C.A.S.H. Writes Formal Comments on Federal and State Management Plans

February 22, 2008

Ms. Beth Goldstein, Planning Team Leader

U.S. Fish & Wildlife Service

300 Westgate Center Drive

Hadley, MA  01035


Dear Ms. Goldstein:

The Committee to Abolish Sport Hunting is a wildlife advocacy organization that encourages the public to engage in forms of outdoor recreation that do not involve the violence of hunting.  On behalf of our members and supporters in the states of New Jersey and New York, we wish to comment on the U.S. Fish & Wildlife Service’s “Wallkill River National Wildlife Refuge Draft Comprehensive Conservation Plan and Environmental Assessment.”

USFWS is considering three alternatives to the management of the Refuge, with one being a “no action” alternative, meaning that current management policies will remain in effect when the Conservation Plan is finalized.  Common to each proposed plan are the conditions that Canada geese and white-tail deer populations will be hunted, beavers and muskrats will be trapped by recreational trappers, permits will be obtained to kill Canada geese populations and eradicate mute swans on the refuge.  Under Alternative A there would be continued hunting of turkeys, migratory birds, and woodcock.  The state’s youth hunting programs would continue to be honored.  Alternative B would include the pro-hunting language of Alternative A and would also open Service-owned land to a black bear hunt (according to state seasons and regulations), open land in the proposed expansion area to public hunting, and expand accessible hunting opportunities at Owens Station.  Alternative C would allow the continued hunting of deer and geese but would not include the bear hunting provisions set forth in Alternative B, nor would it continue the youth hunting program.

While the Committee to Abolish Sport Hunting cannot endorse any plan that includes hunting as part of its wildlife management agenda, there are many provisions of each of the proposed alternatives that we are able to support and that we wish would be included in any final decision that is made by USFWS regarding the management of the Wallkill River National Wildlife Refuge.  Among the proposals we support are the following:


  • Honoring wildlife observation and photography as “priority public uses” under the Refuge Improvement Act.
  • Prohibiting hunting “where the refuge identifies it as a threat to public safety or when it poses an unacceptable disturbance to wildlife.”
  • Acquiring additional acreage to be added to the Refuge and used for the non-violent, non-consumptive public enjoyment of wildlife and habitat.
  • Constructing of additional photography blinds on the Liberty Loop Trail and elsewhere throughout the refuge, to improve and increase the amount of wildlife observation and photography opportunities.
  • Protecting bog turtles from poaching activities by conducting routine and random site visits.
  • Continuing work to restore and enhance wetlands to benefit wildlife.
  • Continuing the prohibition of stocking of game species and night hunting.
  • Providing wildlife observation and photography opportunities in the proposed expansion area, on Service owned land, using pullouts and interpretive panels.
  • Any other programs and improvements that educate the public about interacting with and respecting wildlife and nature in non-violent ways.


Managing the Wallkill River National Wildlife Refuge for the primary purpose of enhancing biodiversity, and also for the purpose of enhancing public wildlife watching and photography opportunities should be the prime concern of the U.S. Fish and Wildlife Service. 


USFWS statistics show that New Jersey is home to approximately 91,000 hunters (2006 National Survey of Fishing, Hunting, and Wildlife-Associated Recreation, State Overview, Issued July 2007) – a figure that represents just over one-percent of the state’s population.  As New Jersey’s non-hunting public outnumbers the state’s hunters by a margin of more than 95:1, any plan to modify the management goals within the Wallkill River National Wildlife Refuge should reflect this overwhelming preference among the public for non-violent recreational opportunities.


Sincerely, Joe Miele


Contact Us

Committee to Abolish Sport Hunting / C.A.S.H.
P.O. Box 562
New Paltz, NY 12561