DU supports the conversion of the four management units to salt marsh, as well as the use of active management by refuge staff to mimic natural processes. DU feels this approach will ultimately prove to be the most sustainable. Additionally, the reversion will help compensate for the historic losses of salt marsh within the mid‐Atlantic region. We recognize and understand the role freshwater impoundments at the refuge have played in recent decades in regards to waterfowl habitat. It is important to note that allowing the units to revert to salt marsh will not decrease habitat value, but instead, will likely alter the species composition that uses them. Specifically, salt marshes serve as critically important habitat for the American black duck, a species of conservation concern.
DU asserts, however, that allowing the impoundments to revert to salt marsh will require the Service to place higher emphasis on the management of the remaining freshwater areas on and adjacent to Prime Hook. The reversion will make these adjacent areas inherently more important for migrating waterfowl. We urge the Service to continue and possibly expand the use of fee title acquisition and conservation easements from willing sellers to protect existing wetland, upland and riparian habitat on adjoining private lands.
DU supports waterfowl hunting, when conducted in an ethical and sustainable manner, as a legitimate and acceptable use of a renewable resource and a compatible use of national wildlife refuges. Federal public lands are an important destination for American hunters. According to the 2006 National Survey of Fishing, Hunting, and Wildlife‐Associated Recreation, nearly 40 percent of all hunters conduct a portion of their hunting activity on public lands. As such, we support expansion of available hunting opportunities at Prime Hook as associated with Alternative B.
DU does not support the elimination of cooperative farming as described in Alternative B. In fact, we support the continued use of this practice as outlined in Alternative C. As described in the CCP, it is well known that certain populations of dabbling ducks and geese have come to depend on agricultural areas for foraging in response to declines in the amount and quality of aquatic habitats within this region. We acknowledge that the area under production at Prime Hook is minimal in comparison to the overall agricultural land in southern Delaware, but maintain that it is important for this activity to continue on public access lands. A cooperative farming program could potentially serve as a source of revenues for the refuge that could be used to offset the cost of recurring management strategies such as invasive species control. Additionally, this program would assist the Service in maintaining healthy relationships with local landowners and producers while providing further hunting, wildlife photography and viewing opportunities. At minimum, DU urges the Service to consider integrating a cooperative farming program with the upland regeneration strategies described in Alternative B.
Ducks Unlimited recognizes that waterfowl require a variety of habitat types during their life cycle. Again, we commend the Service for undertaking this strategic planning process to ensure all of these habitat types are in sufficient quantity, quality and location to support healthy and sustainable waterfowl populations and compatible public use.
These comments were submitted to the U.S. Fish and Wildlife Service on Aug. 20, 2012.
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Contact Information:
Jacob McPherson
jmcpherson@ducks.org
410-224-6620