The Biggest Hunting Expansion in Refuge History Is Also Its Most Controversial
On paper, the numbers are staggering. The proposal would make more than 92 million acres, or over 95% of National Wildlife Refuge System lands, available for hunting — a milestone the administration is framing as the most significant expansion of public access in the agency's history. The U.S. Fish and Wildlife Service is proposing to open or expand hunting opportunities on 111 field stations, including 107 units of the National Wildlife Refuge System and four units of the National Fish Hatchery System, adding more than 1,450 opportunities for hunting and fishing across the combined system. For hunters and anglers who have spent years navigating the patchwork of federal access restrictions, this reads like a long overdue correction. But the proposed 2026–2027 Hunt-Fish Rule is drawing sharp criticism from conservationists and former federal land managers who argue it is being layered on top of a system already buckling under chronic neglect — and that the result could be more harmful than the problem it claims to solve.
What the Rule Actually Does
The U.S. Fish and Wildlife Service recently released its proposed rule expanding hunting and fishing opportunities across the National Wildlife Refuge System, framed as a means of "moderniz[ing] federal regulations," opening new refuge areas and lifting closures on others. The scale dwarfs previous annual rulemaking cycles. The Service offered more than 1,000 new hunting or fishing opportunities across more than 2 million acres of Service-managed lands and waters from 2019 to 2021 — and yet the current proposal eclipses those efforts in scope and ambition.
The proposed rule would increase access at 111 field stations, including 107 national wildlife refuges and four national fish hatcheries, and includes first-ever hunting or sport fishing opportunities at 14 refuges and three hatcheries. Specific regional highlights give a sense of the geographic reach involved. Big game hunting would open at Rocky Flats National Wildlife Refuge in Colorado, the first of any hunting allowed at the site, which once held a nuclear weapons plant. Neal Smith National Wildlife Refuge in Iowa, a 6,000-acre property established in 1990 to protect and restore native tallgrass prairie and oak savannas, would be newly open to waterfowl and upland hunting and its big-game hunting would be expanded. On Grass Lake National Wildlife Refuge, a 4,300-acre complex of wetlands and adjacent prairie in central Montana, hunting for migratory birds, upland game, and big game would be allowed under the proposal.
The rule also reflects a broader effort to simplify and modernize federal regulations, with the Service proposing more than 500 revisions and deletions to existing regulatory provisions, reducing complexity and making it easier for hunters and anglers to understand and comply with applicable rules. That regulatory streamlining piece is the part many in the hunting community genuinely welcome — years of contradictory, station-specific regulations have made planning a refuge hunt feel like reading a tax code. But buried in the proposal is another provision drawing fire from wildlife advocates with real teeth: the rollback of lead ammunition restrictions.
The Lead Ammunition Rollback: An Overlooked Flashpoint
In 2022 and 2023, the Service finalized regulations requiring the use of non-lead shot shells, single-fire ammunition, and/or fishing tackle at nine National Wildlife Refuges, with those regulations scheduled to go into effect on September 1, 2026. The Service now proposes to rescind these regulations and invites the public to comment on the proposed changes. For waterfowl hunters familiar with the lead ban that has governed duck and goose hunting since 1991 — a restriction that demonstrably helped bring back eagle and loon populations that were collapsing from lead ingestion — the rollback cuts against decades of settled conservation science.
Secretary Burgum also ordered refuge managers to align their management practices with those of the states and prohibited restrictions on the use of lead ammo and tackle, removing needed protections for bald eagles among other species. Critics point out that bald eagles, now a symbol of American conservation success, are particularly vulnerable to lead poisoning through scavenging gut piles left by hunters — a well-documented exposure pathway. Advocates at Defenders of Wildlife note that the elimination of these protections runs directly counter to the stated goal of expanding healthy wildlife populations for future generations of hunters and anglers to pursue.
The Institutional Crisis Underneath the Headlines
What makes the Hunt-Fish Rule uniquely contentious is not the idea of expanding hunting and fishing access — virtually no serious conservation organization opposes responsible, compatible hunting on refuges. What they oppose is the specific sequence of events: a historic expansion of recreational use simultaneously with a historic collapse in the staffing and resources needed to manage that use.
Of the 573 refuges nationwide, not a single unit is fully staffed, and over half have no staff on site at all. Needed management projects, including wildlife inventorying and monitoring, have virtually ceased due to chronic funding shortfalls. By any measure, the Refuge System is in substantial decline. That is not a fringe assessment — it is the operational reality documented by the agency's own records and corroborated by field personnel across the country.
Of the 573 refuges nationwide, not a single unit is fully staffed and over half have no staff on site at all. With roughly 200 officers spread across the entire country, law enforcement is virtually nonexistent. Infrastructure is crumbling. The math here is grim. Two hundred law enforcement officers covering the entirety of a refuge system that spans 95 million-plus acres — one that is now being opened to even more hunting pressure — means that effective enforcement of any rules, compatible or otherwise, is essentially theoretical.
The reality is that FWS morale has never been lower, refuges have never received less Congressional support or attention, and most critically, needed management activities are no longer occurring. By demanding more of an already broken system, the proposed rule will make an already desperate situation worse for wildlife. That perspective from Defenders of Wildlife echoes what hunters themselves are hearing from former agency professionals who spent careers building the refuge system into what it is.
Case Studies in Underfunded Management: From Texas to Oregon
Laguna Atascosa and the Ocelot Problem
Laguna Atascosa, located in the Lower Rio Grande Valley, supports the country's only population of endangered ocelots. As the center of recovery efforts for these cats, it requires intensive management, monitoring and restoration of habitats — and to fulfill these and other management goals, the refuge needed nearly double its existing resources two decades ago. That was before the current wave of staffing cuts. Funding has since further declined, yet the hunting program will "increase administrative costs," requiring roughly $100,000 annually. In a refuge already running on fumes, an additional six-figure annual administrative burden for a hunting program is not a small ask — it is a direct diversion of resources away from ocelot recovery efforts that affect one of the most critically endangered big cats in North America.
The Klamath Basin: When Staffing Collapses, Everything Follows
Fifteen years ago, the Klamath Basin Refuge Complex in California and Oregon had over 30 full-time staff. Since then, the workforce has declined by one-third, and the strain has become so great that "we [can] barely keep the front doors open," according to a FWS retiree. The Klamath Basin Complex is not a minor footnote in the refuge network. It is one of the most critical migratory waterfowl staging areas in the entire Pacific Flyway, supporting millions of ducks, geese, and shorebirds during their annual north-south migrations. The fact that hunters care deeply about waterfowl makes the staffing collapse there especially relevant — without adequate personnel to manage water levels, control invasive species, and monitor bird health, the very resource that attracts hunters to the basin will degrade.
$400,000 per year in resources and staff time, none of which are available, are needed to properly oversee the expanded hunt at the Complex, according to the proposed rule itself. That admission buried inside the federal rulemaking document is striking: the agency's own paperwork acknowledges it lacks the resources to oversee what it is proposing to allow.
Cape Romain and the Red Knot: When Incompatibility Gets Overridden
The federally threatened red knot relies on the calories provided by horseshoe crab eggs to complete its transcontinental migration, and horseshoe crab harvesting in Cape Romain National Wildlife Refuge is thus considered an incompatible activity. Cases like this illustrate why the compatibility determination process exists in the first place — not as bureaucratic obstruction, but as a scientific guardrail ensuring that individual refuge uses don't compromise the ecological functions the land was established to protect. The proposed rule's broader pressure to lift restrictions across the system creates concern among biologists that case-by-case compatibility analyses could be subjected to top-down override pressure in ways they historically have not been.
What the Administration Says — and What It Doesn't Address
The effort advances President Trump's priorities to expand access to public lands and reduce unnecessary regulatory burdens, including Executive Order 14192, "Unleashing Prosperity Through Deregulation," and also implements Secretary's Order 3447, which directs the Department to remove barriers to hunting and fishing access and better align federal regulations with state wildlife management frameworks. Interior Secretary Burgum has been the public face of the push. "America's public lands belong to the American people, and they should be able to access them without unnecessary bureaucracy standing in the way," Burgum said.
FWS Director Brian Nesvik took a more measured tone in announcing the proposal. "We are pleased to continue to increase access for hunters and anglers while fulfilling our conservation mission, and we are committed to responsibly managing these areas for the benefit of future generations," said Fish and Wildlife Service Director Brian Nesvik. What neither Burgum nor Nesvik addressed directly in their public statements was the staffing and funding gap — the operational reality that makes "responsibly managing" these areas a genuine question rather than a given.
According to the FWS's most recent National Survey of Fishing, Hunting and Wildlife-Associated Recreation, nearly 40 million Americans fish and more than 14 million hunt, contributing more than $144 billion annually to the U.S. economy. That economic argument is real and not trivial. Hunters and anglers pump money into local rural communities — motels, gear shops, outfitters, restaurants — and their license fees and excise taxes on equipment fund a significant portion of state wildlife management through the Pittman-Robertson and Dingell-Johnson acts. But the economic benefit argument for expanding access does not automatically resolve the question of whether the expanded access can be managed without degrading the wildlife populations that create the economic value in the first place.
Industry and Advocacy Groups: Where the Divides Actually Fall
The response from major stakeholder groups reveals a more nuanced picture than a simple pro-hunting versus pro-environment split. The National Wildlife Refuge Association supports efforts to connect more Americans with the outdoors, noting that any new or expanded opportunities must be carefully evaluated through the required compatibility process to ensure it supports both responsible public access and the wildlife conservation mission of the Refuge System. That phrasing — "carefully evaluated" — is doing considerable work. The Association is not opposing the expansion outright, but it is making a public point about process integrity that directly addresses the critics' concerns.
"Compatible wildlife-dependent recreation is one of the great strengths of the Refuge System," said the Association's president and CEO. "The key is ensuring that refuge managers and staff have the science, staffing, and enforcement capacity, and public input they need to make responsible access decisions that benefit people, wildlife, and local communities." That last sentence lands with particular weight given the documented staffing crisis: if refuge managers lack the science, staffing, and enforcement capacity the Association says is necessary, then by that organization's own standard, the compatibility process cannot function as it should.
From the hunting side, Land Tawney, co-chair of American Hunters and Anglers, voiced support for more access while also flagging the same operational concern others are raising. Tawney supported the effort to provide more hunting and fishing opportunities at refuges, noting that "national wildlife refuges are set up to make sure the wildlife have places to go, but they're also set up for other resources like recreation, which includes hunting, photography, bird watching," and that hunting and fishing support conservation funding through licenses and taxes. But Tawney was candid about the tension. He is concerned that federal staff cuts could get in the way of goals like more recreation on public lands, and also said efforts to expand oil and gas production could hinder wildlife and hunting at refuges like the Arctic National Wildlife Refuge in Alaska.
Sarah Rosa, the vice president of policy at the American Conservation Coalition, an organization started by young conservatives, backed the changes and said they better match state hunting rules, including harvest limits and seasons. Aligning federal refuge regulations more closely with state frameworks has long been a practical request from hunters, who often find themselves operating under two conflicting sets of rules at the same time and place.
A Former Agency Director Raises the Central Question
The large-scale expansion of hunting and angling opportunities on national wildlife refuges raises the question of whether the activities would disrupt the conservation value of the properties — a question that former USFWS director Steve Williams, who led the agency under President George W. Bush, has been asking as the Interior has implemented Secretary's Order 3447. Williams is a Republican-appointed official with no ideological motivation to oppose the current administration's general direction on public land access. His concern is purely operational. Williams is mainly concerned that, with $4 billion in cuts to Interior agency staff and budgets in the One Big Beautiful Bill, refuge administrators will struggle to adequately balance conservation and wildlife management with increased recreational opportunities.
That concern — coming from a former Bush-era agency head — carries a different weight than criticism from environmental advocacy groups. Williams understands how refuges are actually managed from the inside. His worry is not that hunting shouldn't happen on refuges. It's that a system stripped of its operational capacity cannot responsibly administer a dramatic increase in human activity, regardless of how that activity is characterized politically.
The Historical Baseline: How We Got Here
Since the first national wildlife refuge was created in Florida in 1903, the National Wildlife Refuge System has been expanded to protect millions of acres of land and water across the nation, now providing homes to animals from hundreds of species, including those who are endangered and threatened, while drawing millions of visitors each year. Hunting has been part of the refuge system for most of that history. National wildlife refuges have long welcomed Americans to enjoy the outdoors through compatible wildlife-dependent recreation, including hunting and fishing. These traditions support local communities, strengthen our shared conservation ethic, and help people experience the wildlife and wild places that make the National Wildlife Refuge System so special.
The annual station-specific rulemaking process is not new — it has happened every year across administrations of both parties. Every administration has announced incremental expansions of hunting and fishing on national wildlife refuges, but none has achieved the acreages and number of properties in this month's announcement, just as no previous administration has declared that refuges are considered to be open to hunting and angling unless specifically closed. That last shift — from a default of closed unless opened, to a default of open unless specifically closed — is arguably the most consequential philosophical change embedded in the current rule, even if it draws less attention than the raw numbers.
What Hunters and Anglers Should Actually Watch
The public shouldn't read the proposal as a blanket opening. It remains station-specific, and refuges can still set rules on species, seasons, bag limits, methods of take, access areas, permits, boats, stands, blinds, and other local restrictions. That is an important practical reality for anyone planning their next season around newly opened refuge land. What the rule creates is opportunity; what local managers choose to do with that authority — assuming they have the staff to implement anything — will vary widely by location and species.
Federal law recognizes hunting and fishing as priority wildlife-dependent recreation on refuges when those uses are compatible with each refuge's purpose. That compatibility requirement keeps the proposal from being a blanket opening. Each refuge still has to manage hunting and fishing around wildlife, habitat, public safety, and the purpose of that specific station. In practice, that means hunters should expect substantial variation in what the rule means on the ground — a newly opened waterfowl unit at one refuge might have rigorous access protocols, while a refuge with zero on-site staff might have no mechanism to enforce anything at all.
The tension at the heart of the Hunt-Fish Rule is not really about whether Americans should be able to hunt and fish on their public lands. They should, and in many places, more of them should be able to. The real argument is about sequence and honesty: whether it makes sense — for wildlife, for the long-term quality of the hunting and fishing experiences themselves, and for the ecological integrity of the refuge network — to dramatically expand use while simultaneously accepting the gutting of the institutional capacity required to manage that use responsibly. The hunting and fishing traditions that Interior Secretary Burgum invokes as justification for this rule have survived and thrived precisely because previous generations made sure the underlying resource — the wildlife, the habitat, the functioning ecosystem — was protected first. Whether this rule does the same is a question the agency's own documents suggest it cannot yet answer.
