Assabet River NWR Final CCP - U.S. Fish and Wildlife Service
Assabet River NWR Final CCP - U.S. Fish and Wildlife Service Assabet River NWR Final CCP - U.S. Fish and Wildlife Service
- 158 - Appendix C: Responses to Substantive Comments actions have on the surrounding landscape. The patchwork of lands that create these refuges creates unique challenges and partnerships. The Service mission and refuge purposes must be our first priority. We understand that this priority does not always mesh with adjacent landowners’ wishes and concerns. We are a part of the larger Refuge System and must consider not only our role in the surrounding ecosystem, but our role in the Refuge System, as well. Priority Public Uses Hunting – General Hunting was the issue most frequently addressed in comments on the draft CCP. General hunting comments include advocates for hunting on public lands and individuals that are opposed to hunting in any form. The National Wildlife Refuge System Improvement Act of 1997 (Refuge Improvement Act) lists hunting as one of six priority, wildlife-dependent public uses to receive enhanced and preferential consideration in refuge planning and management. In addition to hunting, other priority uses include fishing, wildlife observation and photography, environmental education and interpretation. Our mandate is to provide high-quality opportunities for these priority uses where they are compatible with respective refuge purposes, goals, and other management priorities. Regardless of individual opinions about the appropriateness of hunting on the refuges, the Refuge Improvement Act requires that we give preferential consideration to the six priority, wildlife-dependent uses. We are also concerned about the potential for hunting to impact other priority uses. There appears to have been some confusion about where we are proposing to allow hunting. We have outlined the areas where hunting is to be allowed on the maps that are included as a part of the CCP. We have included some of the additional details in regard to hunting in the Final CCPs. In order to open the refuges to additional hunting opportunities, Federal regulations will need to be changed. There will be an additional public comment period when proposed hunting regulations are released in the Federal Register. This will likely occur during the winter/spring of 2005. Additionally, we will be developing a Hunt Management Plan for each Refuge that will outline all of the details for each specific hunting program. Each plan will be completed in cooperation with the Massachusetts Department of Fish and Game (MA DFG), Division of Fisheries and Wildlife. Refuge areas that meet certain criteria have been evaluated to determine tracts of land that have the ability to support a high quality public hunt. We have determined that certain areas are appropriate for certain types of hunting and not others. The criteria used included: 1) an area of sufficient size to insure public safety; 2) an area more than 500 feet from occupied dwellings (Massachusetts state law); and 3) an area that provides reasonable opportunities for a successful hunt. An additional consideration that was considered in some instances is Assabet River NWR
Appendix C: Responses to Substantive Comments whether hunting of an area of the refuge is consistent with or complements other hunted areas in surrounding towns. Hunting – Safety and Conflicts with Other Users There were a large number of individuals that expressed concerns about safety and hunting. Some individuals expressed concerns about safety while using the refuge during hunting season and the assertion that the non-hunting public will not participate in other wildlife dependent activities during the hunting seasons. Other people indicated their concerns about the proximity to the refuge boundary of homes, schools, and conservation areas. Additionally, individuals raised the possibility of hunters accessing non-refuge lands or misguided arrows, shotgun slugs, or pellets injuring someone not on the refuge. There will be areas on the refuges where no hunting will be allowed. In some cases, these are highly used areas, such as the Concord Impoundments at Great Meadows NWR. In others, we have restricted hunting because of the mandated safety zones. We realize that there may be people that will not visit the refuges during specific seasons. As mentioned previously, we have a responsibility to facilitate all forms of wildlife-dependent public use on the refuges, when possible, and there may be days when people engaged in hunting will have preferential access to parts of the refuges. National policy encourages refuges to follow state hunting regulations, but we do have the authority to set our own dates and times if needed and we can limit the number of hunting permits issued. We will evaluate these options in the development of the Hunt Management Plan for each refuge, but do not anticipate a need to include such restrictions at this time. We strive to achieve a balance between consumptive and non-consumptive uses on the refuges. Because Massachusetts does not allow hunting on Sunday, at a minimum nonhunters will be free to enjoy our nature trails with no concern about possible hunting conflicts on those days during the hunting seasons. In addition, experience managing hunts both at Oxbow Refuge and at other refuges within the system shows that many areas can safely support both hunting and non-consumptive uses, such as wildlife observation, at the same time. We are confident that we can develop a hunting program that will safely provide opportunities for wildlife-dependent public use to a majority of our refuge visitors. We contacted the Massachusetts Division of Fisheries and Wildlife to obtain hunting accident statistics. We considered investigating such statistics in other states, but decided that Massachusetts has a higher population density than the majority of other states with readily available accident statistics such as Pennsylvania, North Carolina, and Texas. According to Massachusetts Law, any person involved in a hunting accident or any person with knowledge of a hunting accident must file a report with the state or local police, who, in turn, must file a report with the Division of Law Enforcement. The Massachusetts Environmental Police, Hunter Education Program reports hunting accidents in the Hunting Accident Report: 1995 – 2002. During the reporting period, there were 38 hunting accidents. None of the accidents were fatal and none involved any individuals who were not hunting at the time of the accident. According to the 2001 National Survey of Fishing, Hunting, and Wildlife-Associated Recreation, there were 1.58 million days of Comprehencive Conservation Plan - 159 -
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Appendix C: Responses to Substantive Comments<br />
actions have on the surrounding l<strong>and</strong>scape. The patchwork of l<strong>and</strong>s that create these<br />
refuges creates unique challenges <strong>and</strong> partnerships. The <strong>Service</strong> mission <strong>and</strong> refuge<br />
purposes must be our first priority. We underst<strong>and</strong> that this priority does not always<br />
mesh with adjacent l<strong>and</strong>owners’ wishes <strong>and</strong> concerns. We are a part of the larger Refuge<br />
System <strong>and</strong> must consider not only our role in the surrounding ecosystem, but our role in<br />
the Refuge System, as well.<br />
Priority Public Uses<br />
Hunting – General<br />
Hunting was the issue most frequently addressed in comments on the draft <strong>CCP</strong>. General<br />
hunting comments include advocates for hunting on public l<strong>and</strong>s <strong>and</strong> individuals that<br />
are opposed to hunting in any form.<br />
The National <strong>Wildlife</strong> Refuge System Improvement Act of 1997 (Refuge Improvement<br />
Act) lists hunting as one of six priority, wildlife-dependent public uses to receive enhanced<br />
<strong>and</strong> preferential consideration in refuge planning <strong>and</strong> management. In addition to hunting,<br />
other priority uses include fishing, wildlife observation <strong>and</strong> photography, environmental<br />
education <strong>and</strong> interpretation. Our m<strong>and</strong>ate is to provide high-quality opportunities for<br />
these priority uses where they are compatible with respective refuge purposes, goals, <strong>and</strong><br />
other management priorities.<br />
Regardless of individual opinions about the appropriateness of hunting on the refuges, the<br />
Refuge Improvement Act requires that we give preferential consideration to the six<br />
priority, wildlife-dependent uses. We are also concerned about the potential for hunting to<br />
impact other priority uses. There appears to have been some confusion about where we<br />
are proposing to allow hunting. We have outlined the areas where hunting is to be allowed<br />
on the maps that are included as a part of the <strong>CCP</strong>.<br />
We have included some of the additional details in regard to hunting in the <strong>Final</strong> <strong>CCP</strong>s. In<br />
order to open the refuges to additional hunting opportunities, Federal regulations will<br />
need to be changed. There will be an additional public comment period when proposed<br />
hunting regulations are released in the Federal Register. This will likely occur during the<br />
winter/spring of 2005.<br />
Additionally, we will be developing a Hunt Management Plan for each Refuge that will<br />
outline all of the details for each specific hunting program.<br />
Each plan will be completed in cooperation with the Massachusetts Department of <strong>Fish</strong><br />
<strong>and</strong> Game (MA DFG), Division of <strong>Fish</strong>eries <strong>and</strong> <strong>Wildlife</strong>. Refuge areas that meet certain<br />
criteria have been evaluated to determine tracts of l<strong>and</strong> that have the ability to support a<br />
high quality public hunt. We have determined that certain areas are appropriate for<br />
certain types of hunting <strong>and</strong> not others. The criteria used included: 1) an area of sufficient<br />
size to insure public safety; 2) an area more than 500 feet from occupied dwellings<br />
(Massachusetts state law); <strong>and</strong> 3) an area that provides reasonable opportunities for a<br />
successful hunt. An additional consideration that was considered in some instances is<br />
<strong>Assabet</strong> <strong>River</strong> <strong>NWR</strong>