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.

The Alabama Wildlife and Freshwater Fisheries Division opposes the proposed fixed three-year publication cycle for the Migratory Game Bird Hunting Memorandum, arguing that it undermines adaptive management based on annual biological data. They also express concern over the lack of state and Flyway Council involvement in developing the new process and request more clarity on implementation guidance.

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, he urges the agency to remove the proposed 3-year constraint, arguing that annual adjustments are necessary for adaptive management and that a fixed cycle could interfere with existing regulatory cycles and state/tribal authority.

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 state-federal partnerships, lack sufficient consultation with 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 sustainable hunting.

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 supporting NEPA assessment, is inconsistent with existing harvest strategies and NEPA documents, and may hinder the ability of states and tribes to respond timely to biological data.

The Idaho Department of Fish and Game supports the proposed process for authorizing seasonal migratory game bird hunting seasons but opposes the specific 3-year constraint on that process. They argue that the constraint is inconsistent with existing harvest strategies, NEPA compliance documents, and the need for annual public comment, suggesting instead an annual publication of federal limits.

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.