July 21, 2022
Chair Robinson, Vice Chair Tabor, Commissioners Waller, Byorth, Walsh, Cebull & Lane
Montana Fish Wildlife & Parks
1420 East Sixth Avenue
P.O. Box 200701
Helena, Mt 59620-0701
Re: The Proposed Pheasant Release
Chair Robinson; Vice Chair Tabor, Commissioners Waller, Byorth, Walsh, Cebull and Lane:
The Montana Chapter of Backcountry Hunters & Anglers implores the Fish and Wildlife Commission to deny approving the release of pheasants on state-owned lands for calendar years 2022-2026 as proposed by FWP. We maintain and have argued throughout that the impetus, rationale, process, and execution of releasing pen-raised pheasants in Montana are ill-conceived and poorly executed. All this has been forced on Montanans at the hands of an institution seemingly out of touch with the people it is statutorily mandated to serve. The way FWP has gone about the entire program from the very beginning is a textbook example of what government ought not to do and why the state finds itself increasingly at odds with our right to hunt and fish in the great state of Montana.
We remind the Fish and Wildlife Commission about the categorical flaws of this program since its inception at the hands of FWP. We have already and repeatedly submitted testimony on various occasions to that effect. Here's a high-level recap:
- Montanans have not requested for FWP to raise and release pen-raised pheasants; there’s no documented public request to do so;
- FWP single-handedly pursued this idea on its own, via legislative interference,
- The program has received widespread – perhaps universal – objection and condemnation by Montana’s hunting and conservation organizations. The constituency meant to be served by this program has expressed neither interest nor demand for this program;
- The connection between releasing pen-raised pheasants for teenagers to kill in hopes of recruiting them as new hunters is, at best, wishful thinking, and the research in support of it is, at best, mixed and unconvincing. However, the long-term risk and consequences to hunter conduct, skill development, fair-chase hunting, wild-bird management, habitat conservation, hunter-landowner relationships are real and conclusively documented;
- FWP misled the public during the environmental assessment process in spring 2022 when it stated that the Legislature demanded FWP to develop the pheasant stocking program. HB 637 merely authorized the department to spend up to $1M each fiscal year for a pheasant-stocking (FWP later admitted this error in the EA but failed to remedy it);
- FWP is poised to waste $1M annually on a species that has a shockingly low survival rate, and it is inconsistent with best science and biology to introduce pen-raised pheasants in Montana;
- FWP issued a decision notice in support of the pheasant-stocking program despite widespread opposition from the public and a colossal failure by the department to address properly and comprehensively the real and known risk of highly pathogenic avian influenza;
- FWP appears mostly concerned with ensuring that the incarcerated prisoners through the Montana Correctional Enterprises (MCE) have meaningful day-jobs. But FWP's responsibility should be maintaining Montana as the last bastion of a tradition of public hunting of wild birds on both private and public lands with quality habitat at its core, established through programs including the flagship Habitat Montana and the many collaborative efforts between landowners and hunters.
In summary, FWP appears to be the sole advocate of this ill-fated effort and has taken an advocacy position beyond the scope of what a state agency is legally and morally mandated to do by telling the people of Montana what is best for them. The department is not only out of touch with the people but has violated the trust afforded to it by the citizens.
Now it is upon the Fish and Wildlife Commission to put a stop to this madness. Please reign in FWP by denying it the authority to proceed. We implore you to do the right thing for Montana and stand ready to support you with arguments and an accounting of what has taken place here.
Thomas Baumeister, Vice Chair
Montana Chapter of Backcountry Hunters & Anglers