The Michigan Department of Natural Resources opposes the proposed rule because it lacks sufficient collaboration with Flyway Councils and introduces a fixed three-year publication cycle that disrupts established annual management cycles. They request that the Service reconsider the publication cycle, maintain regular collaboration through the Service Regulations Committee, and treat Flyway Councils as full partners in the regulatory process.

The Arizona Game and Fish Department opposes the proposed shift from an annual to a three-year cycle for authorizing seasonal migratory game bird hunting. They argue that the three-year cycle lacks demonstrated benefits, may hinder timely wildlife management and hunter opportunities, and could create regulatory friction or confusion.

The Alabama Wildlife and Freshwater Fisheries Division supports the proposed memorandum-based process for migratory bird hunting regulations but requests the removal of the fixed three-year publication cycle. They argue that annual biological data and flyway recommendations are essential for adaptive management and advocate for maintaining collaborative communication between the Service, States, and Flyway Councils.

The Maryland Department of Natural Resources opposes the proposed direct-to-final rule, specifically objecting to the shift to a three-year memo process for waterfowl management. They argue that this change removes a permanent federal regulatory anchor, creates administrative burdens for the state, and lacks sufficient consultation with state and Flyway Council partners.

Ken McDonald of Montana Fish, Wildlife and Parks supports the U.S. Fish and Wildlife Service's proposal to streamline the notice and memorandum process for migratory game bird hunting frameworks. However, the agency strongly urges the removal of the proposed 3-year constraint, arguing that annual adjustments are necessary for science-based management and to maintain transparency with the public and tribal partners.

The Indiana Department of Natural Resources opposes the proposed and direct final rules establishing a memorandum-based process for migratory bird hunting regulations. They argue that the rules represent a significant departure from established processes, lack sufficient consultation with states and Flyway Councils, and introduce problematic elements like a fixed three-year publication cycle and reduced Service Regulations Committee meetings.

The California Waterfowl Association supports the proposed move to a notice-and-memorandum process for establishing federal migratory bird hunting frameworks to improve efficiency. However, they oppose the proposed three-year constraint on establishing these frameworks, arguing that annual reviews based on current biological data are essential for effective conservation and hunting management.

The Oregon Department of Fish and Wildlife supports the proposed new process for authorizing seasonal migratory game bird hunting but opposes the specific 3-year constraint on the federal notice and policy memorandum process. They argue the constraint lacks a technical assessment, is inconsistent with existing NEPA documents and harvest strategies, and may reduce hunting opportunities and state/tribal authority.

The Idaho Department of Fish and Game supports the proposed process for authorizing seasonal migratory game bird hunting seasons but opposes the inclusion of a 3-year constraint. They argue that the constraint is inconsistent with current harvest strategies, NEPA compliance documents, and the need for annual public comment.

The commenter opposes the proposed fixed 3-year cycle, arguing that it creates confusion and is out of place in the proposal. They express concern that this last-minute insertion erodes the trust and cooperative process between the States and the Federal government.