The Michigan Department of Natural Resources opposes the proposed Direct Final 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 preserve regular collaboration through the Service Regulations Committee and reconsider the proposed publication schedule.

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 a three-year cycle reduces regulatory flexibility, may not deliver intended administrative relief, and could negatively impact wildlife conservation and hunting opportunities.