Comment on FR Doc # 2011-21484

I am writing on behalf of the Michigan Citizens Waterfowl Advisory Committee to express our dissatisfaction with the USFWS decision regarding redhead daily bag limits as published in the recent Federal Register. The Citizens Waterfowl Advisory Committee (CWAC) is a group of 19 people representing a diverse mix of organizations and individuals throughout Michigan with interest in waterfowl. CWAC has been providing input and recommendations to the MDNR on waterfowl hunting issues since 1980. We meet twice annually with the DNR. We are writing because we feel that this process resulted in a loss of potential hunting opportunity for waterfowl hunters. The redhead bag limit has been fixed at 2 birds daily for many years without the guidance of a formal harvest strategy and apparently without much discussion about how this conservative regulation affects diver duck hunters. Michigan is losing a tradition with declining opportunities to harvest species like scaup. Hunting diving ducks requires extra gear and effort and many hunters have quit this type of hunting because of the effort required to take so few birds under restrictive regulations. With a record breeding population of 1.4 million redheads, surely this population could have sustained any additional harvest resulting from a change to a 3-bird bag limit. If the population declined, it would be simple to revert back to the 2-bird limit that has sustained an increasing population. We did not write when the scaup limit was reduced. We understand the need for restriction where and when needed. We are disappointed that USFWS would not act on behalf of diving duck hunters by allowing an additional redhead in the bag limit in the face of unprecedented abundance and population growth. Please take a more positive and proactive stance in support of waterfowl hunters and in maintaining waterfowling traditions. This means more than just restriction when possible. Thank you, John Huffman Chairman, CWAC