May 30, 2023

Righting Several Wrongs – CSF Submits Letter to FWS Relative to Silvio O. Conte Hunting/Fishing Plan

Article Contact: Fred Bird,

Why It Matters: In July 2021, the Congressional Sportsmen’s Foundation (CSF) submitted a letter of support with recommendations to the U. S. Fish and Wildlife Service (FWS) relative to the originally proposed Silvio O. Conte National Fish and Wildlife Refuge (Refuge) Recreational Hunting and Fishing Plan. To the hunting conservation community’s surprise, the final plan that resulted following the public comment period included numerous new restrictions against, among other things, hunting with dogs. CSF subsequently sent the FWS a letter of opposition in early 2022 and following the reopening of the public comment period, as a result from a partner organizations’ lawsuit against FWS, CSF submitted a letter of support for reopening the hunting access that was lost through the final Plan.

Highlights:

  • On Thursday, May 25, CSF’s New England States Assistant Manager, Fred Bird, submitted a letter to the FWS in support of Alternative B with certain additional recommendations for the Silvio O. Conte National Fish and Wildlife Refuge Recreational Hunting and Fishing Plan.
    • When reopening the public comment period for this Plan, the FWS offered two possible routes it could take: Alternative A, which would leave the plan as-is; and, Alternative B, which would reopen several opportunities for sportsmen and women that were lost through the Refuge’s final Plan.
  • CSF provided the FWS with support and additional recommendations for the originally proposed Recreational Hunting and Fishing Plan, but the final Plan that was revealed by the FWS had three surprising new restrictions and one that CSF had initially called to reject.
  • CSF corresponded its disappointment with the FWS, highlighting flawed processes under the Administrative Procedures Act, as there were significant changes to the original Plan in the final Plan with no opportunity for further public comment.
  • A lawsuit stemming from hunting conservation partners resulted in the FWS’ reopening of the public comment period, which allowed CSF’s further engagement.

On Thursday, May 25, CSF’s New England States Assistant Manager, Fred Bird, again submitted comments to the FWS regarding the Silvio O. Conte National Fish and Wildlife Refuge Recreational Hunting and Fishing Plan. The FWS offered two possible routes that could be taken with this approach: Alternative A, or the “No Action Alternative, which “would continue the refuge’s hunting and fishing program as identified in the final 2021 Hunt Plan;” and, Alternative B, which would “expand the dog training season to follow the Vermont State dog training season” and align the use of dogs “with State regulations for hunting and training on the Putney Mountain Unit.” Alternative B would afford sportsmen and women the opportunities that they once enjoyed prior to the implementation of the restrictive 2021 final plan. CSF also offered two additional recommendations: the removal of the Special Use Permit requirement when hunting over more than two dogs and the reauthorization of night hunting across the Refuge.

As CSF previously reported, several of the anti-hunting provisions that were incorporated into the final plan were never raised by the FWS as options it was considering in the draft plan that was open for public comment during the summer of 2021. Therefore, the sporting community was unable to provide input against these restrictions. These included: hunters using more than two dogs must possess a Special Use Permit issued by the refuge manager; restricting the use of dogs to the of hunting ruffed grouse at the Putney Mountain Unity; and limiting the training of dogs to August 1 through the last Saturday in September during daylight hours, and only if the trainer possesses a Special Use Permit issued by the refuge manager.

CSF’s letter is the most recent update on its years-long engagement with the FWS relative to the Silvio O. Conte National Fish and Wildlife Refuge Recreational Hunting and Fishing Plan. Additional updates will be provided as they are made available.

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