A Refuge in Name Only:

Why the USFWS Proposal to Open 95% of National Wildlife Refuge Lands to Hunting, Fishing, and Trapping Is Misguided 

The first time I visited Quivira National Wildlife Refuge in Kansas, I was hoping to photograph one of North America’s rarest birds.

My father and I had driven several hours to reach the refuge during peak migration season. We arrived before dawn, set up our cameras in the dark, and waited for sunrise over the wetlands. Quivira is one of the most important stopovers in the Central Flyway and one of the few places in the country where visitors have a chance to see endangered whooping cranes during migration. Roughly one-fifth of the entire wild population stops there each year.

As the horizon began to brighten, the silence shattered. Shotguns erupted across the refuge. More blasts punctuated the early morning quiet every few seconds.

…We hadn’t realized we had arrived on the opening weekend of duck season.

Within minutes, all the birds—ducks but also plovers, pelicans, stilts, avocets, herons, cranes, and more—were flushing from the marshes and circling overhead. The peaceful wildlife spectacle we had traveled to witness was replaced by a steady cadence of gunfire echoing across a landscape we had thought was set aside for wildlife conservation.

That was the first time I heard, “hunting is conservation.”

Eventually we learned that the whooping cranes we hoped to see were nearby at the state-run Cheyenne Bottoms Wildlife Area, where hunting restrictions are implemented when cranes are present. We were fortunate enough to find them there, observe and photograph them, and salvage the trip.

But the experience left me with a question that has only become more relevant over time: What is a wildlife refuge for? And why are endangered birds undertaking one of the most demanding migrations on Earth forced to navigate a landscape where hunting pressure overlaps with some of the most critical periods of their annual cycle?

Neither my father or I had expected that a national wildlife refuge, particularly one famous for endangered migratory birds, would simultaneously function as a hunting destination. Perhaps that was naive, but how many other members of the non-hunting public hold similar beliefs?

To me, our experience illustrates a broader reality. Across the country, millions of Americans visit wildlife refuges to watch birds, photograph wildlife, hike, learn, conduct research, or simply experience wild places. 

Yet right now, we are moving toward a future in which nearly every refuge in America is managed primarily around expanding opportunities to kill wildlife because a sweeping new proposal from the U.S. Fish and Wildlife Service would make approximately 95 percent of National Wildlife Refuge System lands available to hunting, fishing, and trapping.

What’s Happening?

On May 26, the U.S. Fish and Wildlife Service (USFWS) announced that it would open or expand hunting and fishing opportunities across more than 92 million acres of National Wildlife Refuge System lands. If adopted, approximately 95% of all refuge lands nationwide would be available for hunting, fishing, and trapping.

The proposal affects 107 refuges and four national fish health centers across 32 states and creates more than 1,450 new or expanded hunting and fishing opportunities. It would also eliminate longstanding refuge-specific protections by aligning many refuge regulations with state hunting regulations, including allowing practices that refuges have historically restricted because of their impacts on wildlife and habitat. 

To achieve this, the proposal includes more than 500 revisions and deletions to the existing Code of Federal Regulations, advancing a broader effort to standardize refuge management around state wildlife laws rather than the unique ecological needs and conservation purposes of individual refuges.

The comment period closes June 26.

At first glance, the proposal may sound administrative, but it actually represents a significant shift in how the federal government views the purpose of the National Wildlife Refuge System and who these public lands are meant to serve.

For more than a century, national wildlife refuges have functioned as places where wildlife conservation comes first. This proposal moves in the opposite direction, prioritizing the expansion access for a small subset of users while weakening the refuge-specific conservation standards that distinguish wildlife refuges from other public lands. The result is a future in which “refuge” becomes little more than a label.

What Makes a Wildlife Refuge Different?

The National Wildlife Refuge System was created because Americans recognized that wildlife needed places where protection of wildlife was the primary goal. Congress reinforced that mission through the National Wildlife Refuge System Improvement Act of 1997, which established conservation, management, and restoration of fish, wildlife, and plants as the mission of the refuge system for present and future generations.

Hunting and fishing are permitted on many refuges today, but only after refuge managers determine that those activities are compatible with the specific conservation purposes of that refuge. The system was intentionally designed around refuge-by-refuge decision making because every landscape, species assemblage, and ecological challenge is different.

The new proposal weakens that approach because rather than asking what wildlife in a particular refuge needs, the proposal increasingly asks how refuge regulations can be brought into alignment with state hunting regulations. 

The stated goal is to remove what the administration calls “unnecessary barriers” to hunting and fishing access. Some changes include refuge-specific changes like opening up new species to hunting, like alligators, or allowing hunting from tree stands, while others are more broad-sweeping, like rolling back restrictions on lead ammunition and fishing tackle.

That seemingly simple change carries profound consequences because wildlife refuges were never intended to function as extensions of state hunting programs. They were created to provide an additional layer of protection where ecological needs, scientific expertise, and long-term conservation goals could take precedence.

We should also acknowledge that, for decades, refuge management has drifted away from rigorous refuge-by-refuge conservation analysis and toward a system in which hunting receives increasingly preferential treatment. The current proposal accelerates that trend by replacing refuge-specific decision-making with broader alignment to state hunting regulations.

When refuge regulations are expected to sacrifice their original mission to mirror state regulations, they lose much of the reason they exist.

Wildlife Refuges Are Part of Interconnected Systems

National wildlife refuges are interconnected ecological infrastructure that spans this entire continent. Migratory birds, large mammals, pollinators, fish, and countless other species depend on networks of protected habitats crossing states, regions, and international borders.

A refuge in Oregon is connected to a refuge in California. A wetland in Kansas is connected to breeding grounds in Canada and wintering habitat on the Gulf Coast. Species move through entire landscapes. This is especially true for migratory birds.

The United States has already lost billions of birds over the past half century. Habitat loss, climate disruption, pollution, disease, and development continue to place immense pressure on migratory populations.

Refuges function as critical places where birds can rest, feed, and recover during migration. Expanding hunting pressure while simultaneously reducing conservation safeguards moves in the wrong direction at a time when wildlife needs stronger protections, not weaker ones.

The Lead Ammunition Rollback

One of the most troubling aspects of the proposal is its rollback of restrictions on lead ammunition and fishing tackle.

Lead poisoning remains one of the most well-documented threats to wildlife. Eagles, condors, swans, cranes, loons, and many other species ingest lead fragments directly or consume contaminated prey and carcasses. In fact, 2022 research published in Science found that nearly half of all bald and golden eagles in the United States show evidence of chronic lead exposure.

Lead restrictions on refuges were adopted because the science is clear. Wildlife suffers when lead enters ecosystems yet rather than strengthening those protections, the proposal would move backward.

The question is not whether non-toxic alternatives exist because they do. So why would the federal government would reverse science-informed protections that were specifically designed to reduce preventable wildlife mortality on places designed to conserve and protect wildlife? 

This Is Not Business as Usual

Supporters of the proposal have argued that hunting has long been allowed on national wildlife refuges and that administrations of both parties have periodically expanded hunting and fishing opportunities.

That’s true, hunting does occur in refuges. The issue here is whether the federal government should treat hunting, fishing, and trapping access as the default condition across nearly the entire refuge system.

Even some longtime refuge managers have raised concerns about the direction of the proposal. Former U.S. Fish and Wildlife Service Director Steve Williams, who led the agency under President George W. Bush and oversaw expansions of hunting and fishing opportunities on dozens of refuges, recently questioned whether the agency has the capacity to implement this approach while fulfilling its conservation responsibilities.

During his tenure, refuge planning processes included analyses of hunting and fishing opportunities, and new access was added where appropriate. What concerns him now is the broader context: significant staffing reductions, budget cuts, and a policy framework that increasingly presumes refuges should be open to hunting and fishing unless specifically closed.

Historically, refuge managers evaluated whether hunting was compatible with a refuge’s conservation purposes. The current proposal moves toward the opposite presumption, that expanded access should be the norm, restrictions the exception, and conservation activities should take a backseat to recreation access as Footloose Montana founder Anja Heister notes.

At a time when wildlife populations face mounting pressures and federal conservation agencies are losing staff and resources, expanding recreational uses while reducing management capacity raises a legitimate question: who will ensure that conservation remains the primary mission of the National Wildlife Refuge System?

Following the Influence

This proposal did not emerge in a vacuum. For years, organizations including Safari Club International, the U.S. Sportsmen’s Alliance, state outfitter associations, and trapping organizations have advocated for greater hunting access on federal lands and greater alignment between federal and state regulations.

Recent meetings, lobbying efforts, policy recommendations, and Interior Department directives reveal a clear pattern: reducing refuge-specific protections and increasing deference to state wildlife agencies. And as we’ve documented, those agencies are often heavily influenced by hunting interests themselves.

Wildlife for All has long documented how state wildlife governance systems frequently fail to reflect the values of the broader public. Most wildlife commission seats are still disproportionately occupied by hunters, anglers, agricultural interests, and industry representatives, despite the fact that most Americans do not hunt or trap (though they do watch and photograph wildlife).

This proposal extends that same governance problem onto federal lands. Instead of strengthening independent conservation standards, it alarmingly imports the shortcomings of state wildlife governance into one of the nation’s most important conservation systems.

Who Are Wildlife Refuges For?

This is ultimately the question Americans should be asking because the overwhelming majority of refuge visitors are not hunters.

They are birders, photographers, hikers, educators, researchers, families, and people seeking a connection to the natural world. They are people who believe wildlife has value beyond recreation and harvest.

The USFWS’ own data confirms this: from 2018-2023, 59% of visitors came to watch wildlife, 56% to hike, 46% to birdwatch, and 39% to take photographs. In contrast, 18% of visitors came to fish (another 5% for saltwater fishing), 5% for waterfowl hunting, 2% for big game hunting, and another 2% for upland/small game hunting.

More broadly, Americans contribute billions of dollars to conservation through taxes, outdoor recreation spending, wildlife viewing activities, philanthropy, and public support for conservation programs.

The public has invested heavily in protecting these lands and all users are stakeholders. Yet this proposal prioritizes expanding opportunities for a small minority of users while reducing safeguards for the wildlife those refuges were established to protect.

That is not conservation; it is a political choice, and it is one that deserves public scrutiny.

The Bigger Picture

Wildlife refuges are not simply parcels of land on a map. They are one of the few remaining places where wildlife conservation is supposed to come first.

At a moment when biodiversity loss is accelerating, migratory bird populations are declining, climate pressures are intensifying, and federal conservation agencies are experiencing significant staffing and funding reductions, weakening refuge protections sends exactly the wrong message.

Right now, Doug Burgum and Brian Nesvik are signaling that nearly the entire National Wildlife Refuge System should be managed for the continual expansion of hunting and fishing, not actual conservation.

A refuge should be more than a place where wildlife survives until the next season opens; it should be a place where wildlife can truly find refuge.

How to Comment

Wildlife for All encourages supporters to submit comments opposing this proposal and urging the U.S. Fish and Wildlife Service to:

• Maintain refuge-specific conservation protections
• Uphold science-informed wildlife management
• And ensure that national wildlife refuges remain places where the needs of wildlife—not special interests—comes first.

The U.S. Fish and Wildlife Service is accepting public comments on this proposal through June 26, 2026. Comments should reference docket number FWS-HQ-NWRS-2026-1223 and must be submitted through the federal rulemaking process; comments submitted by email or fax will not be considered.

Remember, effective comments are specific and substantive. Rather than simply stating support for or opposition to the proposal, identify the particular refuge, species, management practice, or regulatory change you are addressing. 

For example, you may wish to comment on expanded hunting or trapping access, the rollback of lead ammunition restrictions, refuge-specific conservation protections, or the proposal’s reliance on state wildlife regulations. 

Explain what concerns you, what changes you support, and how the final rule could better uphold the conservation mission of the National Wildlife Refuge System.

Mandy Culbertson is the communications director for Wildlife for All and an amateur, though enthusiastic, wildlife photographer.