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3. The regulation should be able to be clearly and consi stenUv enforced bv Federal and State 

 law enforcement officers . As you are aware, Mr. Chairman, there are simply not enough 

 USFWS or State law enforcement officers to effectively enforce federal and state fish and 

 wildlife conservation laws and regulations. In most States through a cooperative agreement 

 between the USFWS and the State fish and wildlife agencies. State conservation officers are 

 granted the authority to enforce Federal conservation laws and regulations. Often times, they 

 are supplementing a Federal law enforcement staff of only one or two officers per State. State 

 conservation officers are fi^uentiy thus more familiar with local agricultural practices, bird 

 populations and landowners. It seems imp(»tant to us that the baiting regulation language be of 

 such clarity and certainty that State and Federal law enforcement officers ^>ply it with a 

 significant amount of consistency. We would support improvements in the language to meet this 

 objective. 



4. The baiting regulations should reflect changing apicultural practices for both crop 

 production and wildlife conservation purposes . When market hunting was in its heyday, the 

 planting of agricultural crops was almost exclusively for commodity production. In the last 20 

 years or so, however, there has been increased use of agricultural practices specifically designed 

 and applied to benefit wildlife. These wildlife conservation practices frequentiy are 

 recommended by wildlife conservation agencies and organizations. For example, the 36 million 

 acre Conservation Reserve Program normally involves management which does not include 

 grazing or haying of those lands • not a normal agricultural practice prior to the 198S Farm bill. 

 Fish and wildlife organizations actively promote the planting of species of grass, shrubs and 

 trees on these acres that provide food and cover for wildlife. Under what circumstances certain 

 of these practices could constitute "baiting" could benefit from review of the regulations by the 

 Association's special committee. As another example, moist soil management of crops which 

 provide food for waterfowl provide circumstances where hunting in the vicinity of these crops 

 may or may not be construed as baiting under certain circumstances. A clarity of the "rules" 

 and definitions regarding this could be helpful. 



Also "normal agricultural practices" vary from state to state and sometimes even within the 

 state, depending on climatic factors. In some parts of the Southeast, for example, it is normal 

 agricultural practice to top sow (by airplane) winter wheat into standing soybeans, and without 

 further attention, the seed germinates. Conditions in that part of the country where this occurs 

 should be treated differenUy regarding dove hunting over these fields than in parts of the country 

 where top-sowing winter wheat on "bare" ground is not a normal agricultural practice, i.e., 

 additional discing to cover the seed is required in order for the seed to germinate. Our 

 Committee's review of the baiting regulations will focus on areas such as these, and endeavor 

 to make recommendations that will allow for regional specific differences and will lead to 

 greater understanding of and consistency in enforcement of the baiting regulations. 



5. The baiting regulations should not discourage legitimate sport hunting because of 

 ambiguities in language or application . This seems rather self-evident, Mr. Chairman, but it is 

 helpful to remind everyone in this discussion of the tremendous contribution sportsmen and 

 woman in this country have made to fish and wildlife conservation. Their license dollars. 



