Comment on FR Doc # 2010-11032

From: Marc Schultz-Chairman, La Crosse County Conservation Alliance Re: Third Wisconsin Waterfowl Zone-Mississippi River Subzone Date: June 24 , 2010 The La Crosse County Conservation Alliance, which is comprised of 26 local conservation organizations with 5000+ members, many of whom are waterfowlers, has for decades advocated for waterfowl seasons for the Mississippi River. This is best exemplified by the results of the June Waterfowler Meeting held by the Alliance in cooperation with staff from WDNR and USFWS. Since 1987 at the June meeting waterfowler input on season structure is gathered and agency staff inform waterfowlers on the status of waterfowl populations and habitat. The creation of the North/South Migratory Zones occurred due to the different weather and migration conditions in those areas, which greatly affected hunting opportunities. While the North/South Zone lines need to be "tweaked" occasionally, they have generally served the purpose of allowing maximum hunting opportunities in the northern reaches of the state prior to freeze-up, dependent upon weather conditions. One confounding issue that has been the topic of heated debates concerning the waterfowl seasons in the South Zone, however, has been the extreme differences in hunting opportunities in the Mississippi River Sub-Zone versus those cited in the far majority of the rest of the South Zone. The Mississippi River Sub-Zone, due to river conditions and waterfowl migrations, historically has hunting opportunity potential far later than that of the rest of the South Zone. This issue has been pointed out, argued repeatedly, and generally is a "monkey-wrench" in setting the waterfowl seasons for the South Zone. Inevitably, maximizing waterfowl hunting opportunities for the South Zone is confounded and confused by the conditions on the Mississippi River Sub-Zone. The question of "Why don't we just have three zones without splits?" is often asked. In years of 60-day waterfowl seasons it may not be problematic, however with the potential of 45 or 30 day seasons the inability to have the option for splits will be disastrous in attempting to afford the maximum number of hunting opportunities for all involved. The La Crosse County Conservation Alliance is supporting the Wisconsin DNR, The Upper-Region Regulations Committee of the Mississippi Flyway Council, and the Central and Pacific Flyway Councils recommendation that the Service allow 3 zones, with 2-way splits in each zone as an option for the 2011-2015 duck seasons. In doing so, Wisconsin could offer maximum waterfowl hunting opportunities, while maintaining conservation of the resource, based upon the varying conditions inherent in these different regions, to those who choose to take part in Wisconsin's great heritage of waterfowling. Thank you for the opportunity to comment on this issue. Marc Schultz-Chairman La Crosse County Conservation Alliance