The VT State Team of BHA recently submitted comments to Senator Leahy, with copies to other state and federal decision makers, in support of a federal appropriation to add to United States Fish and Wildlife Service land in Vermont. Viewed from afar, this seems like an obvious win for conservation, hunting, and angling, as both the Missisquoi and Silvio O Conte National Wildlife Refuges (NWR) allow these activities in addition to conserving valuable habitat for an array of wildlife in their regions.

However, one challenge in supporting this opportunity was the manner in which the new Recreational Hunting and Fishing plan for these refuges was updated in 2021.

(Read more about the unique approach to land conservation that brought about the Nulhegan section of the Conte NWR in the Northern Forest Region here)

The 2021 Hunt Plan created concern because while it ostensibly is set up to align rules on the Conte NWR with applicable NH and VT Fish and Wildlife regulations, several new hunting regulations that diverge from State regulations were enacted.  While public input was accepted, the regulations that were ultimately incorporated into the final Hunt and Fish Plan were not part of the drafts and were never made available for comment, so hunters were blindsided by the changes that seemed to come out of nowhere. The result was that hunters, anglers and trappers never had any opportunity to see or understand the issues in question, or to provide input on solutions.

Advocates of science-based wildlife management and the North American Model of wildlife conservation, as well as those hunters who use hunting dogs of any kind and who are directly affected by the new regulations, are justifiably angry and concerned.   In our view, the lack of transparency in the process opens the door for management decisions to be politically influenced, rather than based in the best available science. This type of decision-making, regardless of the validity of these decisions, erodes trust between Federal land managers, State officials, and the hunters and anglers who are among the owners and stewards of these public lands.  We believe this is a critical issue that should be addressed now and in the future.

BHA is committed to public lands for the innumerable benefits provided to people and wildlife. Federal public lands are essential in the mosaic of state, and other conserved lands to provide equitable access for all users, and should be expanded with there is an opportunity. When our great grandchildren see a bay-breasted warbler, tree a bear, hook a brook trout, flush a woodcock, or track a buck across their public land, they’ll thank us.   BHA in Vermont is also committed to working with the US Fish and Wildlife service to ensure there is better transparency and accountability in the process of making regulatory changes.  

Below is the text of our letter to Senator Leahy, Governor Scott, Congressman Welch and members of the USFWS.

Dear Senator Leahy,

We are writing on behalf of the Vermont members of Backcountry Hunters & Anglers (BHA) to express our strong support for adding land to the public trust in VT and to support funding to add land to the Silvio O. Conte NWR.

Securing more public land directly and indirectly benefits the overall wildlife populations and habitat enjoyed by all Vermonters, land that is important to our well-being and the economy. BHA members are a diverse group of hunters, anglers and trappers who support policies that promote backcountry experiences, healthy fish and wildlife habitat, and sound stewardship of public lands and waters. With more than 70% of our members under the age of 45, we represent the rising generation of hunters and anglers. When we focus specifically on our membership, the benefits of adding public land for hunters and anglers are huge. Hunters report that one of the major issues that limits hunting is loss of access. This same study indicates that crowding influences where a hunter chooses to go². New England is losing 65 acres of forest to development each day. Since 2010, annual acreage of conservation is down, falling more than six-fold since the early 2000s, from 333,000 to about 50,000 acres per year¹. With research indicating there is still work to do in terms of protecting corridors for habitat health and connectivity, climate resiliency, watershed health and other goals, this has far-reaching implications within the Green Mountain State.

We support this potential expansion in spite of our concern about the lack of transparency in the process of recent management decisions on NWR’s in Vermont, specifically the 2021 Recreational Hunting and Fishing Plan.

Even though hunting is one of the six priority public uses of National Wildlife Refuges, as well as legislatively mandated (as per the Refuge System Administration Act of 1966-1997 amendment and Secretarial Order 3356 of 2017), the final 2021 Recreational Hunting and Fishing Plan for the Silvio O. Conte NWR included several new hunting restrictions, mainly focused on the use of hunting dogs, without sufficient public process. The new restrictions are generally inconsistent with statewide regulations in New Hampshire and Vermont, and most were not raised by the USFWS in the draft plans available for public comment as potential regulations or even as issues needing to be addressed. This means the public was unable to consider or provide any input whatsoever on these changes. Regardless of the potential need for new restrictions, or their substance, it is the lack of transparency and inability to fully participate in this regulatory process that sets a precedent that BHA considers a grave concern, one that risks the widespread support of Vermont hunters, anglers and trappers for public land in general. Still, our overall support is rooted in a belief that with strong public oversight, federally managed public land, alongside both state-managed and privately-held conserved lands, provide essential habitat needed for thriving wildlife populations and are an important part of a landscape that offers continued access and opportunity for hunting, angling, trapping and other outdoor pursuits for all Vermonters for generations to come.

Our profound hope is that future changes to USFWS management plans affecting hunters, anglers and trappers undergo a more transparent process where all relevant stakeholder groups have ample opportunity to review the data, assess the impact of any potential changes, and then be able to provide meaningful feedback that will be taken into account during the rulemaking process. Doing otherwise will erode support for public land in general. Losing the support of this stakeholder group will not benefit wildlife and the habitat they depend on, nor the land that Vermonters value. Hunters and anglers are a positive source of support for our wildlife and wild places and are generally supportive of necessary regulations backed by sound science and presented in a transparent manner. If the USFWS is unwilling or unable to consider altering the process around regulatory changes, we suggest future land acquisitions and money for such acquisitions be routed through other potential land managers.

This opportunity to improve access and habitat conservation by expanding public land holdings will benefit current and future generations of Vermonters. If the health of our lands and waters, as well as the rural and cultural way of life we value in Vermont, are going to persist in the face of climate challenges, demographic shifts, and development, then protecting these places for all Vermonters must be a priority. We also believe the conservation benefit brought by hunting, angling, and trapping on National Wildlife Refuges, as well as other public and publicly-accessible lands, are vitally important and will continue to be so in the future. We hope you will support not only adding to our publicly accessible lands, but also our effort to ensure the USFWS enacts future regulations through a more transparent and inclusive process recognizing the vital support of this important stakeholder group and guided by the best available science.

Respectfully submitted on behalf of the VT BHA State Leadership Team and our members,

¹ Foster, D. (2017). Wildlands and Woodlands, Farmlands and Communities: Broadening the Vision for New England. Petersham, MA: Harvard University Forest

² Responsive Management and NSSF (2010) ISSUES RELATED TO HUNTING ACCESS IN THE UNITED STATES, Conducted Under a Grant from the U.S. Fish and Wildlife Service and Administered by the Association of Fish and Wildlife Agencies Multi-State Conservation Grant CT M-8-R