Opinion
By Larry Keane
Congress had sharp criticism for a proposed rule that would prioritize a climate change agenda over a proven hunting conservation strategy that has benefitted wildlife conservation and sportsmen and women.
It’s not the first time, either.
The U.S. Fish and Wildlife Service’s (USFWS) proposed Biological Integrity, Diversity and Environmental Health (BIDEH) rule update would implement a rule to “combat” climate change at the expense of wildlife conservation through hunting and angling. The proposal would put National Wildlife Refuge System (NWRS) decisions based solidly in Washington, D.C., and not in the hands of local biologists who are best positioned to make policy decisions for sustainable conservation.
If this all sounds familiar, it’s because it is. This is the same sort of rule making process USFWS embarked on when they unilaterally banned the use of traditional ammunition and lead-based angling tackle in wildlife refuges. The rule was part of a “sue and settle” scheme hatched with the Center for Biological Diversity (CBD) in a federal court case filed in Montana where instead of opposing the lawsuit the USFWS entered into an immediate settlement discussion with CBD. The rule, opposed by NSSF and published last year, offered sportsmen and women a “bait-and-switch” that opened 48 new distinct hunting opportunities across approximately 3,000 acres of National Wildlife Refuges (NWRs) but implemented a phased plan to ban the use of traditional ammunition. Despite the Biden administration’s promise to “follow the science,” those making these policy decisions are ignoring the data.
Activism Over Conservation
The BIDEH rule proposed updates would emphasize climate change policies over the stated mission of the very reason NWRs exist. The 1997 National Wildlife Refuge System (NWRS) Improvement Act states that the system of over 500 refuges consisting of more than 850 million acres “was created to conserve fish, wildlife, and plants and their habitats” by “providing Americans opportunities to participate in compatible wildlife-dependent recreation, including fishing and hunting, on System lands and to better appreciate the value of and need for fish and wildlife conservation.”
That’s the “user-pays” system, also called the North American Model of Wildlife Conservation. That’s supported by the Pittman-Robertson and Dingell-Johnson excise taxes. Pittman-Robertson excise taxes are specific to the firearm and ammunition industry, which has paid out over $27 billion since 1937, when adjusted for inflation. Hunting and fishing were the priorities of the BIDEH policy since 2001. The proposed “new practices” discourages predator control and agriculture practices on NWRs. According to the USFWS’s proposed BIDEH updates, these proven conservation practices are now considered “anthropogenic stressors.”
USFWS claims these changes are needed because of “the universal and profound effects of climate change on refuge species and ecosystems.” Except, there’s no scientific data to show that. Changing the BIDEH rule to satisfy eco-activists would be contrary to the 1997 Organic Act, which directs a strong and singular wildlife conservation mission for the Refuge System. It would also centralize authorities with Washington, D.C., bureaucrats over the boots-on-the-ground managers who are in the best position to make these conservation decisions. If formalized, the rule would be detrimental to conserving habitat for game species and other native wildlife. This draft rule was developed without input, either formal or informal, from the sportsmen and women community who have a longstanding partnership in crafting sound wildlife conservation practices. If promulgated in its current form, this could have devastating negative consequences for sportsmen and women, not to mention the habitat and wildlife they work to conserve.
Congress Not Buying It
There was bipartisan angst in Congress over this proposed rule. The U.S. House of Representatives Subcommittee on Water, Wildlife and Fisheries held a hearing where Members from both sides of the aisle took aim at the “woke” rule that puts environmentalist climate policies ahead of proven conservation practices.
“I’ve seen on fish and wildlife refuges in my district where management practices have been put in place and the wildlife has flourished and including ‘ag’ management practices,” explained House Natural Resources Committee Chairman Bruce Westerman (R-Ark.) “So, it seems like in the name of science, fish and wildlife is pushing false science and trying to make it to where we can have this utopia where you just do what the federal government seems to be wanting to do with all public lands. It’s put an imaginary fence around it and say, we’re going to let it be a wilderness area and everything’s going to be okay. And we know that doesn’t work.”
Rep. Mary Peltola (D-Alaska) pointed out that many native Alaskan populations have long-relied on subsistence hunting for centuries before the NWRS was established. She pointed out that a previous rule that removed predator management from Alaskans and centralized that with Washington, D.C., bureaucrats was overturned. She noted that while the BIDEH proposals are national in scope, they would have the same effect.
“This rule has the same result in Alaska, which would be predator control, would fall to refuge managers rather than the state and the people who live closest to the resources and have always lived there,” Rep. Peltola explained. She later added, “However, this rule doesn’t align with the Congressional mandates and supersedes Alaska’s expressed management authority by prohibiting state authorized predator control in the refuge system.”
Rep. Peltola drove home the point that Alaskans are part of the environment and rely on wild game and predator control for food sources, which appear to have been disregarded in the proposed BIDEH updates.
Rep. Harriet Hageman (R-Wyo.) brought up the issue of agricultural production on NWRs, particularly for migrating ducks. Supplemental rice production is vital to ensure waterfowl have the food sources to provide energy for migration routes.
David Wielicki, CEO of the South Carolina Waterfowl Association, expressed his concern that the proposed BIDEH updates would eliminate that food source for waterfowl. He explained that it takes just one acre of flooded rice fields to provide the same food energy that it would take on 20 acres of moist soil vegetation. Biologists refer to this as “duck energy days,” or the amount of food that’s needed to provide one duck the energy needed to exist for one day.
“Refuges need to do more,” Wielicki said. “There was a study completed by the Fish and Wildlife Service in the southeast region looking at waterfowl population and energy objectives on national wildlife refuges. Currently provide 475 million duck energy days, of which 223 million, or 47 percent, are provided with agriculture. And they want to provide another 140 million duck energy days. So, in order to accomplish that, agriculture would be the most efficient technique to complete that.”
Rep. Garret Graves (R-La.) questioned why USFWS didn’t partner with conservation groups to craft the proposed BIDEH updates, since they represent the stakeholders that would be most affected by these proposed policy changes, yet the Humane Society of the United States (HSUS), an anti-hunting organization, issued a press release praising the policy changes the day it was posted.
“I’d love to make sure we probe that a little bit more,” Rep. Graves said.
Policies crafted to satisfy Washington, D.C., special interests do more than disenfranchise sportsmen and women. They would dismantle the wildlife conservation model that has proven effective for nearly a century that when those who invest in wildlife conservation are integrated in solutions, wildlife flourishes for all. These proposed BIDEH updates put successful wildlife conservation at risk for a “woke” climate agenda. That’s not just bad policy. That’s putting politics ahead of science.
About The National Shooting Sports Foundation
NSSF is the trade association for the firearm industry. Its mission is to promote, protect and preserve hunting and shooting sports. Formed in 1961, NSSF has a membership of thousands of manufacturers, distributors, firearm retailers, shooting ranges, sportsmen’s organizations, and publishers nationwide. For more information, visit nssf.org
