Brad:
I'm not interested in debating the proposal, or in arguing the science that supports it, but I am trying to understand it. A recommended 2 black duck bag limit is a significant change from a longstanding 1 duck limit. Presumably something in the data, the modeling methods, or the interpretation of them has changed to support this recommendation.
Based on the most recent Waterfowl Population Status Report, the population estimate for black ducks in the eastern survey area is pretty much a flat line with some year-to-year variation since 1990.
https://flyways.us/sites/default/files/uploads/statusreport2016_final_0.pdf, page 16-17. This year's population estimate is up a bit from last year and within 1% of the long term average.
I confess I am not sure I understand the AHM report that was cited. It's difficult to understand a complicated model based on a few paragraphs of text. But the discussion there suggests that key factors in the decision making are estimates of mallard competition and of black duck harvest additivity. Neither of those estimates appears to have changed much in recent years. To the extent they have changed, this year's estimate of mallard competition appears to have slightly increased, while harvest additivity has dropped very slightly. My naive impression is that those factors would tend to offset each other.
Since population status and model estimates of mallard competition and harvest additivity are all pretty much the same as in recent years, it's difficult for a layman to understand how the recommendation is different this year.
It seems to me there are at least two possibilities:
(1) We layman may simply not understand the model, and relatively small changes in model inputs may lead to different recommendations. For example (grossly oversimplified, I'm sure), since we can only harvest one duck or two (not 1.5), a model that suggested allowable bag limits of 1.4 ducks may have been rounded down in recent years, while this year slightly different inputs suggests 1.6 which is being rounded up.
(2) The policy makers may be interpreting the model results differently than they have in the past--perhaps informed by new information beyond the model.
Again, I don't think this or any online forum is the right venue to argue this recommendation, and I don't expect you to reply here. That's what the public comment process is for, and you have rightly directed us to it.
But as a sportsman who does frequently write comments on proposed regulations, I'd like to understand the analysis behind this one better.
Right now, I'm torn between native conservatism about harvesting game and the selfish assessment that some of my hunts would be more enjoyable if I could kill two black ducks. Neither of those provides me much of a basis for an informed public comment.