January 19, 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

Dear Chair Robinson, Vice Chair Tabor and Commissioners:

The Montana Chapter of Backcountry Hunters & Anglers submits this comment in opposition to the current proposal to extend the upland bird season in Montana until January 31 of each year. Our more than 3,000 dues-paying Montana members have a keen interest in both the conservation and sporting heritage of Montana upland birds as our organization is dedicated to protecting the value that these wonderful birds (and all fish and wildlife) bring to our great state. 

As part of our mission, we strive to promote science-driven management of fish and wildlife that is geared towards not only the conservation of species, but also the continuation of Montana’s position as a national leader in public opportunity and access. Montana BHA believes the foundation of Montana’s success is rooted in our state’s adoption of public trust principles for governance of its natural resources and our adherence to the North American Model of Wildlife Conservation. With these principles in mind, we oppose extending the upland bird season in Montana.

First and foremost, upland bird populations (like all fish and wildlife) in Montana have been struggling to adapt to our ongoing and historic drought conditions. This past year, FWP biologists consistently noted how the dramatic drought conditions, driven by climate change, negatively impacted upland bird populations across the state. According to FWP’s own biologists, extremely hot temperatures and below average precipitation has (among other extreme weather events) “put a great amount of stress on chicks” who as a result “probably didn't survive.” FWP biologists believe these difficult natural conditions have been detrimental to “pretty much all the upland species — pheasant, Hungarian partridge and grouse.” In what is perhaps Montana’s most productive upland region (Region 4) FWP notes that “overall numbers are still below the long-term average across the region.”

In relation to the current proposal, adding an additional month of the hunting season adds insult to injury for these struggling populations. The fact that the proposal is to add the month of January is even worse. Winter is well-documented as the season most impactful to adult survival of upland birds. In winter conditions, often accompanied by heavy snow, pheasants are concentrated in the last remaining heavy cover near food resources. Continual disturbance by hunters not only flushes roosters but results in repeatedly flushing hens away from these critical habitats, likely impacting hen winter survival and potentially even their springtime egg production essential to abundant upland bird populations. An additional month of bird hunters on the landscape could also further stress big game like deer, elk and pronghorn.

Furthermore, Montana already has one of the longest upland bird seasons in the west, and if this change is accepted, we’d have a longer pheasant season than South Dakota, the state with the most pheasants. While our organization is dedicated to promoting new and more opportunities for the public, we will not do so when it means that opportunity is detrimental to the species we are seeking to conserve and hunt. Simply put, there has been no need-based assessment for this action and, as a result, there is no stated biological or science-driven basis for this expansion. In fact, given the findings of FWP’s own biologists (as stated above), this action appears to be harmful and could result in long term damage to both hunter opportunity and the success of our wild birds.

Finally, we’re concerned that this proposal is lacking consideration and cooperation from our neighbors enrolled in Block Management, properties where many of these birds reside. We’re also aware of potential conflicts with the trapping community as bird hunting often includes bird dogs, who are not immune to foot traps or snares. We ask the Commission to consider all these concerns when making final decisions.

For all these reasons, Montana BHA offers this comment in opposition of the Commission’s plan to expand Montana’s upland game bird season by some 25% (roughly 57% for pheasants), extending until January 31^st of each year.

Sincerely,

Graham Coppes,

Conservation Leader

Montana Chapter of Backcountry Hunters & Anglers