Explore The NRA Universe Of Websites

APPEARS IN Hunting

NRA Comments For The Cape Cod National Seashore Hunting Program

Friday, June 16, 2006

Printer Friendly version (PDF format)

June 16, 2006

George E. Price, Jr.
Superintendent
Cape Cod National Seashore
99 Marconi Site Road
Wellfleet, MA 02667

Dear Superintendent Price:

The National Rifle Association appreciates the opportunity to comment on the Draft Environmental Impact Statement (DEIS) for the Cape Cod National Seashore (CACO) Hunting Program. After thoroughly reviewing the three alternatives proposed, the NRA supports a modification of Alternative A, the No Action Alternative.

The NRA is completely opposed to Alternative C that would phase out all hunting within CACO. If implemented, this Alternative would violate the statute creating CACO that is explained in 1.2.2. History and Significance of CACO as "seeking to perpetuate many of the traditional values, pastimes, and ways of life that have helped shape the special ambiance of the Cape. One of the customary activities at CACO, the hunting of upland game and waterfowl, is the focus of this DEIS." As noted in the Introduction section of the DEIS, hunting is "considered a part of the cultural heritage and fabric of life on Outer Cape Cod." Put-and-take pheasant stocking has occurred in certain areas of CACO since the 1940's, well predating the creation of CACO in 1961.

Alternative C also contradicts the National Park Service's (NPS) policy on introduction of exotic species. As explained in the Draft EIS, preference is given to enhancing native species; however, "where stocking of exotic fish and same species has historically occurred, stocking for the same species may be continued unless it is known to be damaging native resources."  The stocking and hunting of ring-neck pheasant and the hunting programs for deer, rabbit, waterfowl, and other game species have been demonstrated to have no adverse effects on natural or cultural resources.

This leads then to concerns over NPS' Preferred Alternative, Alternative B, that is described as improving the hunting program. The NRA supports elements of this Alternative. We support Element 3A that would establish a new hunting season for eastern wild turkeys in accordance with the Massachusetts Division of Fisheries and Wildlife (MDFW) regulations. We support Element 3B that would include habitat improvement for upland game birds, focusing on the northern bobwhite quail, in the development and implementation of landscape restoration activities as outlined in CACO's general management plan. However, we support an "active" habitat restoration program, not a "passive" restoration program that the DEIS addresses. And, we support Element 3C that would integrate MDFW's annual wildlife monitoring results into CACO's management decisions to ensure sound wildlife management with a focus on deer, rabbits, turkey and quail.

The NRA also supports Element 4 to improve hunter and non-hunter information with major caveat. One of the objectives listed is to "inform hunters of the need to be courteous and respectful towards other users, and to follow the maps and regulations." The National Park Service should, at the same time, inform other users of CACO to be courteous and respectful of hunters. All fifty states have recognized the problem with hunter harassment through enactment of statutes to punish those whose intent is to disrupt or halt a lawful recreational activity. It would also be helpful to the non-hunter to know that hunting in CACO has an exemplary safety record. Other recreational uses should also be informed about the Seashore's maps and regulations to ensure compliance with policies and laws.

The NRA strongly opposes Element 1 because it would phase out the pheasant stocking and hunting program. By quoting policy and statute, the DEIS has made a solid case for supporting the continuation of the pheasant stocking and hunting program since the program meets the threshold of cultural heritage and no adverse environmental effects. While it is laudable that the NPS desires to attain a "no net loss of hunting opportunity" by replacing the pheasant hunt with upland bird hunting, Alternative B sets a phase out period for pheasant stocking and hunting with no documentation to show that the quality of hunting experienced over these many years will not suffer in the future, measured by the number of birds available to the hunter and the hunter's enjoyment of pheasant hunting vs quail hunting.

The DEIS provides no scientific data to suggest that CACO will be successful in restoring bobwhite quail and at the level of birds needed to fully replace the annual pheasant hunt. Furthermore, Alternative B calls for terminating the pheasant stocking and hunting program in 15 years, "independent of the upland game restoration activities" (emphasis added). This deadline makes a farce of the "adaptive strategy" that would be applied to phase out the pheasant hunting program as numbers of native game birds increased and of the statement that it is CACO's intent to "minimize any loss of hunting opportunity by creating an alternative to the pheasant hunt through the restoration of native upland species."

To offset the possibility (or likelihood) that the population of quail will be unable to rise to the level of the stocked numbers for pheasant hunting, the NPS proposes to work with MDFW to create opportunities for a stocked quail hunt. However, the DEIS does not reference any authority for the NPS to substitute pheasant stocking for quail stocking. To the contrary the DEIS suggests that the NPS does not have the authority. Under Section 1.2.7. CACO's Mission Statement, Management Philosophy, Objectives and Goals it states:

In some situations, the NPS may stock native or exotic animals for recreational purposes, but only when such stocking will not impair Park natural resources or processes and: such stocking is in an NRA or preserve that has historically been stocked (In these situations, stocking only of the same species may be continued); or Congressional intent for stocking is expressed in statute or a House or Senate report accompanying a statute.

It would seem that the NPS could open itself up to a lawsuit by anti-hunters against the stocked quail hunt. The outcome could be termination of the stocking/hunting program without any recourse since Alternative B would terminate the pheasant stocking and hunting program independent of the upland game restoration activities.

Element 2 ostensibly would assist the hunter and other recreational users by simplifying and clearly delineating areas opened to hunting. However NRA is opposed to increasing the buffer zone adjacent to bike paths from 150 feet to 500 feet. The DEIS clearly states in Section 1.2.3 CACO Hunting Program that "There has never been a serious hunting accident recorded at CACO (emphasis added)." The DEIS also notes that "there have never been any documented "close calls" involving hunters and non-hunters (emphasis added). The NPS has not made a case for the need to expand the buffer zone around bike paths. The DEIS was developed in response to a court ruling that enjoined the pheasant stocking and hunting program until an environmental assessment was completed by the NPS. User conflicts or potential safety issues were not the reasons for nor the subjects of the court's action and should not have been part of an "environmental review" under the National Environmental Policy Act.

In summary, there are too many negative elements in Alternative B for the NRA and its hunter-members to support. Therefore, the only remaining alternative that is supportable is Alternative A. However, the NRA would like to see Alternative A modified to include the following elements of Alternative B: Element 3A to establish a turkey hunting program; a modification of Element 3B to proactively restore upland game bird habitat; Element 3C to work with the MDFW in implementing sound wildlife management practices with a focus on game species; and a modification of Element 4 to improve hunter and non-hunter information as addressed above.

Thank you, again, for the opportunity to comment on the DEIS.

Sincerely,

Susan Recce
Director
Conservation, Wildlife and Natural Resources
National Rifle Association

TRENDING NOW
Bloomberg Dismisses Texas Hero, Insists It Wasn’t His “Job” to Have a Gun or Decide to Shoot

News  

Monday, January 6, 2020

Bloomberg Dismisses Texas Hero, Insists It Wasn’t His “Job” to Have a Gun or Decide to Shoot

Jack Wilson – a 71-year-old congregant of the West Freeway Church of Christ in White Settlement, Tex. – is a hero to most Americans. When a deranged man savagely murdered two of Mr. Wilson’s fellow ...

New Hampshire: Bill to Shut Down Shooting Ranges Set for Committee Hearing

Thursday, January 16, 2020

New Hampshire: Bill to Shut Down Shooting Ranges Set for Committee Hearing

On January 23rd, the New Hampshire Senate Judiciary Committee will hold a public hearing on Senate Bill 469, sponsored by Senator Jeanne Dietsch (D – District 9), at 10:00 AM in Room 100 of the State ...

Sorry Shannon, But Those “Random Civilians” Are What Are Known As NRA Members

News  

Sunday, January 19, 2020

Sorry Shannon, But Those “Random Civilians” Are What Are Known As NRA Members

We were well aware that after New York billionaire Michael Bloomberg spent a cool $2.5 million on his latest acquisition, majority control of the Virginia General Assembly, law-abiding gun owners in The Old Dominion would see an onslaught of legislation ...

Wednesday, January 15, 2020

Alert! Florida REPUBLICAN Senators Vote for Massive Gun Control Bill

On Monday, 1/13/20, it happened again.  Senate President Bill Galvano picked a fight with Floridians who believe in the constitutional Right to Keep and Bear Arms. It is well known -- even by the media ...

Virginia: Senate Passes Three Anti-Gun Bills

Thursday, January 16, 2020

Virginia: Senate Passes Three Anti-Gun Bills

On Thursday, January 16th, the Virginia Senate voted to pass three of the anti-gun bills that the Senate Judiciary Committee approved on Monday. The fight is far from over! Dozens of other gun control bills ...

Washington: Upcoming Hearings On Gun Bills This Week

Sunday, January 19, 2020

Washington: Upcoming Hearings On Gun Bills This Week

As previously announced, the Washington State Legislature will be hosting committee hearings next week on over a dozen Second Amendment related bills. Please see below for the latest information on the committee hearing agendas, including ...

State of Ignorance: California Pushes False Information to School Kids on the Second Amendment

News  

Sunday, January 19, 2020

State of Ignorance: California Pushes False Information to School Kids on the Second Amendment

As an incorporated provision of the United States Bill of Rights, the Second Amendment is the supreme law of the land, applying to all U.S. jurisdictions and to the actions of federal, state, and local ...

Virginia Senate Passes Three Gun Control Bills - Committee Advances a Fourth

News  

Sunday, January 19, 2020

Virginia Senate Passes Three Gun Control Bills - Committee Advances a Fourth

Last week, the Virginia Senate Judiciary Committee sent four gun control bills to the full chamber. The measures included an attack on the state firearms preemption statute and Right-to-Carry permit holders (SB35), a one-handgun-a-month bill ...

Missouri: Gun Bills Filed for 2020 Session

Friday, January 10, 2020

Missouri: Gun Bills Filed for 2020 Session

With the 2020 Missouri legislative session starting, legislators have filed pro-gun and anti-gun legislation. See below for information on some of the bills that have been introduced to date. Your NRA-ILA will keep you informed of ...

Virginia Gov. Northam Wants Millions in Tax Money to Ban Guns and Jail Gun Owners!

News  

Monday, January 6, 2020

Virginia Gov. Northam Wants Millions in Tax Money to Ban Guns and Jail Gun Owners!

In recent weeks NRA-ILA informed Virginia gun owners about gun control funding included in the state budget bill. The budget legislation, HB30, included a $250,000 appropriation to the Corrections Special Reserve Fund in order to provide for the ...

MORE TRENDING +
LESS TRENDING -

More Like This From Around The NRA

NRA ILA

Established in 1975, the Institute for Legislative Action (ILA) is the "lobbying" arm of the National Rifle Association of America. ILA is responsible for preserving the right of all law-abiding individuals in the legislative, political, and legal arenas, to purchase, possess and use firearms for legitimate purposes as guaranteed by the Second Amendment to the U.S. Constitution.