41 



First of all, all of our comments today are within the framework 

 that the Service recognizes hunting both as a management tool and 

 as a legitimate recreational and subsistence activity. It is impor- 

 tant to our public. There are over 3 million migratory bird hunters 

 in the U.S. It brings $3.6 billion into the American economy. On 

 our national wildlife refuges, we have hunting on over 250 of them 

 and more are opening in the future, and we are very pleased to be 

 implementing an executive order that highlights fish and wildlife 

 dependent recreation opportunities when they are compatible with 

 the purpose of a refuge. 



The second point is that we recognize the importance and value 

 of hunting. The Migratory Bird Treaty Act is the Service's author- 

 ity for regulating migratory birds. It implements a 1916 Treaty 

 with four of our neighboring countries. It requires the Secretary to 

 determine by regulations when and to what extent and by what 

 means hunting can be allowed. The Service, with its State part- 

 ners, has subsequently regulated migratory bird hunting based 

 first of all on the overall health of the resource. We have utilized 

 professional judgment and scientific knowledge, and we have 

 evolved a system for setting seasons and managing migratory birds 

 that we believe is a model for conservation efforts worldwide. 



The hunting regulations, then, which are really the point of de- 

 bate at this hearing have basically been accepted and have been in- 

 stitutionalized as a conservation strategy. Hunting regulations, in- 

 cluding the baiting regulations, are just one strategy that we use 

 to ensure sustainable huntable populations. I would like to point 

 out that habitat loss, concern about contaminants, disease and 

 other things are a much bigger concern at this point with the regu- 

 lations that have been established. 



The Federal baiting regulations, specifically, were established in 

 1935, or 60 years ago. Federal and State biologists and the public 

 had recognized that unacceptable practices attracted and con- 

 centrated birds, and they tried to diminish that type of activity 

 through the regulations. Regulations are not static; they have been 

 updated ten times since that time to try to keep them current. 

 Baiting regs have been an issue of repeated formal, professional, 

 Congressional, citizen and legal reviews, but the basic issue of hav- 

 ing baiting regs has generally been supported by responsible State 

 officials and the hunting public alike. 



As a hunter, as a professional wildlife biologist as well as a man- 

 ager, I think that the majority of our 3 million migratory bird hun- 

 ters know and respect the regs. I have some data on that, but I 

 will skip over that right now. 



Third point. I am aware of two issues with the current regs: the 

 definition of normal agricultural practices, specifically with the use 

 of top sown green have been revised and are out for public review 

 and comment; the regulations dealing with the manipulation of 

 natural vegetation, sometimes referred to as moist soils manage- 

 ment are in the process of being reviewed by the states and other 

 concerned groups to review and consider any modifications that are 

 needed and to modify those regs if they are needed. I will be glad 

 to answer questions related to that later. 



The fourth point is that our constituents expect and deserve the 

 highest professional level of migratory bird management possible, 



