ECONOMIC ANALYSIS OF THE MIGRATORY BIRD HUNTING REGULATIONS FOR THE 2021-2022 SEASON - Prepared by: Economics Branch Policy, Economics, Risk ...

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ECONOMIC ANALYSIS OF THE MIGRATORY BIRD
HUNTING REGULATIONS FOR THE 2021-2022 SEASON

                          Prepared by:
                        Economics Branch
  Policy, Economics, Risk Management, and Analytics (PERMA)
                  U.S. Fish & Wildlife Service
                          August 2020
Contents
Economic Analysis ......................................................................................................................... 3
Initial Regulatory Flexibility Analysis ......................................................................................... 10
References ..................................................................................................................................... 28
Appendix A ................................................................................................................................... 29
Economic Analysis

Economic Background and Significance

The purpose of this economic analysis is to determine the economic effects of Federal
regulatory alternatives for the 2021-2022 hunting season for migratory birds. This
analysis centers on changing daily bag limits and season lengths, the two most important
policy variables in the Federal framework. The analysis will show that differences in
those key variables between alternatives result in measurable changes in the number of
hunters, how often they hunt, and the amount of consumer surplus they enjoy as well as
the amount of money they spend in pursuit of their sport. There are two components to
this analysis: first, each of the regulatory alternatives will be evaluated for their effects on
consumer surplus and second, each alternative will be evaluated for their effects on
hunter expenditures. The results of this analysis will document the expected economic
effects of the final framework for the 2021-2022 Fall migratory bird hunting season.

Over harvesting at the turn of the century resulted in depleted bird populations and
inspired the Migratory Bird Treaties between the United States, Great Britain (Canada),
Mexico, Japan, and the Soviet Union. The Migratory Bird Treaty Act (Act) implementing
the treaties authorizes the Secretary of the Interior to establish national frameworks
within which States may establish migratory bird hunting regulations. The status of
migratory bird populations are discussed in a series of annual reports. Environmental
considerations are covered under a separate Finding of No Significant Impact (FONSI).
These reports and more information about Adaptive Harvest Management are available at
http://www.fws.gov/migratorybirds/NewsPublicationsReports.html.

The Act is permissive. Without the national frameworks, the States cannot establish
hunting seasons and hunting is prohibited. The national framework indirectly regulates
migratory bird hunting in the United States by setting maximums for season length and
bag limits under which the States can set their own hunting regulations. The States can be
more restrictive than the Federal framework but not more lenient, i.e., the States can set
shorter seasons and/or lower bag limits.

Government policies generate economic effects by changing the use of resources in the
economy. Alternative resource allocations may increase the efficiency of the national
economy and generate greater welfare for its citizens, or policies may redistribute
resources from one region or industry to another. The former are national economic
effects. The latter are regional economic effects. By permitting hunting, the migratory
bird hunting framework regulations generate both types of effects.

                                               3
Approximately 1.5 million people bought duck stamps in 2017 1 (U.S. Fish and Wildlife
Service 2018). In addition to State hunting licenses, duck stamps are necessary to hunt
ducks or geese in the United States. This analysis estimates the economic effects of
regulatory alternatives on duck hunting – a major component of all migratory bird
hunting. Sufficient data exists for duck hunting to generate an analysis of hunter behavior
in response to regulatory alternatives. The analysis for all migratory bird hunting is not
possible because of data limitations but can be inferred from the results of the duck
hunting analysis presented here. Duck hunters represented approximately 51 percent of
all migratory bird hunters in 2016, or 57% of the number of days hunting (2016 National
Survey).

Evidently, hunters derive more pleasure from duck hunting than from their next most
preferred option for spending that time and money. The increment in their welfare versus
the next most preferred activity and the increment in producer surplus versus the next
most productive use of the resources are the national welfare benefits of duck hunting.
The Office of Information and Regulatory Affairs (OIRA) in the Office of Management
and Budget (OMB) has determined that the migratory bird hunting frameworks
rulemaking constitutes an economically significant rule, under the definition of Executive
Order 12866.

Effects of Allowing Migratory Bird Hunting

The Service calculates annually the biological impacts of each regulatory alternative as
part of the regulation development process and in consultation with the four Flyway
Councils. This annual assessment process occurs when the Service obtains current year
duck population status information and the updated expected harvest information for each
alternative in August. The results from this assessment are considered each year at the
Flyway Council meetings and Service Regulations Committee meetings, and results are
provided for public review in the subsequent hunting season frameworks proposed rule.

These expected harvests and population level impacts under each alternative are
evaluated annually and part of the formal decision making process. The optimal
regulatory alternative is derived each year based on current population status, expected
harvest under each alternative, and the population and harvest management objectives
adopted by the four Flyway Councils and the Service. The annual Environmental
Assessment of the migratory bird hunting regulations provides detailed descriptions of
three alternative frameworks for the annual duck hunting season:

       Alternative 1. Issue restrictive regulations allowing fewer days than those issued
                       during the 2020-2021 season.

       Alternative 2. Issue moderate regulations allowing more days than those in
                       Alternative 1.

1
 Stamp sale data is scheduled to be updated by the U.S. Fish & Wildlife Service after
January 2021.

                                             4
Alternative 3. Issue liberal regulations identical to the regulations in the 2020-
                       2021 season.

The Service proposes to issue liberal migratory bird hunting regulations in 2021-2022
(Preferred Alternative 3). This alternative is consistent with the objectives for long-term
sustained duck population levels and harvest objectives. A final determination of which
alternative to promulgate will be made when the analysis of the bird population status,
due to be completed in the summer of 2021, is available.

Economic Model

An economic model of duck hunting was developed to estimate changes in annual duck
hunting days, changes in expenditures, and changes in consumer surplus for each
Alternative (Appendix A). The underlying model utilizes data on the number of duck
hunters, number of duck hunter days, and duck harvest by flyway. The model uses data
from the Migratory bird hunting activity and harvest during the 2017-18 and 2018-19
hunting seasons and the 2011 and 2016 National Surveys of Fishing, Hunting and
Wildlife Associated Recreation. The model will be updated once new data are available
from the next iteration of the National Survey of Fishing, Hunting, and Wildlife
Associated Recreation, scheduled to take place in 2022. Current economic effects were
determined by comparisons with the most restrictive Federal framework under
Alternative 1, i.e. the minimum migratory bird hunting permitted. Alternatives 2 and 3
increase season length and permitted harvest which result in an increase in consumer
surplus when compared to the baseline (Alternative 1). The estimated economic benefits
resulting from the preferred alternative (Alternative 3) are the maximum achievable with
the proposed framework.

Estimating Consumer Surplus 2

Estimates of individual’s willingness to pay for duck hunting provides some insight into
the consumer surplus derived from this activity. Willingness to pay for migratory
waterfowl hunting (which includes both ducks and geese) averaged $81 per day (2018$)
(Walsh, Johnson, and McKean 1990). This is the average of 17 estimates the authors
found in the research literature. In order to account for regional differences in consumer
surplus estimates, data for estimating consumer surplus of waterfowl hunting by flyway
are needed. The most recent flyway estimates in the existing literature has only one study
where sufficient data were collected to derive consumer surplus estimates by flyway. Hay
(1988) is the only study found that estimated values for each of the four flyways. Average
consumer surplus estimates are required to evaluate the alternative duck hunting
frameworks, which are specified by flyway. In this report, the consumer surplus is
presented as a range taken from the Hay (1988) study. To date, this is the most recent
study that estimated consumer surplus by flyway. The daily consumer surplus estimates

2
 “Consumers’ surplus is the difference between what a consumer pays for a unit of a good or
service and the maximum amount the consumer would be willing to pay for that unit” (U.S.
Office of Management and Budget 2003).

                                               5
are used to determine the economic value of the baseline (restrictive migratory bird
hunting regulations) and the estimated effects of changes brought about by different
frameworks. The estimates from the Hay (1988) study provided the 95 percent
confidence intervals for flyway consumer surplus per day used in this analysis. The
estimates range from $43 to $69 (2018$) per hunting day. This range of estimates used is
more conservative than the Walsh, Johnson, and McKean findings from the literature.

Estimating Producer Surplus 3

The estimation of producer surplus is the missing value for a complete analysis of the
economic benefits generated by the migratory bird framework. Producer surplus is more
difficult to quantify in the case of a natural resource. There may be some producer
surplus associated with land leases for access to waterfowl hunting as well as habitat
leases to provide primary constituent elements needed to allow waterfowl to reproduce.
Any producer surplus associated with the sale of equipment and services to hunters is not
easily estimated since the data on profit margins for all these items are not known. Also,
the large numbers of suppliers of services and equipment would tend to eliminate excess
profits through competition. Since most of the services and equipment have non-duck
hunting applications, producers cannot set a price that discriminates between duck
hunters, who would presumably be willing to pay more, and other customers. Therefore,
they could not extract excess profits from duck hunters. Data to estimate producer surplus
are not available. Given competitive markets and the inability to price discriminate,
producer surplus is probably minimal compared to consumer surplus.

Consumer Surplus Effects of Alternative Frameworks

Using the economic model described in Appendix A, duck hunting days are estimated for
each Alternative. Table 1 shows the estimated consumer surplus from duck hunting by
Alternative and by flyway. Total consumer surplus ranges from $265 million for the
restrictive framework (Alternative 1) to $305 million for the preferred framework
(Alternative 3).

3
 “Producers’ surplus is the difference between the amount a producer is paid for a unit of a good
or service and the minimum amount the producer would accept to supply that unit.” (U.S. Office
of Management and Budget 2003).

                                                6
Table 1. Estimated Total Consumer Surplus for Alternative Frameworks (thousand
2018$).

                   Consumer
                    Surplus
                    Per Day        Alternative 1       Alternative 2        Alternative 3
  Flyway            (2018$)         Restrictive         Moderate             Preferred
  Atlantic          $43 - $62          $37,000             $42,100              $47,800
  Mississippi       $50 - $64         $131,900            $138,300             $145,400
  Central           $48 - $60          $43,600             $46,800              $49,300
  Pacific            $50- $69          $52,100             $57,400              $62,500
  Total                               $264,600            $284,600             $305,000

Alternative 1 This alternative includes restrictive regulations allowing fewer days than
              those issued in 2020-2021. Bag limits are 3 ducks below the 2020 levels
              and seasons are 30 to 47 days shorter. The reduced bag limit reduces the
              probability of hunting about 1.5 percent resulting in 138,000 fewer
              hunters. Total hunting days would be approximately 723,000 fewer days.
              Taken together the restrictive framework results in an estimated $265
              million (2018$) in duck hunter consumer surplus.

Alternative 2 Bag limits under this alternative are the same as under the preferred
              alternative (Alternative 3) but season lengths are 14 to 21 days shorter.
              Duck hunters would spend fewer days afield. The reduced season length
              decreases the probability of hunting resulting in 65,000 fewer hunters.
              Estimated consumer surplus would be $285 million (2018$).

Alternative 3 The preferred regulations are similar to the 2020-2021 regulations and
              have the most positive economic effect when compared to Alternative 1.
              The estimated consumer surplus ranges from $263 to $347 million with a
              mid-point estimate of $305 million. The bag limits and season lengths
              results in an estimated 910,000 duck hunters. This alternative is the
              preferred alternative and maximizes the total hunters’ welfare benefits
              which are related to bag and days afield.

The net effect of alternative frameworks results in relatively modest increases in
consumer surplus primarily reflecting the fact that the frameworks are not severely
binding on duck hunters decisions on how many days to hunt (Table 1). The differences
between season length, days afield, and bag limits and actual harvest are large enough
that only marginal changes in hunter behavior are expected from alternative frameworks.
The season length and bag limits set in the National framework, for example 90 days of
hunting and 5 as a bag limit per day, are significantly higher than the typical hunter uses.
Typically, hunters hunt for 9 days and bag slightly more than 2 ducks per day. Thus, any

                                             7
changes in the National framework are expected to have only a small impact on hunter
behavior (days afield and hunter bag) and migratory bird populations.

Duck hunting accounted for approximately 51 percent of all migratory bird hunting days
in 2016. This analysis of duck hunting benefits, if extrapolated to all migratory bird
hunting, would be 2 times higher than the duck hunting estimate discussed above. There
is no data to support the extrapolation so it is not performed.

The frameworks safeguard the efficient use of the resource over time by imposing limits
on its exploitation. Overexploitation when access to the resource was unconstrained
threatened its sustainability. Limiting resource consumption ensures future hunting
opportunities and the resulting ongoing benefits to hunters.

The frameworks have little direct effect on other agencies’ actions nor any material
budgetary impact. As the framework procedure has been in place for over 20 years, no
novel legal or policy issues are raised by these regulations.

Effects on Migratory Bird Populations

As noted above, the frameworks do not severely dictate duck hunter’ choices on how
many days to hunt since participation trends have been relatively flat since 1991.
Furthermore, the season length and bag limits set in the National framework, for example
90 days of hunting and 5 as a bag limit per day, are significantly higher than the typical
hunter trends of 9 days of hunting and about 2 birds per day. Thus, the differences
between the three Alternatives are expected to have only small impacts on hunter
behavior (days afield and hunter bag) and, consequently, migratory bird populations. As
a result, when comparing the preferred alternative to the most restrictive alternative, the
preferred alternative would have minimal impacts on migratory birds and the various
ecosystem services (such as birdwatching, pest control, disease regulation, and nutrient
cycling) that they provide.

Costs Incurred by States

The framework regulations for migratory bird hunting impose some costs of
administration and enforcement on the States. If there were no migratory bird hunting,
the States could apply their resources to different ends. As the States also derive revenue
from licenses and sales taxes on hunting supplies, the net effect on State resources is
uncertain.

                                             8
If States were free to set hunting seasons and bag limits (abrogating the Migratory Bird
Treaty Act), some might opt for longer seasons and higher bag limits without regard to
the health of the waterfowl populations. To the extent the frameworks constrain the
regulatory regime these States may impose, the framework imposes an opportunity cost
on the States. The opportunity cost is the lost revenue and hunter expenditures the State
cannot recover because it is constrained by the framework in its hunting regulations.
There is no way to quantify this cost. In particular, the long run impact of over harvesting
the population would be difficult to estimate and value.

                                             9
Initial Regulatory Flexibility Analysis

Background

The Regulatory Flexibility Act of 1980 (Public Law 96-354) requires agencies to
evaluate the potential effects of their proposed and final rules on small businesses, small
organizations, and small governmental jurisdictions.

Section 603 of the Act requires agencies to prepare and make available for public
comment a regulatory flexibility analysis (RFA) describing the impact of proposed rules
on small entities. Section 603(b) of the Act specifies the content of a RFA. Each RFA
must contain:

      A description of the reasons why action by the agency is being considered;
      A succinct statement of the objectives of, and legal basis for, the proposed rule;
      A description – and, where feasible, an estimate of the number – of small entities
       to which the proposed rule will apply;
      A description of the projected reporting, record keeping, and other compliance
       requirements of the proposed rule including an estimate of the classes of small
       entities which will be the subject to the requirement and the type of professional
       skills necessary for preparation of the report or record; and
      An identification, to the extent practicable, of all relevant Federal rules that may
       duplicate, overlap, or conflict with the proposed rule.

1. Description of the reasons why action by the agency is being considered

Over harvesting at the turn of the century resulted in depleted bird populations and
inspired the Migratory Bird Treaties between the United States, Great Britain (Canada),
Mexico, Japan, and the Soviet Union. The Migratory Bird Treaty Act (Act) implementing
the treaties authorizes the Secretary of the Interior to establish national frameworks
within which States may establish migratory bird hunting regulations.

The Act is permissive. Without the national frameworks, the States cannot establish
hunting seasons and hunting is prohibited. The proposed regulation indirectly regulates
migratory bird hunting in the United States by setting maximums for season length and
bag limits under which the States can set their own hunting regulations. The States can be
more restrictive than the Federal framework but not more lenient, i.e., the States can set
shorter seasons and/or lower bag limits.

2. Objectives of, and legal basis for, the proposed rule

The U.S. Fish and Wildlife Service (FWS or Service) is the Federal agency delegated the
primary responsibility for managing migratory birds. This delegation is authorized by the
Migratory Bird Treaty Act (MBTA, 16 U.S.C. 703 et seq.). We implement the provisions
of the MBTA through regulations in parts 10, 13, 20, 21, and 22 of title 50 of the Code of
Federal Regulations (CFR).

                                             10
Migratory game birds are those bird species so designated in conventions between the
United States and several foreign nations for the protection and management of these
birds. Under the Migratory Bird Treaty Act (16 U.S.C. 703–712), the Secretary of the
Interior is authorized to determine when “hunting, taking, capture, killing, possession,
sale, purchase, shipment, transportation, carriage, or export of any * * * bird, or any part,
nest, or egg” of migratory game birds can take place, and to adopt regulations for this
purpose. These regulations are written after giving due regard to “the zones of
temperature and to the distribution, abundance, economic value, breeding habits, and
times and lines of migratory flight of such birds” and are updated annually (16 U.S.C.
704(a)). This responsibility has been delegated to the Service as the lead Federal agency
for managing and conserving migratory birds in the United States. However, migratory
game bird management is a cooperative effort of State, Tribal, and Federal governments.

3. Description and estimate of the number of small entities to which the proposed rule
would apply

The underlying model utilizes data from the “Migratory bird hunting activity and harvest
during the 2017-18 hunting season” for the number of duck hunters, number of duck
hunter days, and duck harvest by flyway. Expenditure data are from the 2011 and 2016
National Survey of Fishing, Hunting and Wildlife Associated Recreation.

Major Categories of Hunter Expenditures

Waterfowl and other migratory bird hunting represent an important part of the total
economic activity generated by fishing and hunting in the United States. The 2016
National Survey of Fishing, Hunting and Wildlife Associated Recreation indicates that all
migratory bird hunter expenditures, exclusive of licenses, stamps, tags, permits, and
special equipment totaled over $2.1 billion in 2016 (2018$).

This analysis looks at duck hunting and the economic effects of regulatory alternatives on
that major component of migratory bird hunting. Expenditure data specific to duck
hunters are not directly available from the Survey. An estimate of duck hunter
expenditures was obtained by using the numbers of active duck hunters and hunter days
reported in the “Migratory bird hunting activity and harvest during the 2017-18 hunting
season” and the per capita and per day expenditure data reported in the 2011 and 2016
Surveys updated to 2018 dollars. Resulting duck hunter expenditures for travel and
equipment in the four flyways totaled $1.1 billion (2018$). Equipment and daily spending
were estimated for each flyway. Expenditure data are from the 2016 National Survey and
are weighted using flyway-level expenditure estimates calculated from the 2011 Survey.

Assuming that duck hunters distributed their spending among the Survey’s travel
expenditure categories in the same way as did other migratory bird hunters in 2016, duck
hunters spending would have been as follows:

                                             11
Table 2. 2016 Expenditures by Migratory Bird Hunters and Duck Hunters
                                              Expenditures (million 2018$)
 Category                     Percent      All MB Hunters1        Duck Hunters
 Equipment                         37%               $788.6              $398.5
 Food                              15%               $327.6              $165.5
 Transportation                    24%               $505.9              $255.7
 Lodging                           11%               $225.2              $113.8
 Other                             13%               $285.0              $144.0
 Total                         100.0%              $2,132.4             $1,077.5
Source: 2016 National Survey of National Survey of Fishing, Hunting, and Wildlife-Associated
1

Recreation

Migratory bird hunters spent $2.1 billion for guns, ammunition, travel, and recreational
services in 2016 (2018 $). These resources would have been spent on other activities if
migratory bird hunting had not been possible so they do not represent a change in
national economic efficiency or welfare. Nevertheless, this spending is important for the
industries and regions where the money is spent. If items like hunting camps, off-road
vehicles, and land are included, 2016 spending for migratory bird hunting increases
substantially.

Beneficiaries of the Rule

There were an estimated 1.2 million duck hunters in the U.S. in 2016 (U.S. Department
of the Interior 2016). In addition to hunters, a wide range of businesses and individuals
benefit economically from the establishment of the annual migratory bird hunting
regulations. A partial list of migratory bird hunter expenditure categories and the types of
businesses that benefit from those expenditures are shown in Table 3.

Migratory bird hunting regulations generate significant economic activity for small
businesses. Nationwide, migratory bird hunters spent $1.6 billion at small businesses in
2016 (Table 5). Over 800,000 small businesses will share in these sales. All but two of
the States with reported sales derive, as a minimum, an excess of $2 million in small
business sales from migratory bird hunting.

                                                  12
Table 3. Types of Expenditures by Migratory Bird Hunters
 Expenditure Item            Examples                    Beneficiaries
 Equipment and Supplies        Guns, ammunition, boats        Sporting goods stores,
                                                              department stores, boat
                                                              dealers

 Transportation                Gasoline, oil, repairs, air    Service stations, vehicle
                               travel, vehicles               dealers and rental
                                                              agencies

 Lodging                                                      Motels, campgrounds

 Food and Beverages                                           Restaurants, grocery
                                                              stores

 Lands and Leases              Club memberships, daily        Hunting clubs, private land
                               and seasonal hunting fees      owners

 Clothing                      Specialized clothing,          Retail clothing stores, mail
                               waders, boots                  order firms

Limited information is available on the number of businesses and individuals in the
various categories who benefit from duck hunter expenditures. This is not surprising
considering that those who provide equipment, supplies and services to duck hunters
often provide identical or similar items to non-hunters. For example:

1. A motel in a duck hunting area may obtain a portion of its income from duck hunters.
   Registrants are not requested to indicate the nature of their travel. The same situation
   prevails for food service establishments, gasoline stations, etc.

2. The number of sporting goods stores in the United States is obtainable. However,
   such stores may cater to fishermen, bowlers, skiers, joggers, etc., in addition to
   hunters. Without knowledge of their specialty, knowing the number of sporting goods
   stores is not sufficient.

3. Considerable leasing of lands for hunting and other purposes is accomplished
   informally without record keeping, and the payment is often in cash or otherwise
   undocumented.

Methods

This analysis combines information from the 2011 and 2016 National Surveys of Fishing,
Hunting, and Wildlife-Associated Recreation (Survey) and the U.S. Department of
Commerce County Business Patterns 2017 database to develop estimates of migratory
bird hunters’ expenditures at small businesses. The Survey provides excellent

                                            13
information about hunters and anglers expenditures for sporting trips and equipment. Trip
expenditures are categorized as food, lodging, transportation, and other travel items (e.g.,
guide fees, access fees, and rentals). Equipment expenditures include guns, ammunition,
and decoys. Expenditures for vehicles, cabins, and land are excluded from this analysis.
As very few respondents purchased these items, the data are considered unreliable.

The Surveys do not collect information about vendors. Therefore, another method is
necessary to find the proportion of total expenditures that can be attributed to small
businesses. The U.S. Department of Commerce publishes the County Business Patterns
database that includes the number of enterprises by county and North American Industrial
Classification System (NAICS). To assess the effects of the rule on small entities, this
analysis focuses on retail establishments. The U.S. Small Business Administration
(SBA) defines a small business as one with annual revenue or employment that meets or
is below an established size standard (Table 4).

Table 4. Small Business Size Standards
 Industry Code       Description                 Small Business Size Percentage of
                                                 Standard (millions) Businesses that
                                                                     are Small1
                      Full-Service                                        99%
 722511                                                  $8.0
                      Restaurants
                      Limited-Service                                          98%
  722513                                                 $12.0
                      Restaurants
                      Supermarkets and                                         98%
                      Other Grocery
  445110                                                 $35.0
                      (except Convenience)
                      Stores
                      Hotels (except Casino                                    99%
  721110                                                 $35.0
                      Hotels) and Motels
                      Gasoline Stations                                        98%
  447110              with Convenience                   $32.0
                      Stores
                      Other Gasoline                                           92%
  447190                                                 $16.5
                      Stations
                      Sporting Goods                                           99%
  451110                                                 $16.5
                      Stores
1
  US Census Bureau, 2017 Economic Census

The U.S. Census Bureau’s Economic Census provides national level data for the number
of firms by sales and industry type. Since the Economic Census does not provide state
level data for the number of firms by sales and industry type, the national estimate is
applied. As shown in Table 4, the majority of businesses qualify as small businesses.
The County Business Patterns information permits calculation of small business’ share of
businesses but not their share of sales. An alternative method was used to allocate sales to
small businesses from establishment information for each State. If all businesses sell
about the same amount, the share of expenditures spent at small businesses will be the

                                            14
proportion small businesses are to the total number of firms. This proportion probably
overstates small business’ share. A large discount department store probably sells more
guns and ammunition than a small neighborhood gun shop. Using this method generates
estimates of expenditures by migratory bird hunters at small businesses. To illustrate the
State level of benefits, the following tables have been developed based on the 2011 and
2016 National Surveys. The estimates are reported in Table 5 and are shown by State and
expenditure category.

Table 6, Estimated Migratory Bird Hunters’ Expenditures on Food, illustrates the
calculations for each of the expenditure categories shown on Tables 6 through 9. All
expenditures in this section are reported in thousands of 2018 dollars.
 The first column contains State totals of the amounts respondents to the Survey reported
they spent for food while on trips whose primary purpose was to hunt migratory birds.
Food may be bought at a full service restaurant (NAICS 722511), limited service
restaurant (NAICS 722513), or grocery store (NAICS 445110) so all types of firms were
combined. The second column shows the number of establishments in NAICS 72200 or
44510 in each State. The third column shows the number of establishments categorized as
small businesses in each State. The proportion small business establishments are of the
total is the method used to allocate expenditures to small businesses. This allocation is
shown in the fifth column.

Although more than 25,000 hunters and anglers were interviewed for the Survey, these
expenditure estimates are based on only those who actually hunted during 2011 and
stated that the primary purpose of their trip or equipment purchase was hunting migratory
birds – a sample of about 485 individuals. Only a small subset of hunters in each State
meets both criteria so the expenditures are quite sensitive to individual responses. Zero
totals may be based on small sample sizes. Small samples may also inflate expenditure
estimates. Lodging observations were sparse so state lodging estimates are spotty and
unreliable. A zero estimate for a state indicates a small sample size and no estimate was
attempted.

County business pattern information may also introduce errors. To avoid disclosure of
private information, the Census Bureau withholds employment information when there
are few establishments in a geographic area. Exclusion of a single large employer can
greatly affect the proportion attributed to small business. In addition, entry of enough
firms into an area results in all of the establishments appearing in the statistics. This
exacerbates the instability of the published series. No effort was made to compensate for
unreported firms in this analysis.

Surveys of a wide range of businesses would be required to obtain the necessary detailed
data. The Small Entity Analysis included in this section spreads expenditures across all
beneficiary businesses in proportion to the number of establishments.

The direct expenditures described above cycle through the economy generating additional
income and sales. Analysis of this multiplier effect is beyond the scope of this report but
clearly $2.1 billion is the minimum stimulus from the migratory bird regulations.

                                            15
Results

Migratory bird hunting generates considerable revenue for small businesses. In Arkansas,
California, and Minnesota, migratory bird hunting would be considered a significant
industry generating over $100 million in expenditures in each state. The multiplier effect
in each of these regions generates significantly more economic activity. Nationwide,
migratory bird hunters spent approximately $1.6 billion at thousands of small businesses
in 2016. Some of this economic activity would occur without the annual promulgation of
hunting regulations. Since much of the equipment and services used in migratory bird
hunting can be used for other purposes, some of the annual sales would continue even if
migratory bird hunting were prohibited. Much, if not all of this business activity would be
redirected to alternative pursuits.

4. Description of the projected reporting, record keeping, and other compliance
   requirements for small entities

The proposed rule would establish national frameworks within which States may
establish migratory bird hunting regulations. No reporting, record keeping, or other
compliance requirements are necessary.

5. Duplication with other Federal rules

There are no relevant Federal rules that may duplicate, overlap, or conflict with the
proposed rule.

6. Description of any significant alternatives to the proposed rule

Each alternative outlined in the economic analysis results in a different level of economic
stimulus generated from duck hunter spending. State expenditures for enforcement of
duck hunting regulations are not affected by any of the proposed alternatives. In each
case, the States would be required to field about the same enforcement effort. Only if the
frameworks greatly relaxed bag limits and seasons would the States be able to reduce
enforcement effort significantly. Alternatives 1 and 2 will reduce State license sales and
sales taxes on hunting goods compared to the preferred Alternative 3. These revenue
losses would be in addition to the lost stimulus of expenditures in local economies.

Although reduced hunting now may result in more ducks to hunt next year, higher
populations also increase the risk of disease outbreaks and unhealthy competition, in the
absence of adequate natural predation. The opportunity cost of duck hunting, ignoring
long run effects, is minimized by the preferred framework, Alternative 3.

QUESTIONS FOR COMMENT TO ASSIST REGULATORY FLEXIBILITY
ANALYSIS:

                                            16
1. Please provide comment on any or all of the frameworks in the proposed rule with
   regard to (a) the impact of the provision(s) (including any benefits and costs), if
   any, and (b) what alternatives, if any, the Service should consider, as well as the
   costs and benefits of those alternatives, paying specific attention to the effect of
   the rule on small entities in light of the above analysis.
2. Please describe ways in which the proposed rule could be modified to reduce any
   costs or burdens for small entities consistent with the Service’s requirements.
3. Please identify all relevant federal, state or local rules that may duplicate, overlap
   or conflict with the proposed rule.
4. Please provide consumer surplus data for migratory bird hunting by flyway.
5. Please provide information regarding change in sales and associated revenue due
   to the proposed rule.

                                         17
Table 5. Estimated Expenditures by Migratory Bird Hunters at Small Businesses – Summary
(Millions of 2018 dollars)
         State            Food          Lodging     Transportation     Equipment          Total
Alabama                           6.3          -                 0.1          5.8             12.2
Alaska                            0.5        0.2                 4.3          0.8               5.8
Arizona                           2.6        1.1               19.8          14.2             37.7
Arkansas                         17.3          -                 4.4        234.5            256.1
California                       30.9        7.8               44.7          58.2            141.6
Colorado                          1.4          -                 1.2          5.4               8.0
Connecticut                       2.3          -                 1.5         31.3             35.1
Delaware                          0.3          -                 0.2          4.2               4.7
Florida                           1.4          -               12.3           6.2             19.9
Georgia                           2.9        0.7                 3.0         39.6             46.3
Hawaii                              -          -                   -            -                 -
Idaho                             0.9          -                 0.9          1.3               3.1
Illinois                          3.4          -                 1.8         33.3             38.6
Indiana                           4.1          -               10.1           5.0             19.2
Iowa                              0.3          -                 3.1         14.5             17.9
Kansas                            1.6          -                 1.7          2.6               5.9
Kentucky                          2.2          -                 4.4         11.5             18.0
Louisiana                        14.3        0.1               20.4          42.9             77.7
Maine                             2.5          -                 3.7          0.7               6.9
Maryland                          0.9          -                 0.6          0.5               2.0
Massachusetts                     2.7        1.5                 5.3         11.9             21.4
Michigan                          5.5          -               12.3          66.6             84.4
Minnesota                        27.1          -               44.0          77.5            148.5
Mississippi                       4.5        3.5               26.2          14.3             48.5
Missouri                         11.4          -                 4.5         27.6             43.5
Montana                           5.1        0.3                 2.1         19.7             27.2
Nebraska                          1.8        0.5               22.0           1.5             25.8
Nevada                            1.3        0.9                 2.5          2.6               7.3
New Hampshire                     0.1        0.8                 3.4            -               4.2
New Jersey                        0.8          -                 1.5          4.2               6.4
New Mexico                        3.6          -                 1.0          5.9             10.5
New York                          0.2        0.4               10.1           0.1             10.9
North Carolina                   29.2        0.1               11.9           7.9             49.1
North Dakota                      1.0          -                 0.6          2.4               4.0
Ohio                              2.4       13.6                 4.6         16.5             37.1
Oklahoma                          1.3          -                 7.5          3.5             12.3
Oregon                            1.6        0.7                 2.3          0.1               4.6
Pennsylvania                      0.2          -                 3.0            -               3.2

                                          18
Table 5. Estimated Expenditures by Migratory Bird Hunters at Small Businesses – Summary
(Millions of 2018 dollars)
         State            Food          Lodging      Transportation     Equipment         Total
Rhode Island                      0.3            -                0.6          1.1             2.0
South Carolina                    1.5            -                1.5          7.1            10.0
South Dakota                      8.3          9.0              29.9           9.7            57.0
Tennessee                         4.3            -                5.2         11.2            20.7
Texas                            19.1            -              30.3          17.4            66.8
Utah                              2.4            -              12.3           9.0            23.7
Vermont                           0.2          1.4              18.6          17.7            37.9
Virginia                         20.2            -                0.3         14.3            34.7
Washington                        5.2          3.6                4.2          6.4            19.5
West Virginia                       -          0.3              12.0             -            12.3
Wisconsin                         5.4            -                0.1         23.3            28.8
Wyoming                           0.8            -                1.9          0.6             3.3
                 Total     $ 263.6          46.5             $ 419.9     $   892.6        $1,622.3

                                          19
Table 6. Estimated Migratory Bird Hunters' Expenditures on Food
(Expenditures in thousands of 2018 dollars)

State             Total MB Hunter      Total Number of   Number of Small   Estimated MB
                  Expenditures on     Firms              Businesses        Hunters'
                  Food                                                     Expenditures at
                                                                           Small Businesses

Alabama               $8,048                 9,105                 8,140         $7,195
Alaska                $1,719                 1,925                 1,806         $1,613
Arizona              $10,712                12,786                11,254         $9,429
Arkansas              $4,913                 5,673                 5,162         $4,470
California           $80,681                93,154                84,762        $73,413
Colorado             $11,497                13,409                12,078        $10,356
Connecticut           $8,380                 9,488                 8,804         $7,776
Delaware              $1,875                 2,226                 1,970         $1,659
Florida              $37,110                44,550                38,987        $32,476
Georgia              $18,749                22,138                19,697        $16,682
Hawaii                $3,353                 3,961                 3,523         $2,982
Idaho                 $3,215                 3,662                 3,378         $2,966
Illinois             $26,552                30,593                27,895        $24,210
Indiana              $11,478                13,537                12,059        $10,225
Iowa                  $6,168                 7,068                 6,480         $5,655
Kansas                $5,213                 6,100                 5,477         $4,681
Kentucky              $7,048                 8,368                 7,404         $6,236
Louisiana             $8,700                10,221                 9,140         $7,780
Maine                 $3,397                 3,831                 3,569         $3,165
Maryland             $11,263                13,296                11,833        $10,024
Massachusetts        $17,164                19,700                18,032        $15,711
Michigan             $18,508                21,416                19,444        $16,804
Minnesota            $10,037                11,730                10,545         $9,023
Mississippi           $4,703                 5,517                 4,941         $4,212
Missouri             $10,902                12,814                11,453         $9,744
Montana               $2,744                 3,090                 2,883         $2,560
Nebraska              $4,005                 4,555                 4,208         $3,700
Nevada                $5,771                 6,785                 6,063         $5,157
New Hampshire         $3,194                 3,642                 3,356         $2,943
New Jersey           $21,498                24,177                22,585        $20,082
New Mexico            $3,270                 3,908                 3,435         $2,874
New York             $57,851                64,352                60,777        $54,637
North Carolina       $18,370                21,945                19,299        $16,155
North Dakota          $1,633                 1,879                 1,716         $1,491

                                           20
Table 6. Estimated Migratory Bird Hunters' Expenditures on Food
(Expenditures in thousands of 2018 dollars)

State             Total MB Hunter      Total Number of   Number of Small   Estimated MB
                  Expenditures on     Firms              Businesses        Hunters'
                  Food                                                     Expenditures at
                                                                           Small Businesses

Ohio                 $22,169                25,907                23,290        $19,930
Oklahoma              $6,989                 8,085                 7,343         $6,348
Oregon               $10,775                11,972                11,320        $10,188
Pennsylvania         $26,595                30,679                27,940        $24,221
Rhode Island          $2,929                 3,275                 3,077         $2,752
South Carolina        $9,151                10,923                 9,614         $8,054
South Dakota          $1,853                 2,098                 1,947         $1,720
Tennessee            $11,260                13,319                11,829        $10,000
Texas                $48,135                57,299                50,569        $42,481
Utah                  $4,810                 5,637                 5,053         $4,312
Vermont               $1,659                 1,848                 1,743         $1,565
Virginia             $16,262                19,085                17,084        $14,557
Washington           $16,139                18,167                16,955        $15,062
West Virginia         $3,156                 3,640                 3,316         $2,875
Wisconsin            $12,618                14,440                13,256        $11,583
Wyoming               $1,281                 1,438                 1,346         $1,199

                                           21
Table 7. Estimated Migratory Bird Hunters' Expenditures on Lodging
(Expenditures in thousands of 2018 dollars)

State             Total MB Hunter       Total Number of     Number of Small   Estimated MB
                  Expenditures on      Firms                Businesses        Hunters'
                  Lodging                                                     Expenditures at
                                                                              Small Businesses

Alabama                       -                   853                  814               -
Alaska                      712                   284                  261           $654
Arizona                   4,464                   721                  694          $4,297
Arkansas                      -                 1,080                  932               -
California               31,226                 5,735                4,899         $26,674
Colorado                      -                 1,353                1,199               -
Connecticut                   -                   382                  326               -
Delaware                      -                   180                  164               -
Florida                       -                 3,388                2,791               -
Georgia                   2,970                 1,996                1,855          $2,760
Hawaii                        3                   293                  178              $2
Idaho                         -                   759                  713               -
Illinois                      -                   373                  351               -
Indiana                       -                 1,489                1,270               -
Iowa                          -                   991                  931               -
Kansas                        -                   607                  582               -
Kentucky                      -                   745                  707               -
Louisiana                   272                   909                  839           $251
Maine                         -                   778                  633               -
Maryland                      -                   700                  603               -
Massachusetts             5,914                   516                  484          $5,547
Michigan                      -                 1,343                1,225               -
Minnesota                     -                   931                  815               -
Mississippi              13,895                 1,074                  976         $12,627
Missouri                      -                   679                  657               -
Montana                   1,126                   530                  497          $1,056
Nebraska                  2,115                 1,801                1,661          $1,951
Nevada                    3,789                   318                  301          $3,586
New Hampshire             2,988                   456                  427          $2,798
New Jersey                    -                   332                  297               -
New Mexico                    -                 1,041                  934               -
New York                  1,618                   631                  582          $1,492
North Carolina              709                   457                  404           $627

                                           22
Table 7. Estimated Migratory Bird Hunters' Expenditures on Lodging
 (Expenditures in thousands of 2018 dollars)

 State               Total MB Hunter         Total Number of      Number of Small    Estimated MB
                     Expenditures on        Firms                 Businesses         Hunters'
                     Lodging                                                         Expenditures at
                                                                                     Small Businesses

 North Dakota                  194                  2,340                    1,965          $163
 Ohio                       55,006                  1,419                    1,302        $50,471
 Oklahoma                         -                   862                      820              -
 Oregon                      2,679                    967                      878         $2,432
 Pennsylvania                     -                 1,479                    1,309              -
 Rhode Island                  116                    140                      112            $93
 South Carolina                   -                 1,118                    1,001              -
 South Dakota               37,385                    439                      419        $35,682
 Tennessee                        -                 1,391                    1,286              -
 Texas                           67                 5,259                    4,882            $62
 Utah                             -                   612                      536              -
 Vermont                     5,746                  1,523                    1,349         $5,090
 Virginia                         -                   236                      203              -
 Washington                 14,207                  1,221                    1,081        $12,578
 West Virginia               1,201                  1,097                      995         $1,089
 Wisconsin                        -                   320                      300              -
 Wyoming                          -                   397                      365              -
Note: A hyphen (-) denotes that sample sizes are too small to report data.

                                                23
Table 8. Estimated Migratory Bird Hunters' Expenditures on Transportation
(Expenditures in thousands of 2018 dollars)

State              Total MB          Total Number of    Number of Small     Estimated MB
                   Hunter           Firms               Businesses          Hunters'
                   Expenditures                                             Expenditures at
                   on                                                       Small Businesses
                   Transportation
Alabama                  $169                3,217                  3,202              $168
Alaska                  $4,922                 182                    182             $4,922
Arizona               $22,929                1,529                  1,520            $22,794
Arkansas                $5,084               1,604                  1,584             $5,021
California            $51,776                7,488                  7,424            $51,333
Colorado                $1,364               1,555                  1,540             $1,351
Connecticut             $1,691               1,066                  1,062             $1,685
Delaware                 $275                  247                    246              $274
Florida               $14,118                6,336                  6,312            $14,065
Georgia                 $3,460               5,063                  5,038             $3,443
Hawaii                      $1                 244                    243                 $1
Idaho                   $1,079               1,745                  1,733             $1,072
Illinois                $2,071                 657                    652             $2,055
Indiana               $11,701                3,816                  3,787            $11,612
Iowa                    $3,621               2,737                  2,712             $3,588
Kansas                  $1,960               1,072                  1,056             $1,931
Kentucky                $5,065               2,024                  2,014             $5,040
Louisiana             $23,619                2,419                  2,399            $23,424
Maine                   $4,309               1,970                  1,968             $4,305
Maryland                 $725                1,480                  1,474              $722
Massachusetts           $6,089                 773                    772             $6,081
Michigan              $14,230                3,562                  3,547            $14,170
Minnesota             $50,850                2,134                  2,118            $50,469
Mississippi           $30,394                2,669                  2,636            $30,018
Missouri                $5,132               2,022                  2,016             $5,117
Montana                 $2,430                 505                    499             $2,401
Nebraska              $25,378                4,491                  4,475            $25,288
Nevada                  $2,904                 459                    449             $2,841
New Hampshire           $3,891                 968                    961             $3,863
New Jersey              $1,715                 563                    562             $1,712
New Mexico              $1,146               2,346                  2,263             $1,105
New York              $11,778                  837                    820            $11,539

                                           24
Table 8. Estimated Migratory Bird Hunters' Expenditures on Transportation
(Expenditures in thousands of 2018 dollars)

State              Total MB          Total Number of    Number of Small     Estimated MB
                   Hunter           Firms               Businesses          Hunters'
                   Expenditures                                             Expenditures at
                   on                                                       Small Businesses
                   Transportation
North Carolina        $13,894                  800                    784            $13,616
North Dakota             $649                4,974                  4,941              $645
Ohio                    $5,285               3,904                  3,871             $5,240
Oklahoma                $8,628               1,858                  1,849             $8,586
Oregon                  $2,683                 928                    914             $2,643
Pennsylvania            $3,465               3,943                  3,908             $3,434
Rhode Island             $654                  306                    306              $654
South Carolina          $1,739               2,609                  2,590             $1,726
South Dakota          $34,507                  617                    615            $34,395
Tennessee               $5,958               3,466                  3,444             $5,920
Texas                 $35,041               11,397                 11,300            $34,743
Utah                  $14,325                  746                    733            $14,075
Vermont               $21,496                3,107                  3,084            $21,337
Virginia                 $352                  416                    415              $351
Washington              $4,888               1,896                  1,885             $4,860
West Virginia         $13,865                2,575                  2,563            $13,800
Wisconsin                $141                  937                    927              $139
Wyoming                 $2,277                 323                    315             $2,221

                                           25
Table 9. Estimated Migratory Bird Hunters' Expenditures on Equipment
(Expenditures in thousands of 2018 dollars)

State                  Total MB Hunter     Total Number of     Number of Small   Estimated MB
                       Expenditures on     Firms               Businesses        Hunters'
                       Equipment                                                 Expenditures at
                                                                                 Small Businesses

Alabama                      $5,261                  248                 225           $4,773
Alaska                        $761                    77                  73            $721
Arizona                     $12,865                  440                 423          $12,368
Arkansas                   $212,165                  190                 177         $197,648
California                  $52,635                2,250               2,183          $51,068
Colorado                     $4,876                  780                 745           $4,657
Connecticut                 $28,359                  276                 267          $27,434
Delaware                     $3,804                   78                  74           $3,609
Florida                      $5,625                1,563               1,522           $5,477
Georgia                     $35,877                  494                 456          $33,117
Hawaii                            -                  121                 121                -
Idaho                        $1,138                  215                 205           $1,085
Illinois                    $30,170                  640                 605          $28,520
Indiana                      $4,548                  420                 402           $4,353
Iowa                        $13,107                  221                 210          $12,455
Kansas                       $2,345                  166                 152           $2,147
Kentucky                    $10,362                  266                 254           $9,895
Louisiana                   $38,856                  225                 202          $34,884
Maine                         $668                   151                 146            $646
Maryland                      $459                   291                 279            $440
Massachusetts               $10,806                  502                 481          $10,354
Michigan                    $60,306                  735                 713          $58,501
Minnesota                   $70,106                  512                 482          $65,998
Mississippi                 $12,901                  129                 120          $12,001
Missouri                    $24,989                  346                 326          $23,545
Montana                     $17,870                  195                 183          $16,770
Nebraska                     $1,378                  120                 111           $1,275
Nevada                       $2,378                  159                 153           $2,288
New Hampshire                     -                  195                 193                -
New Jersey                   $3,804                  510                 489           $3,647
New Mexico                   $5,352                  159                 156           $5,251
New York                      $129                 1,189               1,143            $124
North Carolina               $7,135                  676                 644           $6,797

                                          26
Table 9. Estimated Migratory Bird Hunters' Expenditures on Equipment
 (Expenditures in thousands of 2018 dollars)

 State                     Total MB Hunter      Total Number of       Number of Small   Estimated MB
                           Expenditures on      Firms                 Businesses        Hunters'
                           Equipment                                                    Expenditures at
                                                                                        Small Businesses

 North Dakota                    $2,137                     53                     48         $1,935
 Ohio                           $14,950                   674                    641         $14,218
 Oklahoma                        $3,210                   215                    199          $2,971
 Oregon                             $69                   435                    417             $66
 Pennsylvania                          -                  814                    766               -
 Rhode Island                    $1,005                     76                     76         $1,005
 South Carolina                  $6,386                   277                    257          $5,925
 South Dakota                    $8,815                     86                     82         $8,405
 Tennessee                      $10,159                   371                    351          $9,611
 Texas                          $15,744                 1,167                  1,017         $13,720
 Utah                            $8,102                   334                    321          $7,787
 Vermont                        $16,007                   121                    118         $15,610
 Virginia                       $12,895                   492                    465         $12,187
 Washington                      $5,796                   559                    534          $5,537
 West Virginia                         -                  116                    112               -
 Wisconsin                      $21,041                   476                    459         $20,290
 Wyoming                           $526                     92                     90          $515
Note: A hyphen (-) denotes that sample sizes are too small to report data reliably.

                                                27
References

Hay, Michael J. Net Economic Recreation Values for Deer, Elk and Waterfowl Hunting
      and Bass Fishing. Addendum to the 1985 National Survey of Fishing, Hunting,
      and Wildlife-Associated Recreation. U.S. Department of the Interior, Fish and
      Wildlife Service, Washington, D.C. July 1988.

Raftovich, R.V., K.K. Fleming, S. C. Chandler, and C.M. Cain, 2019. Migratory bird
        hunting activity and harvest during the 2017-18 and 2018-19 hunting seasons.
        U.S. Fish and Wildlife Service, Laurel, Maryland, USA.

U.S. Department of Commerce, Bureau of the Census. Economic Census. Washington,
       DC. 2017. Available from: https://factfinder.census.gov. Accessed July 2020.

U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of
       Commerce, Bureau of the Census. 2011 National Survey of Fishing, Hunting, and
       Wildlife-Associated Recreation. U.S. Government Printing Office, Washington,
       DC.

U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of
       Commerce, Bureau of the Census. 2016 National Survey of Fishing, Hunting, and
       Wildlife-Associated Recreation. U.S. Government Printing Office, Washington,
       DC.

U.S. Department of the Interior, Fish and Wildlife Service, Office of Migratory Bird
       Management. Administrative Report – July 2012, Preliminary estimates of
       waterfowl harvest and hunter activity in the United States during the 2010 and
       2011 hunting season. USFWS/OMBM: Laurel, MD. 2012.

U.S. Fish and Wildlife Service. 2007. Environmental Assessment. Duck Hunting
       Regulations for 2007. U.S. Department of the Interior, Washington, D.C., U.S.A.

U.S. Fish and Wildlife Service 2018. Federal Duck Stamp Sales by Year.
       https://www.fws.gov/migratorybirds/pdf/get-involved/DuckStampSales.pdf.
       Accessed May 2018

U.S. Office of Management and Budget. Circular A-4. September 30, 1993.
       https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/circulars/A4/a-4.pdf

Walsh, Richard G., Johnson, Donn M., and John R. McKean. What Can We Learn From
      20 Years Of Work With TCM And CVM. W-133 and Western Regional Science
      Assn., Annual Meeting, Molokai Hawaii, February 22, 1990.

                                           28
Appendix A

Introduction

The economic model was originally developed in the early 2000s to analyze duck hunter
behavior under different regulatory migratory bird hunting frameworks.. The underlying
model utilizes ratios on the number of duck hunters, number of duck hunter days, and
duck harvest by flyway. This model has been updated with the most current data
available: the 2011 and 2016 National Surveys of Fishing, Hunting and Wildlife-
Associated Recreation and the Migratory bird hunting activity and harvest during the
2017-18 and 2018-19 hunting seasons. The primary research interest of this analysis is
the tradeoff between season length and bag limit assuming a desired total harvest of
ducks. This is not the question these alternative frameworks pose. Each framework varies
both bag limit and season length in order to not over harvest the species. The present
analysis seeks to quantify these relationships and apply them to changes in both season
length and bag limit.

Because of the less stringent data requirements, the empirical approach employed for this
analysis is a reduced form of the random utility model bypassing the site decision
equation. The hunter’s decision is limited to two questions. First, does the hunter choose
to hunt ducks? Second, how many total days does the hunter choose to hunt ducks during
one hunting season? The methodology used to analyze the impacts of varying the season
length and/or bag limit is explained in the following text.

In any season, the total harvest of ducks (K) is the product of average bag per day per
hunter (B), average days afield per hunter per season (DAF), the probability that a hunter
will hunt ducks (PROB), and total hunters of all game (H):

       (1)     K = (B) (DAF) (PROB) H

The variables in the model and in the subsequent empirical analysis are defined in Table
8. The analysis was conducted under the assumption that total harvest, K, is set according
to annual biological considerations. To develop the parameters of the model it was
assumed that once K is determined, it remains constant under all alternative combinations
of daily bag and season length. Therefore in the model, any change in K, denoted as (dK),
is equated to zero.

This can be seen in the total differential of equation (1):

                          δK               δK                   δK
       (2)      dK = dB      + dDAF            + d(PROB)            =0
                          δB              δDAF                δPROB

The differential shows that the various components of dK can be allowed to vary as long
as the effects of their changes on K net out to zero. The components are the changes in
duck harvest that can be attributed to changes in bag per day (dB), days afield (dDAF),
and probability (dPROB). It is assumed that total number of hunters (H) remains

                                              29
constant. Measuring the compensating changes in these components is what ultimately
permits the determination of the tradeoffs between bag limit and season length. The
magnitude of the change in harvest caused by each of the components is the product of
the initial change in the component and the partial derivative of K with respect to the
component. For example, the effect on K of a change in daily bag (dB) is the product of
dB and the partial derivative of harvest with respect to daily bag (δK/δB). Thus, equation
(2) summarizes the nature of the tradeoffs between daily bag limits and season length in
setting the regulatory framework. It shows that any increase in daily bag (dB > 0) must be
offset by decreases in DAF and PROB such that total harvest remains the same (dK = 0).

Table 10. Definition of Variables
 Variable           Definition                           Unit of Measurement
 PROB               Probability of duck hunting,         1 = if hunts ducks
                    given that a person hunts            0 = otherwise
 DAF                Days afield per hunter per season    Days
 SL                 Season length                        Days
 BL                 Bag limit per hunter per day         Ducks
 B                  Actual daily harvest per hunter      Ducks
 K                  Duck harvest per season              Ducks
 H                  Number of hunters of all species     Participants
 DH                 Number of duck hunters               Participants
 HD                 Duck hunting days (DAF x DH)         Days
 AGE                Age of individual                    Years
 INC                Individual’s household income        Thousands of dollars
 Gender             Sex of individual                    1 = if male
                                                         0 = female
 METRO              Urban residence                      1 = if residence is in urban area
                                                         0 = otherwise
 BD05               2017 average daily harvest of        Ducks
                    ducks per hunter in individual’s
                    state of residence
 WH05               Square miles of waterfowl habitat    Square miles of wetlands per
                    in individual’s state of residence   square mile of total state area
                    in 2005
 AES                Average 2016 equipment               2018 Dollars
                    expenditures of duck hunters
 AVS                Average 2016 variable                2018 Dollars
                    expenditures per day for duck
                    hunting
 E                  Elasticity of season length with     Unitless Number
                    respect to days afield

                                           30
To measure those tradeoffs it is first necessary to express the components of (2) in other
terms. From equation (1), the partial derivatives of total harvest with respect to daily bag
(B), days afield (DAF), and probability (PROB) are:

                δK
       (2.1)       = DAF(PROB)H
                δB

                 δK
       (2.2)         = B(PROB)H
                δDAF

                  δK
       (2.3)          = B(DAF)H
                δPROB

Two equations were specified to incorporate hunter behavior into the model. It is
assumed that a hunter makes two decisions.

First, a hunter decides whether to hunt ducks. The decision to participate is binary; the
individual either hunts ducks (PROB=1) or he does not (PROB=0). The mean of PROB is
the proportion of hunters that hunts ducks, the participation rate.

As discussed in detail below, the decision to participate is influenced by a number of
factors. The probability that a given hunter will hunt ducks is a function of age, sex,
residence in a rural versus urban area, income, season length, and the amount of
waterfowl habitat and the bag per day per hunter in the individual’s home state. To
simplify the discussion, all factors influencing the decision to hunt ducks except bag per
day can be combined in the intercept (a), making the probability that an individual hunts
ducks a function of bag per day.

       (3)     PROB = a + bB

Second, after deciding to hunt ducks the hunter must decide how many days to hunt
during the season (DAF). The days afield decision is influenced by a number of the same
variables: income, availability of duck habitat, and bag per day. Once again, all factors
influencing DAF except bag per day can be summarized in the intercept ©.

       (4)     DAF = c + eB

Solving equation (4) for B and substituting into equation (3) yields:

                             b(DAF - c)
       (5)     PROB = a +
                                e

The derivative of (5) with respect to DAF is:

                dPROB b
       (6)            =
                 dDAF   e

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Substituting (6) and the partial derivatives (2.1, 2.2, and 2.3) into equation (2) and
solving for the change in DAF results in:

                           − dB(DAF)(PROB)H
       (7)      dDAF =
                                     b
                         B(PROB)H + B(DAF)H
                                     e

Equation (7) may be simplified by combining all factors on the right hand side except dB
into a constant, J. This makes the tradeoffs between changes in DAF and B apparent, in
equation (8).

                         (DAF)(PROB)H
       (7.1)    J=
                                b
                     B(PROB)H + B(DAF)H
                                e

       (8)     dDAF = -dB(J)

Note that B in the model is actual bag whereas the policy variable set in the regulations is
bag limit (BL), a maximum number of ducks per day attained by relatively few hunters.
The estimated relationship between changes in B and BL for each flyway is shown in
Table 10. When dBL is known, the corresponding dB is determined from those estimates.
The change in days afield (dDAF) for a given dB is derived from (8). With H and K
constant, the new probability (PROB) is then calculated by substituting the new levels of
DAF and B into equation (1). This keeps the duck hunters in the flyway on the isoquant
representing a constant total harvest (K) while allowing BL and SL to vary.

The change in SL consistent with the change in BL is determined programmatically. The
elasticity of SL with respect to DAF (the ratio of the percent change in SL to the percent
change in DAF):

                     dSL dDAF              dSL  DAF 
       (9)      E=                   =              
                     SL DAF                dDAF  SL 

Equation (9) shows how much DAF must change in response to the change in SL to
produce the required new level of BL. If BL is increased, SL must decrease if total
harvest is to be held constant.

After the new probability of duck hunting is determined, the difference (dPROB)
between it and the base probability is multiplied by the total number of hunters (H) to
obtain the change in the number of duck hunters (dDH). This model assumes that the new
hunters will spend the same amount on equipment as the average of previous duck
hunters (AES), the product of dDH and AES is the first part of the economic impact
(IMP1) caused by changing BL. The second part of the impact (IMP2) is the change in

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variable expenditures. It is the product of dHD, the change in hunter days due to the
change in BL, and average variable spending (AVS) per day.

       (10)    Impact = IMP1 + IMP2

       (10.1) IMP1 = dDH(AES), where:
                     dDH = (dPROB)(H)

       (10.2) IMP2 = (dHD)(AVS), where:
                     dHD = dDH(DAF + dDAF) + dDAF(DH)

Thus, the economic impacts are measured as changes from the base case in terms of
hunter equipment spending and spending for food, travel and lodging as the number of
duck hunters and days afield change in response to the regulatory alternatives.

Estimation of the Model Parameters
As discussed above, the individual hunter is assumed to first decide whether to hunt
ducks and then decide the amount of time to spend in the field. The individual’s decision
whether or not to hunt ducks is specified as a function of age, sex, residence in rural
versus urban areas, income, season length, and average bag per day and amount of
waterfowl habitat in the hunter’s home state. The last two variables are included as
measures of the relative quality and availability of waterfowl among states. The days
afield (DAF) equation is a function of household income, average daily harvest, season
length, and residence in rural versus urban areas. The variables in the equations are
defined in Table 8. Data used for this analysis are from the 2011 and 2016 National
Survey of Fishing, Hunting and Wildlife Associated Recreation, and the Waterfowl
Harvest and Hunter Activity Administrative Reports for the 1979 through 2011 seasons.
These data sources provide the required variability in harvest, season length and bag
limits to allow the estimation of the economic model.

The two equations were estimated on a national basis because there was insufficient
variation for some variables to estimate individually for each flyway. The probability
equation was estimated with logit equation, and the days afield equation was estimated
with ordinary least squares. Below each parameter estimate is the t-value in parentheses.
The probability equation is estimated for all hunters. The days afield equation is
estimated for those hunters who hunted ducks. The results are shown in Table 11 below.

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