Introduction

Prime Hook National Wildlife Refuge (Prime Hook) in Sussex County, Delaware, was established in 1963 under the authority of the Migratory Bird Conservation Act with the explicit purpose of providing habitat for migratory birds. It supports approximately 300 avian species and is a key stopover and wintering area for shorebirds, wading birds and waterfowl in the Atlantic Flyway. It also provides six major wildlife-oriented recreational opportunities, including hunting, fishing, wildlife observation, photography, environmental education and environmental interpretation.

Prime Hook is home to nearly 2,300 acres of tidal salt marsh, a rapidly diminishing habitat type, and boasts some of the largest freshwater impoundments along the East Coast. These impoundments were created in 1988, total 4,200 acres and are managed to provide a diversity of freshwater plants not commonly found in such close proximity to the Atlantic Ocean.

Due to the importance of these habitats, Ducks Unlimited has made a significant investment in conserving wetlands and associated habitat at Prime Hook and within the Delaware Bay watershed. Additionally, Prime Hook lies within the boundaries of our Completing the Cycle Initiative, a landscape‐level program that addresses the life-cycle needs of waterfowl in the northeastern Atlantic Flyway by combining science, policy and on‐the‐ground habitat conservation.

Ducks Unlimited comments on the May 2012 Draft Comprehensive Conservation Plan

The U.S. Fish and Wildlife Service (Service) acknowledges in the draft Comprehensive Conservation Plan (CCP) that wetlands at Prime Hook have been subject to extensive human alterations dating back to before the refuge's existence. Prime Hook was established in 1963 expressly to serve as "an inviolate sanctuary, or for any other management purpose, for migratory birds." Some of the aforementioned alterations were implemented by the Service and its partners (including Ducks Unlimited) as a means of achieving this goal.

Specifically, in the late 1980s, DU was contracted by the Service to help survey, design and construct the freshwater impoundments that are in place at Prime Hook. The best science available at that time was used to guide this management decision, and for more than 20 years these impoundments benefitted Atlantic waterfowl populations immensely. However, the decision to create freshwater impoundments was made at a time when factors such as global climate change and sea‐level rise were poorly understood and scarcely considered a threat to the sustainability of the impoundments. A recent evaluation of the potential threats posed by these factors indicates that action is warranted to minimize the possibility of future dilemmas like the one at hand. DU commends the Service for undertaking this strategic planning process to help guide future management decisions. We appreciate the opportunity to provide comments on the CCP, and we encourage the Service to continue to consider input from all refuge stakeholders.

DU reviewed the CCP with a particular focus on actions that would affect the quantity and quality of waterfowl habitat at Prime Hook. Due to the recent infrastructure damage experienced at the refuge and the related impacts on future habitat management capabilities, DU placed increased emphasis on the long‐term financial and ecological sustainability of each alternative. In general, DU supports the Service's preferred Alternative B, but hopes that certain aspects of Alternative C will be considered for inclusion in the final CCP if they are determined to be compatible with the Service's goals.