04/08/2026
A recent Wisconsin Natural Resources Board rule proposal has opened up the question of whether or not "open water hunting" should be allowed on all Wisconsin waterbodies. Current hunting regulations provide that waterfowl hunters must be partially concealed and close to shore. The proposed rule will eliminate the concealment requirement and change in a dramatic way the use of important natural resources: waterfowl (ducks, geese) and the Wisconsin lakes, rivers, and streams they use in their annual migration.
Our organization opposes the rule change, most notably for the impact it will have on migratory birds that rely on Wisconsin's lake and wetlands to rest and recover during their annual southern migration. The process for this rule change is being done in a silent way, but the rule has huge potential impacts for Wisconsin riparian landowners, hunters, and waterfowl alike.
For questions about the rule change and how you can oppose it contact: Linn Duesterbeck, LKWA Secretary - 608-290-4692
You can register to speak at the April 15 NRB meeting, and can still do so today using the information below:
For NRB-related questions, information requests, written comment submittal, or registration to speak at an NRB meeting or listening session, please contact:
NRB Liaison
tel:+1-608-267-7420
PO Box 7921
Madison, WI 53707-7921
Unless otherwise noted, all Madison meetings are held at:
Rm. G09, State Natural Resources Bldg. (GEF 2)
101 S. Webster St.
Madison WI 53703
Enter the building at the 101 S. Webster St. entrance and take the hallway to the right to the reception desk.
BELOW IS THE LKWA's letter OPPOSING the rule change outlining reasons for opposing the rule:
Lake Koshkonong Wetland Association Letter to the WDNR Opposing the rule change:
March 5, 2026
To: Wisconsin Department of Natural Resources and the WDNR Citizens Board
RE: Proposed Elimination of the 3’ concealment regulation that would allow open water hunting on
inland lakes
To Whom this may concern,
The Lake Koshkonong Wetland Association is an organization with over 75 members, both hunters and non-hunters. The group is devoted to the protection and preservation of the wetlands and resources of Lake Koshkonong in Southern Wisconsin. The group was formed in 2003, and proudly participated in many conservation initiatives and education efforts to improve the environment of the wetlands of the lake and its surrounding wetlands including: successful efforts to greatly reduce purple loosestrife, a large nest box effort to support wood ducks, mallards, and other wetland birds, representing ecological interests in water-level litigation, financial support of Koshkonong’s fishery through donations to the
Bark River Fish Hatchery, numerous educational programs over the span of twenty years on topics ranging from conservation to natural history, and most recently the LKWA has financially supported habitat restoration efforts through the WDNR’s “Adopt a Fen” program to restore an important fen located in the Koshkonong Wildlife Area. Additionally, our group has repeatedly opposed open water hunting proposals over the years.
Our organization learned on February 20, 2026, with just ten days notice before public hearings on this issue, that there is a proposal by the Wisconsin Wildlife Federation, Wisconsin Waterfowl Association and the Wisconsin Conservation Congress to abolish the current 3’ concealment rule that would allow for open water hunting on all inland lakes. Our association has previously voiced its opposition to proposals such as this one, and once more we
dissent from this current open water hunting proposal, which affects the resources of our wetlands and beneficial use of the resource for hunters and non-hunters alike for the following reasons:
1) Open water hunting is detrimental to the resource. Studies show that motor-boat disturbances
will cause waterfowl to shift out of flyway areas
2) Open water hunting reduces or eliminates viewing areas for waterfowl in non-refuge lake areas
used by bird watchers.
3) The proposal creates tension between private property owners (hunters) against public open
water users.
4) The proposal opens duck hunting to large public lake areas displaying hunting in an adverse way.
5) Enforcement of the new rule will cause more enforcement issues for an already stressed DNR
staff.
6) The argument that open water hunting is allowed in surrounding states is not correct.
Minnesota does not allow it, while Illinois and Iowa have very few lakes and are not appropriate
points of comparison.
7) The proposal is incompatible with other recreational uses such as boating, fishing and bird
watching.
8) The proposal only provides only satisfaction to a small special interest group, open water
hunters.
9) The proposal may deter owner enhancement of wetland areas that are motivated by improving
waterfowl habitat.
10) The proposal is likely to diminish the participation overall of hunters. Some studies show that
competitive experiences reduce hunter participation in the activity.
11) Open water hunting increases pressure on waterfowl and reduces the migration flyway.
12) It is our group’s shared experience that the 3’ rule has already impacted the waterfowl that are resting on the lake. This is chiefly due to the large number of mud motors which now swarm the
resource every hunting season. The open water hunting proposal will only add more boat traffic to an already stressed resource which is important not only for ducks but various other
waterfowl such as loons, grebes, tundra swans, and trumpeter swans.
Our group is concerned that the open water hunting proposal lacks the support of scientific evidence, and we offer the following studies in rebuttal to the proposal in opposition to the proposal.
https://www.ducks.org/conservation/waterfowl-research-science/understanding-waterfowl-the-
science-of-disturbance
https://www.nalms.org/wp-content/uploads/2017/10/37-3-8.pdf
https://www.yourwetlands.org/pdf/A%20Review%20of%20Human%20Disturbance%20Impacts%20on%
20Waterbirds.pdf
https://www.jstor.org/stable/3782512
We are also aware of recent similar studies which will be obtaining from other conservation organizations such as Delta Waterfowl which will reinforce our opposition. In summary, we ask that you support the continuation of the current 3’ concealment rule and not allow further expansion of open water hunting in Wisconsin.
If you should have any further questions regarding this matter, please feel free to contact us at the following email address: [email protected], [email protected]
Sincerely,
Justin Shultz, LKWA Chairman
Linn Duesterbeck, LKWA Secretary
Rich Kahl, Boating Disturbance of Canvasbacks during Migration at Lake Poygan, Wisconsin, Wildlife Society Bulletin (1973-2006), Vol. 19, No. 3 (Autumn, 1991), pp. 242-248
