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enforcement of fish and wildlife laws is an essential component of fish and wildlife 

 conservation" and "the public has the right to expect that fish and wildlife regulations will be 

 unambiguous, relatively easy to interpret, and applied consistently in all areas across the 

 country." In short, the regulations must be "user friendly." Accordingly, we urge that all 

 wildlife enforcement agencies strive towards user friendly regulations to facilitate compliance 

 by people involved in wildlife related recreation and, ultimately, to enhance wildlife 

 conservation. 



Another critical component of law enforcement is education. Fish and wildlife 

 agencies and their law enforcement branches should be engaged fully in educating the public 

 about fish and wildlife regulations, and the reasons for those regulations. This will enhance 

 the desire of wildlife associated recreationists to comply with the regulations, decrease 

 violations, and improve conservation. 



Moist Soil Management 



On March 22, 1996 the Service published (Federal Register 61 [57] 11805-11806) a 

 notice that it is beginning to review and may later propose to change the regulations 

 governing the "manner in which, or if at all, natural vegetation in moist soil areas may be 

 altered or manipulated artificially to attract waterfowl for hunting purposes." We commend 

 the Service for its intent to review these regulations to ensure that they are working as 

 intended and are "user friendly." 



We are deeply concerned that allowing cutting of mature vegetation will, in essence, 

 create "baited" areas sufficiently attractive to waterfowl to inappropriately enhance their 

 susceptibility to hunters. This would essentially reverse a policy of prohibiting baiting in 

 waterfowl hunting because of greatly increased vulnerability of birds to harvest. 



Furthermore, the use of bait seems to violate the rules of fairness, as all hunters 

 certainly are not equally capable of bearing the cost of baiting operations. It is easy for a 

 few heavy baiters to attract waterfowl away from other nearby areas, thereby decreasing 

 hunting opportunities for other hunters. Waterfowl hunting should be available to all 

 hunters, not just to those who can afford costly baiting operations. 



The Service notes that some people allege mowing of vegetation around duck blinds 

 should be allowed because habitat is being lost when landowners, finding that the current 

 rules cause economic hardship, simply forego hunting as a source of income and convert 

 waterfowl habitat to other uses. However, as the Service notes in the proposal, losses of 

 waterfowl habitat because current regulations are not economical is unproven. Also, it is 

 unproven (as well as unlikely) that simply changing vegetation management would make an 

 unprofitable op)eration into a money-maker. Furthermore, there are federal statutes (Section 

 404 of the Clean Water Act) that protect wetlands, thereby reducing the degree to which 

 waterfowl habitat is converted to other uses. In short, there is very little, if any, evidence 

 that mowing regimes determine whether or not a wetlands habitat will be converted or lost. 



