the USFWS has decided to open the area for hunting. There has been no public input on the management of a property donated for public uses of the area yet a federal edict will now be issued to benefit a select group. Proper decisions are not based upon some conceptual nothing.
“1.3 Purpose and Need for the Proposed Action
“The purpose of this proposed action is to provide compatible wildlife-dependent recreational opportunities on Seier NWR. The need of the proposed action is to meet the Service’s priorities and mandates as outlined by the NWRSAA to “recognize compatible wildlife-dependent recreational uses as the priority general uses of the NWRS” and “ensure that opportunities are provided within the Refuge System for compatible wildlife-dependent recreational uses” (16 U.S. Code 668dd[a][4]).” [page 5]
Once again compatible uses are more than hunting. Birding and other recreational pursuits cannot be appreciated if the public is prohibited from any appreciation of a place donated to the USFWS for public enjoyment. The service ignoring multiple uses indicates their lack of attention to all compatible recreational uses.
“Mitigation Measures to Avoid Conflicts:
“Because the refuge is not currently open to any public use, opening the refuge to hunting would not conflict with other uses.” [page 6]
How it is being opened to hunters only is sordidly shown by this statement.
Elk and antelope occurrence. These two species might be a wildlife value to the refuge, but though transient. Allowing hunting could effectively remove these species from the local landscape.
Wild Turkey hunting could also have a detrimental impact on this species. A decision is being made without any details given for the extent of occurrence of this wildbird in the local area.
A table shows the estimated extent of furbearers or migratory birds that would be taken by hunting are minimal to sport hunters [pages 13-14]. For this reason, there should be no hunting in order to retain the conservation integrity of the refuge.
“Therefore, we consider that opening the refuge to migratory bird hunting would not significantly affect the overall migratory bird populations at the flyway and national levels.” [page 14]
Hunting of waterfowl would dramatically alter the species occurrence and distribution on the refuge when hunting events occurred.
It would also have a significant and potentially ongoing disturbance factor.
“Overall, hunting impacts on other wildlife and their habitats and impacts on the biological diversity of the refuge would be insignificant.” [page 16]
This is an opinion. There are no factual details given in the environmental assessment on the direct impacts at the refuge! Who is the arbitrator on insignificant? It certainly should not be the USFWS because they are making the decision. There needs to be an independent consideration!
“American burying beetles probably occur on the refuge. They are seemingly common in the Nebraska Sandhills.” [page 16]
This comment of opinion once again shows how little the USFWS understands the biotic resources present on Seier refuge and how they can be best managed. Probably is an opinion not fact.
“We anticipate a few hundred hunter use days per year to start. This number may go up, but due to the small size of the refuge, hunter presence would decrease the abundance of huntable game. Because the open hunt area is highly visible and is otherwise off-limits all year to other members of the public, allowing hunters may cause a perception of favoritism for one user group over another. This could be alleviated in the future, if necessary, by opening the area to the general public for other uses such as photography, wildlife observation, and interpretation.” [page 19]
No kidding. Favoritism is obviously being shown. Let hunters visit but not other people interested in a variety of other sorts of outdoor recreation. This is blatant and deplorable preferential treatment that can only be called prejudice.
“The addition of hunting under this alternative would likely benefit the state and local economy through revenues generated by hunter lodging, food, gas, and miscellaneous purchasing.” [page 21]
Minimal hunting visits are projected, yet rather than focus on local economic impact statewide figures are given. What is the threshold for minimal as an earlier statement said few hundred, which is not minimal.
Since the refuge has been closed to the public there is no opportunity for passive uses to contribute to the local economy if people want to walk the prairie and enjoy the creek places. Once again selective bias on the information presented is dramatically obvious.
“The Service believes that hunting on the refuge would not add significantly to the cumulative impacts of migratory bird management on local, regional, or Central Flyway populations.” [page 22]
This is an opinion that once again shows bias. No land management decision should be based on beliefs. The agency does not have any information to indicate in any manner how the refuge might contribute to local bird populations. Is there a heron rookery? Are Dickcissels ample in number? Do snipe find it to be a haven? Do bobolink raise young and contribute to the species’ numbers because the meadows are not mown? How does the service know there are an adequate number of woodcock to support hunting? The same focus can be applied to other species, including prairie grouse.
“Research has shown that lead can be present in gut piles left by deer hunters after field dressing. Bald eagles and other raptors feed on the gut piles and may ingest the lead, leading to poisoning.” [page 23]
Use of lead ammunition should never occur on a wildlife refuge for the reason herewith indicated and perhaps others.
“The Service would adjust the hunting program as necessary to ensure that it would not contribute further to the cumulative impacts of climate change on resident wildlife and migratory birds.” [page 24]
Another comment with no basis. How and when would this occur? Annually or in five years? In ten years? This is another statement not based upon a factual statement by the USFWS.
Hunting and furbearer harvest is also based upon estimates of conjecture and not factual. Why?
“We anticipate that this action” [alternative A] “would have minimal impacts on the refuge. 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 would not add significantly to the cumulative effects on the various species. [page 25]
Once again, an opinion not based on facts is indicated. Anticipate is an unknown and/or vague concept with no actual details of factual reality presented to support the claim. The impact on local bird occurrence would be much more than “negligible” and could reduce some populations in the long term.
Summary
Respect the refuge and its resources. The Seiers should not have given their ranch to the USFWS because their expectations have not been met and are now being disrespected by federal bureaucrats. A number one reason for this special refuge is not being met. And yes, I have visited the place to bird watch before the federales closed the place to the public should be able to appreciate the eastern sandhills refuge space.
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 during this troubling pandemic time.
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.