From: Greg L Munther, BHA Chairman, Montana Chapter
and
Ben Deeble, President, Big Sky Upland Bird Assoc

June 1,2011

FWP-Wildlife Bureau Attn: Public Comment PO Box 200701 Helena, MT 59620-0701

Re Upland Game Bird Enhancement Program

We have read the draft plan and our representatives attended the Missoula public meeting on the draft plan. Our conclusions are that it is a well thought out, positive plan that can move Montana upland gamebird management forward. We found the format of region-specific direction for each gamebird species easy to understand. And we also appreciated the realistic approach to the pheasant stocking and feeding programs, including the recommended reduction from 25% to 15% of available ·monies.

Our suggestions are as follows:

Reasonable access clause: History has shown that the ambiguous language regarding what constitutes "reasonable public access" has lead to some participants denying access to ordinary hunters, claiming all reservations are full, even before opening day arrives. We have no qualms about limiting hunting to certain days or certain numbers of hunters. But any agreement must ASSURE that hunting opportunity will be unbiased, and all hunters will have equal opportunity to reserve or sign up. This plan should include specific guidance in defining "reasonable public access" which should be carried to specific language in each enhancement contract.

Upland Bird Biologists: We appreciate MDFWP employing new upland bird biologists in key areas ofthe State. We believe Montana will benefit substantially with three field biologists in Conrad, Plentywood and Miles City charged with developing and implementing upland bird ha,bitat enhancement projects in partnership with private landowners. If funding is available, an additional biologist in the central part of bird habitat in the Lewistown area would benefit upland birds there as well. We do however, believe that it is important to state an upper limit in the Plan regarding what percentage of enhancement monies will be spent on salaries compared to those monies actually spent on the ground.

Linking Enhancement to Long-term Access: Some types ofenhancement, like shrub plantings or grazing systems take a decade or more to realize obvious habitat improvement. We all know ofexamples where the public has invested in long-term enhancement only to have properties exclusively leased after the contract period or sold even before the contract term had expired. In several cases public access has been lost, before the full benefits of habitat enhancement had been realized in terms ofbird population, hunt quality or harvest. This program should prioritize investments on public land or lands with access guaranteed beyond the typical contract period for planned enhancements. For example, contracting for food plots of standing grain may only need access guaranteed for a year or two. However, windbreak plantings may not be fully beneficial for a decade or more, therefore access must be guaranteed for at least that period to undertake this level ofinvestment.

Expanded Enhancement on Public Lands: It is a fairly common experience to encounter sections of state or federal land which have been subjected to excessive livestock grazing, either in season length or stocking rate. In some areas, state and federal lands are the only uncultivated lands available, and may be the only public ally accessible land in a township. In the same way that this plan is supporting CRP contract extensions to maintain grassland structure (which we are very supportive of), this plan should also contemplate how UGBEP funds could be used to improve grazing practices on state and federal lands. Given the historically low rental rates for public lands grazing, buying-down or eliminating grazing from some of these tracts may constitute relatively inexpensive enhancement. This plan should identify both the importance and opportunity to lease such lands to 1) allow native plant communities and structure to recover and 2) initiate direct enhancement projects such as riparian or nesting cover restoration. Even temporary livestock exclusion from riparian habitat or shrubby draws can have dramatic affects on the ability of an area to provide productive hunting and critical upland habitat later in the· year.

Of course, there are also many opportunities for enhancement on those Trq,st lands already under cultivation or enrolled in the CRP program.

Build Enhancement in Habitat Nodes: It would appear to be beneficial to long term bird enhancement as well as hunting opportunity to build on an existing nucleus ofassured habitat. Existing Wildlife Management or federal Refuge areas or other secure public bird habitat can serve as the nucleus, on which peripheral private or public lands could be improved. This would seem to be beneficial in providing more opportunity for birds to move to nearby high quality habitat during tough winters or drought. This type of node would also be attractive destinations for hunters who must travel long distances once or twice a season. Probably one of the best ex;amples of success·ofthat model is the PlentywoodlFroid areas which is an imp9rtant node surrounding Medicine Lake WMA and other waterfowl production areas. This would appear to be more beneficial that scattering individual projects far removed from other habitat. By clustering such efforts, local communities can feel the economic benefits ofproviding both habitat and access, and upland bird populations may respond to new habitat enhancements more rapidly where they adjoin established high quality habitats. Community support can make this program much more successful. Related, any opportunities for promoting UGBEP sites to youths should be exploited, particularly where access has been secured near Montana's urban centers. We have not seen any advertisement or promotion ofthe UGBEP in the context ofyouth hunting opportunities, and we think these should be emphasized both to benefit youths, and to showcase
the value ofthis program in the public eye.

Monitoring and Evaluation: Expenditures for upland bird habitat enhancement will be questioned by somebody in the future. In addition, we want to assure that UGBEP projects are cost effective in picking the type ofproject which results in the greatest benefit for monies expended. While we appreciate the content ofthe monitoring section, it does not include actual bird population, brood indexes, or harvest success in enhanced vs control areas. While we understand there are some uncontrollable variables, actual upland bird population response or at least hunter success information will be needed to assure skeptics among the public, communities and legislature as well as to confirm which types ofenhancement are most beneficial to upland birds. Although the difficulties ofthis type ofmonitoring are discussed on p 104-105, there may well be partnerships with universities, conservation, or sportsmen's groups that could enable meaningful monitoring to occur without large expenditures.

Russian Olive: We understand there may be major disincentives to establishment of Russian olive in future plantings. This species has been shown to be ofmajor importance to wintering game birds as a food source and shelter. We encourage this plan to address obstacles in using Russian olive in the future on upland sites, or to identify methods for developing alternate forage plantings to maintain upland populations.

Gray Partridge: Throughout the document we notice a lack of specific direction to improving Gray Partridge habitat, or any real recognition of prioritizing the hunting ofthis species. Reasons given were that the population fluctuated wildly and they seemed to occupy a wide range ofhabitats. Nevertheless, this species is one that can be a primary gamebird species for many Montana hunters, just as it has been for generations· ofEuropean hunters as agricultural activities intensified. In Montana this species can serve for many years to come as an important upland bird species, especially where lands are too arid to support pheasant or where access to riparian pheasant habitat is in steep decline. In some years, Gray Partridge may be the most .important upland bi!d in Regions 2 and 3. Certainly more investigation detailing habitat needs, enhancement techniques, and future harvest opportunities for Gray Partridge, should be contemplated.

Region Specific Plans: The Pheasant and Gray Partridge habitat in Region 1 is in high demand, and thus deserves special consideration for intense habitat enhancement. Tribal and USFWS lands offer considerable opportunity with public access generally available. Contracting with tribal restoration companies could build support for the UGBEP in Region 1. Scattered small ) food plots ofgrain may improve hunting opportunity and over-winter survival, while improved grazing management and expanding use of brood strips need to be evaluated for enhancing upland bird productivity.

Living here in Region 2, we do understand the limits on upland bird enhancement. However, grazing, timber harvest and fire management, and cropping patterns can enhance the habitat of any upland bird species. The plan should provide more guidance about how FWP may interact with the USFS, DNRC, and private landowners to engage in these opportunities. For example using a focus area approach, there may be opportunities to enhance Gray Partridge habitats in the upper Clark Fork around the Opportunity re-vegetation projects currently underway. As part of watershed management plans, any number offocus areas could be selected for the intended enhancement ofRuffed or Blue Grouse habitat on USFS, DNRC or private lands.

We also support working with land managers to consider the reintroduction of Sharp-tailed Grouse into Regions 1 and 2~ Recent reports indicate that Sharp-tailed Grouse may persist in the upper Blackfoot Valley, and with interest in reintroduction and new habitat acquisitions by the CSKT and FWP (in particular, Spotted Dog) there may be opportunities for reintroducing sharptails and reestablishing a huntable popUlation in western Montana. Thus, we do not think that a "focus area" approach is unsuited to the region altogether. The upper Blackfoot and Clark Fork, and areas on and adjoining CSKT lands are three a,reas that may be well-suited to the focus area approach, and could deliver real benefits to upland bird populations and hunting opportunities in western Montana.

Sincerely,