Julie Henning
Branch Chief of Conservation Planning and Policy
National Wildlife Refuge System, US Fish and Wildlife Service
5275 Leesburg Pike
Falls Church, VA 22041
Subject: Conservation Groups Comments on 2026-2027 Station-Specific Hunting and Sport Fishing Regulations, FWS-HQ-NWRS-2026-1223
Date: 23 June 2026
Dear Ms. Henning and National Wildlife Refuge System Administration,
The Coalition to Protect America’s National Parks (Coalition) is comprised of over 5,000 members, all of whom are retired, former, or current National Park Service (NPS) employees or volunteers who collectively represent more than 50,000 years of national park management experience. The Coalition studies, educates, speaks and acts for the preservation of America’s National Park System.
We respectfully submit comments on the 2026-2027 Station-Specific Hunting and Sport Fishing Regulations, FWS-HQ-NWRS-2026-1223. We have several items of concern which include adequately funding and staffing
Refuges and the Refuge System in light of the proposed 1,450 new opportunities being opened and our opposition to the rescission of lead ammunition and tackle phase-outs on 9 Refuges that are supposed to take effect on September 1, 2026.
Opposition to Proposed Rescission of Lead Phase-Out on Nine Refuges
We strongly oppose the Service’s proposed rescission of the regulations phasing out lead ammunition and tackle use on nine Refuges.
The decision for Patoka River National Wildlife Refuge to phase out the use of lead ammunition and fishing tackle for approved activities referenced in 87 FR 57108 on September 16, 2022, and Great Thicket, Rachel Carson, Blackwater, Eastern Neck, Patuxent Research, Erie, Chincoteague, and Wallops Island National Wildlife Refuges to phase out the use of lead ammunition and fishing tackle for approved activities referenced in 88 FR 74050 on October 30, 2023 should be upheld as written. These phase out activities were based in sound science and the threats of lead impacts to wildlife and human health have only increased since this time.
The process to institute these changes was public and followed the standards laid out in the Administrative Procedures Act. The resulting regulations in 2022 and 2023 were thoroughly vetted. These regulations were made with “the best available science, analyzed as part of this rulemaking, [which] indicates that lead ammunition and tackle have negative impacts on both wildlife and human health.”
These actions were determined to be compatible with Refuge and Hatchery purposes and in the best interests of wildlife and people which use these lands. Rescinding these regulations will not only have the potential to increase exposure of wildlife and risk to human health, will undo the outreach and compliance work done by the Refuge system for the past three to four years on these stations.
Voluntary lead-free ammunition and tackle programs can be an important first step of the solution to unintentional wildlife poisoning from lead. These programs can engage the sporting community, understand and expand supply chains for lead-free ammunition and tackle, and engage new generations of anglers and hunters in sustainable consumptive recreation. These programs can also alert hunters and anglers to the risk of ingesting lead in meat and the handling of lead. These programs should be maintained and expanded, but due to their relatively limited range at the present moment, they alone are inadequate to address wildlife and human toxicity stemming from exposure to environmental lead. The provisions put in place could greatly contribute to increasing awareness of the risks of lead in the environment.
We oppose the rescission of the regulations governing lead-use on these nine refuges and urgently request that they be stricken from the final rule.
Expanded Opportunities Require Adequate Funding
With Secretarial Order 3447 from Secretary Doug Burgum on January 7, 2026 and Director’s Order 233 from Fish and Wildlife Service (Service) Director Brian Nesvik on February 2, 2026, the Department of the Interior made clear its intention to make public and federally managed lands more open to hunting and fishing. To fulfill these directives, the Service has announced new or expanded hunting and sport fishing opportunities on 107 National Wildlife Refuge System units (Refuges) and four National Fish Hatchery units (Hatcheries).
For fourteen Refuges and three Hatcheries, this would be the first time they have been open for hunting or fishing. These expanded and new opportunities will require Service managers and staff to implement new safety, monitoring, and accessibility infrastructure in addition to additional administrative work. There was a sound reason they were not previously opened and in order to ensure their integrity, adequate funding for staff is critical.
This is coinciding at the same time as federal funding for Refuges and Hatcheries is declining every year. The most recent proposed funding appropriated by the House of Representatives for Refuge resource management is
$506,636,000.00, representing a $15 million decrease from FY2026. Similarly, the House has proposed funding Hatchery operations at $74,000,000.00, a $1.5 million decrease from FY2026. Increasing the expectations, workloads and pressures on Refuge and Hatchery staff must be partnered with sufficient funding for the operations. In order to ensure hunters, anglers, and wildlife are all being stewarded in a safe and responsible manager, we recommend that these expansions of hunting and sport fishing only take place if Service operations are funded, at minimum, at FY2026 levels, and that operations continue to be science-based.
Conclusion
We thank you for your consideration of our requests and thoughts. Refuge and Hatchery lands play an important role in the success of our native wildlife, and serve as fantastic venues for people to connect with nature. The Refuge and Hatchery lands serve as a model for all of our public lands and waters, including in the National Park System. Our comments highlight the need to support the Service’s work with adequate funding, and to allow the best available science to guide Refuge and Hatchery management.
Please feel free to reach out with any questions.
Sincerely,
Elaine Leslie
Executive Council Member
Coalition to Protect America’s National Parks
Mail: 2 Massachusetts Ave NE, Unit 77436, Washington, DC 20013
Web: www.protectnps.org
Phone: (202) 819-8622