Home    back to Autumn 99 C-paper123

                                                                                                      August 31, 1999
United States Fish and Wildlife Service
Division of Refuges
4401 North Fairfax Drive
Arlington VA 22203

Comments in response to proposal for 15 new hunting and fishing programs on
11 National Wildlife Refuges in the Federal Register, August 11, 1999

We are opposed to any expansion in programs that involve killing animals in
National Wildlife Refuges (NWRs), including those listed in the Federal Register, August 11, 1999.

We have opposed hunting in NWRs since 1983 when we first learned that
hunting was permitted on land that had been designated as "refuges". Except
for National Parks, NWRs are (or were intended to be) the only large tracts
of land on which wildlife populations are allowed to function with minimal
human interference. Most people are shocked to learn that hunting, trapping
or fishing now occurs on over half of the areas they consider to be wildlife
sanctuaries rather than public hunting grounds. They would be further
shocked to learn how much of the tax-funded NWR budget is devoted to
providing opportunities for a smaller than 5% minority of Americans to kill
the very animals the refuge system was originally formed to protect. It is
particularly disturbing that USFWS is promoting additional hunting at this
time when the number of hunters has been decreasing.

Before hunting was introduced in the refuges, the proportion of hunter to
non-hunter refuges visitors was about the same as in the general
populations, c. 5% to 95%. If USFWS were serving the taxpayers, it would
have given more consideration to the interests of the overwhelmingly larger
segment of its visitors who came to observe rather than kill. The primary
consideration, however, should have been for preserving the environment and
the wild inhabitants. This is not accomplished by killing them.

Nor is it accomplished by altering habitat to favor target species or
upsetting the balance by regulating hunting to produce the maximum number of a target species like deer. By killing the biggest, healthiest animals,
leaving weaker animals to reproduce, hunting can even interfere with the
local genetic heritage of a species.

Hunting also has the disadvantage of interfering with the rights of 95% of
Americans who visit refuges to observe wildlife. In addition to safety
considerations, hunting changes the behavior of wild animals rendering them
more likely to avoid being seen by humans.

We posit that hunting in NWRs should be eliminated and want, therefore, to
register our objection to this proposed increase in hunting and fishing
programs which will further detract from the concept of "refuge".

                                                                                  Respectfully submitted,