These comments were submitted in response to the proposal to release 'Pheasants for R3' in front of the Montana Fish & Wildlife Commission. You can learn more and comment yourself here.

May 5, 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: Comments on the Pheasant Release for R3

Chair Robinson; Vice Chair Tabor, Commissioners Waller, Byorth, Walsh, Cebull and Lane:

The Montana Chapter of Backcountry Hunters & Anglers (Montana BHA) represents roughly 3,000 dues-paying sportsmen and women in Montana who value robust fair-chase opportunities and public access. Above all else, we value quality habitat that fosters healthy populations of wildlife.

It comes as no surprise that our Chapter vehemently opposes FWP's proposed Motion to approve the release of pheasants on state-owned lands for calendar years 2022-2026.

What was a terrible idea just got worse: avian flu is here and spreading.

FWP's April 18th press release cautioned hunters of the dangers, stating the "Highly pathogenic avian influenza (HPAI) virus was detected in a snow goose from Canyon Ferry and a Canada goose from near Belgrade last week. HPAI was detected earlier this month in domestic poultry in Judith Basin and Cascade counties... HPAI viruses are extremely infectious and fatal to poultry and some species of wild birds." Now the first case of a transmission to humans (at a poultry plant at a prison) has just been reported. More than 25 states have confirmed the disease and had to destroy millions of birds already.

Poultry farms are on high alert and biologists and epidemiologists are both concerned of the potential devastating impacts of the disease. Nowhere will HPAI spread more quickly than at a pen-raised stocking facility. Regardless of what precautions FWP promises, once there's an outbreak, at best, the entire flock will need to be wiped out, making this program an even bigger waste of license dollars; at worst, diseased birds will be released and infect wild populations of game birds, or humans.

This new variable alone should be enough to shut down this proposal, immediately.

But alas, if risking our entire wild bird populations and putting the health of Montanans in jeopardy is not enough, we have other longstanding concerns.

While HB 637 authorized the department to spend up to $1M each fiscal year for a pheasant-stocking program, this legislation does not mandate that FWP actually do it. Repeatedly, hunters have asked that the department not comply, and instead, listen to the science and the concerns of Montanans; this is a waste of money, the wrong way to recruit new hunters or expand sustainable populations of pheasants, and poses significant threats to the health of our wild birds. The decision notice by the department to proceed with the project flies in the face of the strong opposition received by concerned sportspeople and conservationists. What is it going to take for FWP to listen to the people including their own field biologists?

We encourage the Commission to adopt the listed (and purposefully oversimplified, perhaps even misleading) alternative and "opt to not approve the release of pheasants for youth recruitment and retention." To move forward with this stocking facility at this time would not only be extremely unpopular and avoidable, but it would also be incredibly irresponsible.

Thank you for your careful consideration,

The Montana Chapter of Backcountry Hunters & Anglers