Refuge Hunting May 2026

How to Comment on the Federal Register

The direct link to submit a comment is:
https://www.regulations.gov/commenton/FWS_FRDOC_0001-2456
That goes straight to the comment form. No searching, no docket number hunting. Just paste and go. You can also link to the full docket page if you want people to read the rule first:
https://www.regulations.gov/docket/FWS-HQ-NWRS-2026-1223

Scientific citations carry weight in a federal comment — and we’ve filed ours. But what the agency also needs to hear is you. Comments grounded in personal experience and genuine values are read. Tell them you hike Necedah. Tell them you photograph eagles. Tell them you believe there should be places on this earth where wildlife is simply left alone — not managed, not harvested, not accessed by ATVs at 6 AM during nesting season. Tell them public lands belong to everyone, not just people with guns. Tell them you’re tired of a small minority of users dictating what happens to land held in trust for all of us. You don’t need a law degree. You don’t need citations. You need to mean it — and say it in your own words. One honest paragraph from a real person who gives a damn is worth more than a copied form letter.


FACT SHEET: Scientific & Statistical Basis for Opposing FWS Refuge Hunting Expansion
In support of GLWA comment on Docket No. FWS-HQ-NWRS-2026-1223
ON WHO ACTUALLY USES PUBLIC LANDS
The 2022 USFWS National Survey of Fishing, Hunting, and Wildlife-Associated Recreation — the agency’s own data — found that 148 million Americans participated in wildlife watching compared to 14.4 million hunters. That’s more than 10 to 1. Wildlife watchers spent $250 billion on their activities versus $45 billion for hunters. Roughly 57% of Americans 16 and older watch wildlife. Only 5.5% hunt.
Source: U.S. Fish & Wildlife Service, 2022 National Survey of Fishing, Hunting, and Wildlife-Associated Recreation (published October 2023). fws.gov


ON LEAD AMMUNITION AND EAGLE POISONING
A landmark 8-year study published in the journal Science examined 1,210 bald and golden eagles across 38 states. It found that nearly 50% had chronic lead poisoning from ammunition fragments, and a third had acute lead poisoning. The study found lead is actively slowing population growth rates for both species. Lead poisoning occurs when eagles scavenge gut piles and carcasses left by hunters — ammunition fragments throughout the animal on impact.
Source: Slabe et al. (2022). “Demographic implications of lead poisoning for eagles across North America.” Science, 375(6582). doi.org/10.1126/science.abj3068
An estimated 20 million wild animals of all species die annually from lead poisoning from ammunition, including ground-feeding birds that mistake fragments for seeds.
A Cornell University study (2024) identified bald eagles as the most vulnerable of 30+ scavenger species in New York, with nearly 40% showing toxic lead exposure levels from hunters’ ammunition.
Source: Eleftheriou & Schuler (2024). Cornell University / Wildlife Society Bulletin.
Lead ammunition has been banned for waterfowl hunting since 1991 due to documented poisoning of eagles and waterfowl. This proposal rolls back non-lead requirements that were already finalized at nine refuges.


ON HUNTING DISTURBANCE TO NON-TARGET SPECIES
A 2025 peer-reviewed study published in Ecological Applications using 122 camera traps in a national park found that hunting is a stronger driver of wildlife behavioral disruption than recreational activity alone — and critically, that non-target species not being hunted also increased temporal avoidance of trails and human presence when hunting pressure was high. The study concluded that strictly reducing hunting in space and time while concentrating recreation in certain areas “has great potential to reduce temporal avoidance of humans by wildlife.”
Source: Peters et al. (2025). “Temporal displacement of the mammal community in a protected area due to hunting and recreational activities.” Ecological Applications. doi.org/10.1002/eap.70118. PMC12580470.
A separate study on waterfowl found that refuges closed to hunting had 4,010 duck-days/ha over 50 days versus 911 in hunting-permitted refuges and only 56 in non-refuge areas — demonstrating the measurable conservation value of protected sanctuaries.
Source: Bellrose (1954), cited in Conservation Evidence, “Use wildlife refuges to reduce hunting disturbance.” conservationevidence.com/actions/278


ON POACHING AND ENFORCEMENT
A multi-year Boone and Crockett Club / Wildlife Management Institute study — the most comprehensive poaching research ever conducted in the United States — found that an estimated 95% of big game poaching incidents go undetected annually, costing more than $1.4 billion in lost conservation value. Law enforcement officers, landowners, and hunters all rated illegal take as a serious to extremely serious problem (88–97% of respondents).
Source: Gassett & Blevins, Boone and Crockett Club “Poach & Pay” Research Initiative (2025). Wildlife Management Institute. wildlifemanagement.institute
This proposal expands access to 111 refuges while the administration has simultaneously cut refuge staff and law enforcement. Expanding access without enforcement capacity directly exacerbates documented poaching rates on public lands.
ON WHOOPING CRANE MORTALITY FROM SHOOTING
Since the eastern migratory population of whooping cranes was reintroduced — with Necedah NWR as the primary nesting site — at least 1 in 10 deaths in the population has been caused by shooting, including documented misidentification incidents where hunters killed whooping cranes believing them to be sandhill cranes.
Source: International Crane Foundation. “Sandhill Cranes, Crop Depredation and Hunting in Wisconsin.” savingcranes.org
In February 2026, the Wisconsin Legislature rejected AB-117 mandating a sandhill crane hunting season, with the International Crane Foundation citing this misidentification risk as a primary basis for opposition. Expanding hunting at Necedah immediately following this legislative outcome is inconsistent with the documented science.