Valentine NWR was established decades ago in the 1930s for the conservation and management of migratory birds and other wildlife. It was not established so taking can occur associated with killing hunts. It is supposed to be a refuge. The proposed change in regulations is a direct attack on the purpose for refuge establishment and continues a trending diminution of the value of these lands for many essential natural resources.
Preferential regulations seem to be more important to the USFWS than the need to make certain that native flora and fauna continue to occur now and into the future for many generations of enthusiasts of the outdoor sandhills.
Conservation of wildlife should be the primary goal so any decision to increase the taking of wildbirds and furbearers needs to be vehemently opposed. This is a decision that should be derived from local conditions, not the spewing of national statistics as indicated in the federal government documents done by federales that do not even reside in Nebraska making forceful decisions. Quit dealing in the need for shootists to wreak death to native wildlife.
Draft Compatibility Determination for Recreational Hunting
Sustainable management and recreational hunting are two sordid twists in language being used by so-called staff responsible for management while promoting a single intent purpose.
“Refuge Purpose(s): The refuge was established by Executive Order No. 7142, August 14, 1935, “... reserved and set apart ... as a refuge and breeding ground for migratory birds and other wildlife.”
Refuge is not a concept. It is the reality as firmly established when the government pushed to acquire multiple private ranch properties for an indicated purpose. It was not created to provide a place where hunting is a primary promotion.
“This plan proposes to open or expand existing migratory bird hunting from 2,721 acres to 28,918 acres.” [page 1]
How was the proposed increase in acres of area of intent determined? How the need determined? Why was not the entire refuge opened? What were the criteria? No information is given on how this was done with public input. It is very noticeable that most of the areas to be opened are readily accessible highways or improved road, thus making access the easiest of many places. Let them hunt, you will not even have to walk very far. Just stop on the road, hop out and shoot!
“Small Game, Upland Game Bird, and Big Game Hunting Plan” [page 1]
Where is this document, apparently issued in 2019, available? What were the USFWS actions to make certain the public was aware of this plan? How was it implemented? This is public information which should be readily available upon request.
“The NWRSAA mandates” [page 2]
So a national federal bureaucrat decides and local USFWS staff just respond to conform to the demand. Any recent decision is superseded by the original documents that indicate the reason why the refuge was established. The original intent is what is most important and essential to direct management efforts.
“Public Review and Comment:” [page 3]
There have been no public meetings on this matter. The public was given only 22 days to deal with the issued documentation. Also, the USFWS has already issued their pending decision in the Federal Register as of April 8. How sordid that the agency cannot wait until comments were received from the public and suitably considered. This whole effort is a perfect example of federales shoving a decision upon the people of the sandhills and area community that enjoy natural resources without taking by hunting. How was this determination made based upon facts? Not interference! Interference will occur because of the taking by shootists intent on killing wild life for their so-called sport and all of its associated disturbances. Changes with hugely interfere? Present the facts not opinion. Because one dead snipe interferes with its life. Same for waterfowl and prairie chickens. Let the birds die seems to be a mantra of the USFWS. Protection of the refuge birds should reign supreme on a refuge created for their protection. This document indicates a preference to allow killing of so many special birds! Please explain how a refuge prepared a document because a refuge does not know how to write? This is the attribution indicated on the title page. Who is responsible for the words? Project leader without any attribution is also not suitably proper! Please explain this obvious lack of a local name! Why is the majority of a national refuge proposed to not be not a refuge? Is there not a limitation of place where wildlife can be taken. Refuge indicates safety. To think that this is actually a refuge is erroneous in multiple ways. Some many birds can appreciate a haven but the managing federales agency has decided that shootists will have their way so they can kill and kill anytime during a “season”, but of course they say it is being done in accordance with state regulations. These are details from that plan. There is no indication in the wrongly directed guiding document during historic times that hunting would be permissible for rail, snipe and woodcock. How about partridge? Where are the facts? Rail occur very rarely in the multitude of bird occurrence report at this publicly owned refuge. Will shootists be allowed to kill King Rail, which are very rare on this land space? Why is that an agency which conveys a mission statement to conserve wildlife resources for citizens of our nation and state is pushing forth a missive of destruction? Virginia Rail, which are regulars on this refuge land, are now facing a visit that can lead to their destruction. How about the ultra rare Black Rail. The same applies to Wilson’s Snipe! As for the American Woodcock, there is no known record for this species at VNWR. Yet the federal documents issued indicate a season should be opened. Where is the basis of real occurrence for this species’ conservation instead of some decision being made to allow them to be shot? Obviously a decision is being made to kill a rare or phantom species of no known occurrence. How is a kiosk a “non-comsumptive public use” since it is signage. Associated ground is maybe an acre or two. Rare occurrence is conveyed by findings yet hunters would be allowed to kill any of them during a sanctioned season. What is the population of the so-called "northern bobwhite quail" as derived from facts? Is this some new subspecies that you are indicating as occuring. Having following bird taxonomy for decades, this is a faux indication not based in a reality. There are a very few known occurrences for the area of specificity based upon my bird database for the region. Yet the agency will allow the very few numbers to be killed by shootists. There is no known record for Gray Partridge in the Valentine Lake District. Yet the regs of some inane fedarales want to open a season. There is absolutely no basis for any decision regarding this species. How and when and by whom? This is a vague statement with no indication of any reality of agreement or expectation to meet the stated intent. It needs to be noted that the Nebraska Game and Parks Commission will most likely be supportive of the regulation revisions because they could probably sell more hunting licenses as the state agency can convey there will be a notable increase in hunting opportunities. What is the basis for these estimated details? Facts are given but there is no attribution. Does it pertain to the world, or maybe just Nebraska, but it is blatantly obvious it does not apply to VNWR since no site specific details are given. Estimates do not suffice. Has there been any documented damage due to any of these species at VNWR? Indicate the local facts. Estimates convey nothing of any reality. The establishing legislation indicated that the entire refuge be a haven for birds. Now there is an effort to reduce that extent by a rather significant amount. It is absurd how federales twist language. The entire refuge is an inviolate place no matter what some perp in Washington decides. Indicate the language in the original "establishing legislation" that proves it was establishing for any sort of hunting related reason! These are expectations of delusion. The USFWS has no information to provide actual facts whether or not there is even a huntable population. There is no record known that American Woodcock have ever been seen at VNWR. Another statement based upon conjecture not fact. Spread the hunters upon more refuge lands and that means further impacts. Anticipate is an opinion not fact. Anticipation does not convey any sort of reality, but is a vague word being used to promote an agenda. Predators of nongame species? What are they? Perhaps there are predators of non-game species but the given language is tepid at best. The killing of predators will in no way increase the exposure to outdoor experiences. More worthless verbiage. Kill some species and then indicate how that is beneficial to outdoor experiences. Have you heard of the term "balance of nature"? What would be the mitigation measures? When would they be implemented? By whom? Why wasn’t the very important and iconic Blandings Turtle considered in the EA? More road traffic when the turtles are traveling across the land during autumn movements to find a winter haven might result in greater mortality by these critters getting crushed beneath truck or car wheels. Any lack of consideration for this species is indicative on how this EA is lacking. What are the management activities that occur during the hunting season? Please indicate the specifics. What is the basis for this statement that is given as a fact? This statement needs to be based upon real data not opinion. No decisions should be based upon beliefs. The reality is how the change in regulations will impact local populations which are essential for the overall populations so details need to be specific to VNWR. Why isn’t the Trumpeter Swan not being considered in the EA? A great expanse of wetland which should be suitable for this species. Few of them are known to occur. This is a species of concern which deserves attention as is has for decades. Will an increase in hunting possibly result in mistaken identity and subsequent deaths? This is an important item which has seemingly been ignored. The planned implementation of the indicated regulatory changes is some misdirected missive not based upon any sort of reality and needs to be rejected, now. Make decisions based upon facts not delusional and preferential political actions. The natural resources need to be Number One in importance! There is not even any real indication how management changes might be adapted to nurture populations that will be impacted by further, so supposedly regulated killing. There will be several months during each year when wildlife will be chased so they can be killed for so-called sport. 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.
Draft Environmental Assessment for Small Game, Upland Game Bird and Big Game Hunting
“1.1 Proposed Action The Service is proposing to expand hunting opportunities across the Valentine National Wildlife Refuge (NWR). The refuge consists of 72,350 acres total (67,828 open for hunting, 2,721 open to waterfowl hunting, 1,801 closed to hunting [see Figure 1]).” [page 3]
“Hunting would be expanded for upland game, big game, and migratory birds on the refuge in accordance with the 1999 Valentine NWR Comprehensive Conservation Plan (CCP).”
“The primary non-consumptive public use areas of the refuge remain within the Little Hay Wildlife Drive, Fire Tower overlook, and Refuge Kiosks.” [page 7]
“We expect the harvest of each of these species to be between 0 to 2 animals per season given the limited suitable habitat or low population numbers within the refuge hunt area. This level of harvest should not have negative effects on the local or the statewide populations of these species.” [table 1]
“Given the low number of northern bobwhite quail and gray partridge on the refuge, the number of hunters pursuing these species would be low (less than ten hunters). Incidental take of these birds while hunting other upland game would be estimated at less than one daily bag limit for these species for the year (less than six and less than three, respectively)." [page 13]
“Refuge staff would work in close cooperation with the NGPC in sharing/evaluating/discussing available population and harvest data, making recommendations for regulation changes, and any other actions necessary to ensure that viable populations of resident birds are supported.” [page 13]
“Harvest
The estimated harvest during the 2017/2018 season was lower compared with the five-year average. Mink, raccoon, and opossum showed the greatest decrease (down 64 percent, 36 percent, and 20 percent, respectively). Coyote, muskrat, and bobcat showed an increase compared to the five-year average (up 27 percent, 10 percent, and 7 percent respectively).” [page 14]
“Regulated harvest through hunting and trapping seasons is an important management tool needed to control populations and damage that these species can cause.” [page 14]
“Areas of the refuge open to hunting would be increased by about 26,000 acres. Under this alternative, approximately 40 percent of the refuge would be open to hunting with 60 percent of the refuge closed to hunting. The latter would provide 40,000 acres of the refuge where migratory waterfowl would continue to be protected from any hunting pressure and disturbance. This complies with provisions of the refuge’s establishing legislation.” [page 15]
“We expect that the harvest of American crows and woodcock would be between zero and two birds due to low interest from hunters (in the case of crows) and low population numbers (in the case of woodcocks). For coots, sora and Virginia rails, common snipe, and American woodcock, we expect that the harvest would be less than the bag limit for each species (15, 10, 8, and 3, respectively).” [page 16]
“Additional hunting opportunities would disperse hunters over a larger portion of the refuge and provide enhanced hunting opportunities. We anticipate that there would be only a small increase in the number of hunters visiting the refuge (two or fewer additional hunters) due to the low population density of north-central Nebraska and abundant public hunting land near the refuge.“ [page 16]
“We anticipate minor to moderate beneficial impacts with respect to slight declines in predators of many non-game species; and increased exposure to outdoor experiences that potentially would include observations and educational opportunities related to non-game species.” [page 17]
“Impacts of hunting on listed species, especially using the refuge from September through February, could increase with increased hunting opportunities under the proposed action. However, we would apply mitigation measures mentioned above under this alternative and expect to limit the effects of hunting to acceptable risk levels (minor).” [page 19]
“The refuge would continue to engage in habitat management activities during the hunting season to ensure that the refuge meets its other management objective...” [page 25]
“Expanded hunting opportunities could provide improved benefits to the local, regional, and state economy compared to current conditions.” [page 26]
“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 because the percentage likely to be taken on the refuge, though possibly additive to existing hunting takes, would be a very small fraction of the estimated populations.” [page 30]
Summary