06 July 2020

Deplorable State Agency Response to Proposed Federal Refuge Regulation Changes

This is the response by the Nebraska Game and Parks Commission to management regulations changes proposed by the U.S. Fish and Wildlife Service for national wildlife refuges, primarily in the sandhills of Nebraska. Comments prepared by James E. Ducey of Valentine on June 17, 2020.
June 5, 2020 dated response signed by Tim McCoy, deputy director of NGPC as provided to the federal service and personally obtained via an email request to the state agency.

“To whom it may concern,

“The Nebraska Game and Parks Commission (Commission) is pleased to support the additional hunting and fishing opportunities that will be available to our constituents on our beautiful National Wildlife Refuges in Nebraska. We are strongly supportive of the proposed changes for hunting and fishing opportunities on Crescent Lake, North Platte, John and Louise Seier, Valentine and Fort Niobrara National Wildlife Refuges.

“We are very pleased to see expansion of youth seasons where appropriate, and the addition of some “youth only” opportunities as well. We also are very supportive of the refuge regulation changes that align with Nebraska hunting and fishing regulations. These changes will simplify regulations on the hunting and fishing public by making them simpler and more consistent across refuges and other federal and state public lands. We also appreciate the opportunity to provide input and suggestions on potential and proposed changes, and are very pleased with the results of those communications with our valued federal partners that manage the refuges.

“Hunting and fishing are important to Nebraskans and also are a big part of our tourism industry. The changes proposed will add opportunities for hunting and angling on refuges that will be enjoyed by resident and non-resident constituents shared by the Commission and our federal partners. The National Wildlife Refuges in Nebraska, where only 3% of the land is publicly owned, are absolute treasures to our constituents. We applaud the U.S Fish and Wildlife Service for considerations to open up more public hunting and fishing while also simplifying regulations and aligning them with ours. These changes will help us protect the time-honored traditions of hunting and fishing enjoyed by so many of our residents, and without harming the original intent of the refuges.

“President Theodore Roosevelt, a great hunter and passionate conservationist, is credited with starting the National Wildlife Refuge system in 1903. He saw a need to protect wild places, with high-quality habitats and abundant wildlife populations, for the benefit and enjoyment of the public. However, he also was a proponent of wise and regulated use of our natural resources, including our game species. We believe Mr. Roosevelt would be pleased with these proposed changes, and would agree that they do not interfere in any way with the statutory purposes of the refuges. Hunting and fishing on these properties will not have negative impacts on the properties, their habitats, bird nesting and reproduction or wildlife populations.

“These proposed changes are in alignment with the mission of the National Wildlife Refuge System (https://www.fws.gov/refuges/about/), which is “to administer a national network of lands and waters for the conservation, management and, where appropriate, restoration of the fish, wildlife and plant resources and their habitats within the United States for the benefit of present and future generations of Americans.” On the website, the U.S. Fish & Wildlife Service also states the following about the National Wildlife Refuges: “Wildlife conservation drives everything on wildlife refuges, from the purposes for which each refuge was established, to the recreational activities offered, to the resource management tools used.”

“The “North American Model of Conservation” involves users contributing to wildlife management through excise taxes on firearms and ammunition sales through the Wildlife and Sportfish Restoration Program (WSFR). Increased hunting opportunities on our National Wildlife Refuges will help support wildlife management and conservation. As well, these changes will help support Recruitment, Retention and Reactivation (R3) efforts to reduce declining hunter numbers. The Commission has been a leader in R3 efforts in the state and nationally, trying to increase opportunities and improve satisfaction among the hunting and fishing public. We feel strongly that these expanded opportunities on National Wildlife Refuges will provide benefits to “R3”. We also believe the expansion of opportunities for more public use of refuges will increase constituent support for the value of conservation both on refuges and for conservation on private and public lands beyond refuge boundaries.

“The Commission annually produces a “Public Access Atlas” that includes all publicly-available hunting and fishing access opportunities across the state. This includes all seven of Nebraska’s National Wildlife Refuges. When these new changes are approved, the Commission would be more than willing to work with local or regional U.S. Fish and Wildlife Staff to promote them in the Public Access Atlas and provide website links to appropriate information.

“We appreciate the work and effort by the U.S Fish and Wildlife Service and Refuge Staff in bringing forward these hunting and fishing opportunities and aligning regulations for the public. We also look forward to continuing to work with the Service and Refuge staff to explore additional opportunities.”

Comments by Ducey

This letter conveys a deplorable response by a state agency which is responsible for management of all fish and wildlife species in the state for all residents, not just a select group of people that fish and hunt. Instead there is a complete agreement to increase hunting and fishing, obviously so the agency could sell more licenses, in one particular reason.

The agency could not even provide a detailed analysis and review to the proposal, and instead relied on a trite written response to the proposals by the federales. The concept of refuge is wrongly ignored.

For the agency to make a false claim that “We believe Mr. Roosevelt would be pleased with these proposed changes” shows a complete disrespect for the legacy of this man. There is absolutely no reason that such an absurd statement should be made, never, ever!

NGPC wants wild places conserved so hunters can hunt and kill more animals, in my opinion.

And this statement “When these new changes are approved” indicates that the agency is indifferent to any contrary public comments as the regulations will be approved by the USFWS despite notable opposition to the proposed regulatory changes.

As for the agency to support an exploration of “additional opportunities” indicates that the NGPC would like to see how additional taking of fish and wildlife species might occur. This is indicative of the current, ongoing assault on native fish and wildlife – notably wildbirds – being done, most notably by the federal officials.