Comment on FR Doc # 2010-11032

I am submitting this as my personal public comment on the Zones/Splits for the 2011-2015 Waterfowling Seasons. Waterfowlers in the Mississippi River Sub-zone in Wisconsin have been advocating for Wisconsin to have the option of 3 duck zones with splits in each zone for well over a decade. The hunting and migration conditions in the Mississippi River Sub-zone in Wisconsin vary widely from the rest of the South Zone which causes confusion and frustration with the season-setting process year after year. The Mississippi River Sub-zone meets the federal criteria for duck zone delineation. We now simply need the option available to us for Wisconsin to have 3 zones with splits in each zone. Some have discussed the current ability to have 3 zones without splits. During years of 60 day season, this would probably not be problematic. Bit in years of reduced seasons, this would be a true disaster for hunters in the Mississippi River Sub-zone. I fully understand that some states have been grandfathered in with 3 or more zones with splits and they should be allowed to continue. Apparently such an option must not have a significant effect on the empirical data in the Adaptive Harvest Management Program, or certainly they would have been ended. However, the allowance of those states to maintain those options should also be seen as a de facto precedent for other states to have the same option. In closing I am supporting Wisconsin, or any other states requesting it, to have the option of 3 zones with splits in each zone for the 2011 to 2015 duck seasons. To do so will allow conservative use of the resource while maximizing hunting opportunities. If other states have had this option and it has not been shown to be empirically problematic to a significant level, then it certainly should be allowed in Wisconsin. Thank you for the opportunity to comment on this issue which I have pursued for over 15 years. Ray Heidel Onalaska, WI