Deb O’Neill

Special Projects Director

Montana Fish, Wildlife & Parks

PO Box 200701

Helena, MT 59620

[email protected]

RE: Programmatic Pheasant Release EA Comments

Dear Ms. O’Neill:

The Montana Chapter of Backcountry Hunters & Anglers (Montana BHA) represents roughly 3,000 dues-paying sportsmen and women in Montana who value quality recreational opportunities and ethical conduct in the outdoors. Our Chapter values the opportunity to pursue wild upland birds in quality habitat and strives to pass our fair-chase opportunities to the next generation of responsible hunters.

Montana BHA is writing to support Alternative A: No Action in the proposed Annual Release of Pen‐raised Ring‐necked Pheasants. Since the inception of this proposal via HB 637, we have opposed the use of license dollars to purchase pen-raised ring-necked pheasants as a half-hearted gesture toward recruiting new hunters.

Biologically, we object to stocking pen-raised birds, which have an embarrassingly low survival rate. Study after study, many cited in this EA, find that pen-raised birds represent a futile effort toward bolstering populations. These birds rarely survive long enough to be effectively utilized by hunters. Montana FWP’s own 2004 review of upland game bird biology and habitat relationships as part of the Upland Game Bird Habitat Enhancement Program states, “Stocked birds contribute little to harvest or population growth in pheasant populations. In Montana, Weigand and Janson (1976) noted that hunters subsequently harvested only 13%-24% of pheasants released 1-3 weeks prior to hunting season opening.” We trust FWP to make sound biological decisions when managing our wildlife and question why it would go against its own science to conduct these releases.

Socially, while we appreciate and support more opportunities for new and novice hunters, we prefer these to be fair-chase opportunities that present an honest take of hunting including both the difficulty and the thrill, two aspects that make this heritage so rewarding. Presenting a fabricated put-and-take opportunity teaches to kill, rather than to hunt; it diminishes the experience. Small, colorless, pen-raised birds without a wild instinct to rely on provide few challenges compared with wild pheasant hunting, and this scenario will fail to help new hunters by presenting them with unrealistic expectations. At best, this stocking proposal will see poor retention for new hunters while proving to be a waste of dollars better spent on meaningful change and habitat improvements. These are not the kind of R3 efforts we see as recruiting the next generation of fair-chase hunters.

Fiscally, we are completely opposed to this wasteful use of fish and game dollars. While we understand that the funds appropriated from the state special revenue fund established in 87‐1‐601 are separate from the Upland Game Bird Enhancement Program funding, we do not agree that this is the best use for those license dollars. We believe these funds could be better used by the myriad fish and wildlife recovery and restoration efforts FWP biologists propose annually, or any number of more impactful R3 efforts. There is a reason most states and nonprofits have stopped stocking birds and instead focus on the most critical factor impacting wild birds: quality habitat. Any efforts to increase wild pheasant populations in Montana should be focused on continuing to improve and protect their habitat. We do not support efforts through the legislature to circumvent the sound biological findings of this Department and trusted upland bird researchers nationwide by appropriating funds and forcing projects that have no merit.

As mentioned in the EA, Montana BHA questions where the decision-making process to raise these pheasants at the State Prison in Deer Lodge occurred. HB 637 appropriates funds for this stocking effort but does not specify anything about the facility of origin. In fact, we have seen no public notice of a competitive bid process related to the state contract for providing these birds. This causes us to question whether there were ulterior motives in this appropriation process and whether our license dollars are being covertly funneled into subsidizing other state agencies.

Finally, we do not believe this public comment process is being conducted in good faith toward the Montana hunter. It is stated twice within this EA that, “FWP has been mandated by the legislature to proceed with pheasant releases…” (Comment 13e and Part III). In fact, this EA clearly states in Comment 13e that many concerns have been raised over pen-raised pheasant releases and then concludes that because FWP has been mandated to proceed with these releases, newly implemented monitoring will measure the success of this project as it will be proceeding. Montana BHA thus fears that the decision making for this proposal has already occurred and that FWP is conducting a farcical effort to engage hunters before ultimately ignoring our comments. We therefore suggest that FWP amend the EA to correct this inaccuracy and ensure that due consideration is given to public comment on this issue and is not being ignored in favor of legislative whims.

For these reasons, Montana BHA supports only Alternative A: No Action in response to the proposed Annual Release of Pen‐raised Ring‐necked Pheasants. We recommend you stick with wild birds and keep it that way.

Sincerely,

Thomas Baumeister

Vice Chair and Capital Leader

Montana Chapter of Backcountry Hunters & Anglers

Helena, MT

Comments are due 5:00 p.m.,Monday, February 28, 2022. EA and comment information here.