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Deadline for public comments in August 8
By Henri Migala
Photo: mule deer buck by Debbie Merrill
July 17, 2022 (San Diego) -- The San Diego National Wildlife Refuge is seeking public comment on their proposed plan to open 160 acres of the San Diego National Wildlife Refuge to hunting. Hunting would be allowed only in the Otay Mesa and Lakes Management Area of the refuge (near Otay Lakes).
The public is invited to review the draft documents for the proposed changes, including the Draft Hunting Plan and Draft Supplemental Environmental Assessment (EA). These documents will be available for a 60-day public comment period ending on August 8. Instructions on how to submit your comment can be found at the end of this article.
The proposed area is generally south of Otay Lakes Road and east of Lower Otay Reservoir.
The San Diego National Wildlife Refuge is located in southwestern San Diego County, and is managed by the U.S. Fish and Wildlife Service, as part of the National Wildlife Refuge System.
Hunting will be allowed for upland game birds (quail, dove, including spotted dove and ringed turtle doves), resident small game (rabbit, jackrabbit) and big game (mule deer).
Expectedly, this issue of opening public lands to hunting has already received numerous responses on social media, both in support and opposition to the proposed plan.
Background and Context
The mission of the National Refuge System is “to administer a national network of lands and waters for the conservation, management and, where appropriate, restoration of the fish, wildlife and plant resources and their habitats within the United States for the benefit of present and future generations of Americans.” Two of the stated goals of the Refuge System include:
- Provide and enhance opportunities to participate in compatible wildlife-dependentrecreation (hunting, fishing, wildlife observation and photography, and environmental education and interpretation); and
- Foster understanding and instill appreciation of the diversity and interconnectedness of fish, wildlife, and plants and their habitats.
The National Wildlife Refuge System Improvement Act of 1997 defines the priorities for public uses on Refuges and establishes six wildlife-dependent recreational uses: hunting, fishing, wildlife observation and photography, and environmental education and interpretation, as the priority general public uses of the Refuge System.
These uses are to receive priority consideration in Refuge planning and management, and if it is determined that a proposed wildlife-dependent recreational use is a compatible use within a Refuge, that activity “should be facilitated, subject to such restrictions or regulations as may be necessary, reasonable, and appropriate.”
The draft hunting plan states that “the proposed hunting program is not only a compatible use of the Refuge, but would specifically support Refuge Goal 4 of “providing compatible wildlife-dependent recreation.”
Specific strategies for the San Diego National Wildlife Refuge hunt program include:
- Establish an annual special hunt for youth and disabled hunters.
- Working closely with CDFW and the hunting community, identify needs and funding for facilities that when implemented will support a quality hunting program that is compatible with Refuge purposes.
- Develop and manage the hunting program.
The Refuge is not currently open for hunting. There are, however, several very limited opportunities for hunting in the general vicinity of the Refuge, including the California Department of Fish and Wildlife (CDFW) Otay Mountain Ecological Reserve and the Bureau of Land Management (BLM) Otay Mountain Wilderness, where hunting and non-commercial trapping are allowed under State and local laws and in accordance with BLM’s Wilderness Area regulations. Other CDFW hunting areas include a small portion of the nearby Hollenbeck Canyon Wildlife Area, where dove and quail hunting is permitted.
Additionally, the U.S. Forest Service’s Cleveland National Forest is open to hunting of certain bird and game species, including deer, in accordance with the current season schedule and hunting regulations set by CDFW. Hunting is also permitted on some Bureau of Land Management (BLM) lands near the Refuge, as well as other BLM areas located further away, in eastern and northeast San Diego County.
Barrett Reservoir is open by reservation for waterfowl hunting throughout the season established for the southern California zone, and turkey hunting is offered at Sutherland Reservoir on a Monday, Wednesday, and Saturday schedule for the fall season (November) and the spring season (end of March to beginning of May). Periodically, San Diego County has approved a youth turkey hunt at the Santa Ysabel East Open Space Preserve.
The Proposed Plan
The National Refuge Service has determined that the hunting of big game (i.e., deer), resident small game (i.e., rabbits), and resident and migratory upland game birds (i.e., dove, quail) on the San Diego National Wildlife Refuge is a “compatible wildlife-dependent recreational use.”
The Environmental Assessment prepared in association with the Comprehensive Conservation Plan also concludes that wildlife and habitat resources managed on the Refuge are “healthy and robust enough to support regulated hunting in designated portions of the Refuge.” In addition, the Service concluded that “hunting activities will not affect or are not likely to adversely affect any of the special status species or their designated critical habitats on the hunt area of the Refuge, including the threatened coastal California gnatcatcher (Polioptila californica californica), endangered Quino checkerspot butterfly (Euphyrdryas editha quino), threatened Hermes copper butterfly (Lycaena hermes), and endangered Mexican flannelbush (Fremontodendron mexicanum).”
According to the proposed plan and Environmental Assessment, “targeted wildlife populations are present in sufficient numbers to ensure that Refuge objectives for management of these species can be sustained. The Refuge will adopt harvest regulations set by the State of California that uses concepts of density dependent compensatory mortality and adaptive harvest management to ensure sustained game species populations. In addition, impacts to non-target species are minimized through regulations related to when, where, and how hunting can occur on the Refuge.”
The hunting plan and Environmental Assessment go on to state that “the remaining portions of the Refuge are closed to hunting and large areas of the Refuge are closed to all public uses to provide sanctuary for target and non-target species.
The San Diego National Wildlife Refuge is made up of 12,300 acres. The proposed hunting plan would use 160 acres, or only 1.3% of the available land.
There will not be a separate or dedicated Refuge application or registration procedure for hunting on the San Diego National Wildlife Refuge, and all hunters will be required to follow all established hunting laws, rules and regulations already enacted to control such activities. Hunters will be required to have the appropriate CDFW license and tags required to hunt the specific species, but there will not be additional Refuge-specific registration procedures.
The area where hunting will be permitted is not open to the public year-round; therefore, there shall be no provision for pre-hunt scouting. And since the proposed area has not been, and will not be, open regularly to the public, the proposed hunting activities will not interfere with current, or established, land use activities of non-hunters.
Hunters’ Contributions to San Diego Wildlife
Many non-hunters consider hunting and hunters as posing threats to, and being inconsistent with, maintaining healthy wildlife populations. But history and data show that hunters are some of the region’s and country’s most dedicated and committed conservationists, and revenues associated with hunting and fishing as providing the most funding for habitat restoration, wildlife management and conservation, than any other source of funding
Many San Diegans enjoy a drive out to the backcountry to enjoy the scenery and the wildlife. Before the current drought, it was not uncommon to see a flock of turkey when driving to Julian, or through the Laguna mountains. But in 1990, there were no turkeys in San Diego County.
“Turkey were at one time numerous in Southern California,” said Steve Turigliatto, San Diego County Fish and Wildlife Commissioner, and former president, and current Board member, of the National Wild Turkey Federation. “Because turkey bones are found in abundance in the La Brea Tar Pits. But, for some reason, they had long since disappeared.”
“But thanks to John Massie, lead biologist with Dept of Fish and Wildlife, much of San Diego County today enjoys a healthy population of wild turkey,” continued Turigliatto.
Efforts to reintroduce wild turkey were attempted in the 1940s and ‘50s, but were not successful because the species of turkey were incompatible with the local environment. They were the wrong turkey. But in 1993, a hybrid Rio and Eastern species of Turkey was introduced which was better adapted to the rain patterns in San Diego.
“In 1993, approximately 293 (some sources say up to 306, but the data is uncertain because some birds died in transport) were introduced in 3 locations: the McCaw Ranch, near lake Sutherland, the Eagle Peak Ranch, near Julian, and the Cantarina Ranch in Wynola, near Julian,” shared Turigliatto. “Today, every turkey in the county of San Diego, is descendant from these original birds.”
Turkey in San Diego became so plentiful, some estimates were as high as 30,000, that the county opened a 2nd hunting season in the Fall, primarily to limit the number of turkeys.
“There were too many,” said Turigliatto, “but the prolonged current drought has been devastating on the local turkey population, which may be down to as low as 5,000 today.”
Recognizing the declining numbers of turkey in San Diego, the National Wild Turkey Federation San Diego Chapter recommends not hunting turkey in the Fall. But if you do, don’t shoot hens – to allow them the opportunity to reproduce.
“Hunters are conservationists, and we police ourselves,” said Turigliatto. “We have a vested interested in our wildlife doing well.”
Turigliatto also shared stories about the significant amount of volunteer time and effort that hunters put into conservation and habitat restoration throughout San Diego, such as planting trees, shrubs and other vegetation, seeding areas, and putting in “guzzlers,” (watering tanks for wildlife).
“What people don’t realize is that all wildlife benefits when we put in guzzlers for dove and quail – from bluebirds to rabbits to rattlesnakes,” shared Turigliatto. “But it’s only the hunting community that comes out to work and put in the long, hot hours on the habitat. I can’t seem to get any other part of the community involved in getting out there and doing the work.”
Environmentalists weigh in
Wildlife photographer Debbie Merrill, who has photographed wildlife throughout the refuge, told East County Magazine, “I am so sad, but not surprised to see this is progressing. The very definition of Refuge is "a place of safety and security.”
She acknowledged that some wildlife refuges do allow hunting, such as San Jacinto, where duck hunting is allowed only on designated days when the refugee is closed to non-hunters. The land that Fish and Wildlife’s offices are on in Jamul allows hunting of non-native pheasants.
But Merrill says of the proposed plan, “The enjoyment of the Refuge will be erased once users hear gunfire around them and any sense of safety will be gone…. The effects hunting will have on any wildlife in the area will be to leave, abandon nests/den sites, and create stress in conflict with what a Refuge is. A place where Wildlife can reproduce and live safely.”
She voiced concerns over lack of enforcement, adding, “I saw many instances of poaching in my ten years living next to the refugee, including skinning out of animals and carcasses left.”
She also indicated that conflicts among birdwatchers, trail users and hunters are occurring in nearby Hollenbeck Canyon. In addition, she contends the area is too small for hunting and that wildlife there is already negatively impacted by mountain bikers going off trails, illegal offroad vehicles, undocumented immigrants and visitors who have removed fencing and signage.
The Sierra Club of San Diego was contacted by East County Magazine for comment, but they were unaware of the proposed plan and opted to not share a comment.
The San Diego County Wildlife Federation, a non-profit organization “dedicated to the management of San Diego County's open spaces and wild lands for the conservation of our unique habitat and wildlife, as well as for the benefit of the active recreational user,” was also contacted for comment.
“It’s too small for the size of the refugee, and all the land that’s out there,” said Gary Brennan, President SD County Wildlife Federation, about the proposed plan to provide access to only 160 acres of San Diego National Forest Wildlife land.
“For the total amount of the land that’s available, what they are opening for hunting is too little,” shred Brennan. “It can be covered rapidly by a couple of hunters with dogs. Not overworked, but just hunted pretty fast.”
Brennan recounted that “we (the San Diego Wildlife Federation) were in discussions with wildlife officials in the early stages of this plan. We told them a long time ago that we would be willing to work with them to get further input from all the hunting clubs. We wanted to make sure there was enough land to hunt. We’re always willing to work with our elected officials and governmental organizations to increase access for hunting and angling in San Diego County. But they got their initial input and that was it.”
“It’s more of a token area just to appease hunters, but it’s pretty small,” lamented Brennan.
Not everyone is in support of the proposal. “A lot of our volunteers are very concerned and upset about this,” said Jason Joslyn with the Ecological Servants Project in El Cajon. “They’re concern is that it’s been a wildlife refuge where hunting hasn’t been allowed, but now they’re opening it up to hunting in an area meant to protect wildlife. Our volunteers don’t want these animals being hunted.”
Joslyn went on to share his concerns about the possible damage that will be done to the area and wildlife as a result of the proposed hunting plan. “When you start shooting guns, you start putting wildlife at risk. And, according to the plan, they’re going to allow hunting dogs, and it seems obscene to me that they’ll allow dogs to run around and tear up the land. If you’re going to be out there with a dog, the dogs will be used for birds. And we have a very small amount of gnatcatchers. I highly doubt that a dog will know the difference of a gnatcatcher and the bird it will be after. I had a dog once and it killed a bird. Snatched it right out of the air. That’s what these dogs do. These dogs are bread to kill animals.”
“How many people who are going to be going in there to hunt are actually going to be eating the meat?” questioned Joslyn. “Seems like it’s going to be more for the sportsmanship for the hunters. It’s just hogwash. It’s just for the hunters. It’s not for the animals.”
“This plan shouldn’t even be on the table,” continued Joslyn, “because there’s not a necessity for it. There’s plenty of available other hunting options nearby that meets the needs of the hunting community.”
“There isn’t a lot of deer out there,” shared Joslyn, “I come from NY where there are lots of deer. I would see deer several times each month. There are so many deer up there that hunting is just part of the culture there.” Asked if he thought that the abundance of deer in New York might be related to the robust support that hunting receives in New York, and other states where deer are abundant, to make sure that wildlife populations are healthy and thriving, Joslyn responded that “I don’t think so."
Public Comments
Social media sites have been active with members of the public sharing their thoughts, comments and opinions, both in support of, and opposition to, the proposed hunting plan. As with any topic on social media, the “facts” presented by those posting comments are not always accurate, valid or even true.
Below is a sampling of some of the comments shared on social media by members of the public regarding the proposed hunting plan:
“Quail hunting would be fantastic. There are not enough public hunting grounds in San Diego country…driving all the way to Imperial County seems silly.” -- Gerry A.
“Yeah, a bunch of alcohol fueled "hunters" with long guns & automatic weapons shooting everything that moves. Who would even consider something like this?” --Shawn C.
“Game Management, done correctly, can be beneficial to the species in question. Especially if there is a shortage of natural predators. It’s best to see if this is based on hood science before jumping to conclusions.” --Perry W.
“I’m a big walker but haven’t been here. If it’s a refuge, why are they hunting? They wouldn’t even cull bobcats in the Julian area and they are more dangerous than deer. They should be giving the reason.” -- Beryl G.
“I think that’s a good idea, coyotes are in the rise again as well as ground squirrels (a nuisance species known to carry disease). I say let them hunt.” --Jay R.
“Hunting can be a very beneficial part of keeping a wild area in balance. Yet, when I'm hiking in that area, I rarely see any animal in abundance. Let alone in surplus. After San Diego County's three major fires, the deer are near extinct. I can't imagine quail needing to be culled. This area is not that big. Roadways and hiking trails are very nearby. This sounds like a disaster in the making.” --David P.
“I'm for it! Responsible hunting and regulated hunting are parts of a good wildlife management system.” --Andee A.
To Submit your Comments
Comments must be submitted to Office of Management and Budget by August 8, 2022.
You may submit comments to the OMB by one of the following methods:
- Electronically: Go to the Federal eRulemaking Portal: https://www.regulations.gov
In the Search box, type in FWS-HQ-NWRS-2022-0055, which is the docket number for this rulemaking. Then, click on the Search button. On the resulting screen, find the correct document and submit a comment by clicking on “Comment.”
- By hard copy: Submit by U.S. mail or hand delivery:
- Public Comments Processing
Attn: FWS-HQ-NWRS-2022-0055
U.S. Fish and Wildlife Service
5275 Leesburg Pike, MS: PRB (JAO/3W)
Falls Church, VA 22041-3803.
- The Office of Management and Budget does NOT accept email or faxes
Comments can be sent to the office of Fish and Wildlife Services at HuntFishRuleComments@fws.gov with "San Diego NWR" in the subject line.
All comments will be posted on https://www.regulations.gov
LITERATURE CITED
The literature cited in the proposed hunting plan and Environmental Assessment:
- County of San Diego. 1998. Final Multiple Species Conservation Program; MSCP Plan. 278 pp.
- U.S. Fish and Wildlife Service (USFWS). 1997. Environmental Assessment and Land Protection Plan, Otay-Sweetwater Unit, San Diego National Wildlife Refuge, San Diego County, California.
- U.S. Fish and Wildlife Service (USFWS). 2017. Comprehensive Conservation Plan for the San Diego, National Wildlife Refuge, San Diego County, California
LINK to the Proposed Hunt Plan:
Public Comment and Review for Refuge Hunt Plan and Environmental Assessment:
https://www.fws.gov/story/2022-06/public-comment-and-review-refuge-hunt-plan
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