73 



would say that these regulations should be as user-friendly as pos- 

 sible. 



Agencies can ensure that regulations are user-friendly by making 

 sure that these regulations are science-based; they conserve the re- 

 source, and they are easily enforceable. To facilitate these regula- 

 tions, the agencies should also be involved in education, education 

 to make sure that the hunter knows why these regulations are 

 there; to make sure that the hunter knows what the regulations 

 are; and we think that if these two things happen, the hunter, 

 then, will be much more willing to comply with the law because of 

 his understanding of it, and it will ultimately be better for wildlife 

 conservation. 



While calling upon the agencies to provide clear and concise and 

 user-friendly regulations, we also recognize that it is the respon- 

 sibility of the persons who are involved in wildlife-associated regu- 

 lation to be diligent in trying to learn about the law and do their 

 activities within the confines of the law. 



On March 22 of this year, the Fish and Wildlife Service pub- 

 lished a notice of intent to review the so-called moist soil manage- 

 ment regulations. What they are talking about is the cutting of na- 

 tive vegetation to bait waterfowl, thereby perhaps enhancing oppor- 

 tunities to take birds. We commend the Service for their intent to 

 review these regulations to ensure that the regulations are user- 

 friendly. We urge the Service not to liberalize the regulations in a 

 manner that would create a baiting situation. Unfortunately, bait- 

 ing makes waterfowl inordinately susceptible to take, and it can 

 have localized and even national impacts on populations. In tech- 

 nical terms, we believe that baiting can produce conditions of addi- 

 tive mortality. 



We also urge the Service not to liberalize the regulations because 

 we think that it is an unnecessary change. Currently, regulations 

 do allow the cutting of mature weed seeds and weed vegetation be- 

 fore the hunting season, so already, this vegetation can be cut. The 

 third reason that we urge the Service not to liberalize the regula- 

 tions is the anticipated law enforcement problems. An area could 

 easily be baited with wild seeds, and then, what is and is not bait- 

 ing becomes even more ambiguous and difficult to enforce. 



In conclusion, let me say that the National Wildlife Federation 

 supports the Migratory Bird Treaty Act. We support the hunting 

 of migratory birds when in compliance with that act and consistent 

 with sound conservation practices. We oppose the liberalization of 

 baiting regulations, as scientifically unjustified and unnecessary, 

 and we urge all agencies to adopt user-friendly regulations. 



Thank you for this opportunity to testify. 



[The statement of Mr. Inkley may be found at end of hearing.] 



The Chairman. Thank you. Dr. Inkley, and may I say this as a 

 compliment — it may hurt you — this is probably one of the better 

 testimonies I have heard from the National Wildlife Federation. 

 There has been a change since you changed the head of your agen- 

 cy, believe me, and I do appreciate it, because you have recognized 

 some things that are very dear to my heart. And for a long time, 

 your association lost sight of that, and I think it did hurt your 

 membership, so you have come a little bit of a ways my way. I may 

 not go too far your way but 



