288 Crisswell Road

Butler, Pennsylvania 16002

June 23, 2003

Pennsylvania Game Commission

2003 Elmerton, Avenue

Harrisburg, Pennsylvania 17110-97-97

Executive Director Ross, Deputy Director Schmit, Commission Members:

Thank you for the opportunity to comment on Game Commission programs and proposed regulatory changes affecting hunters in the Commonwealth of Pennsylvania. The Pennsylvania Chapter of the National Wild Turkey Federation would like to affirm the action taken at the April commission meeting creating a special early youth spring gobbler hunting day for 2004. This example of forward-thinking regulation change says volumes about the commitment of the commission to our youth hunters. The special spring youth hunt will have a positive impact on hunter recruitment and retention by encouraging young people to turkey hunt. The early date will help to assure that mentoring programs will be available to youngsters whose parents or guardians are not turkey hunters. We will work with the Game Commission and encourage our 72 chapters to establish mentoring programs to benefit youth hunters.

Our members deeply appreciate the commission’s support of trap and transfer operations designed to place wild turkeys into unoccupied range in the southeast region. This three year investment of personnel and equipment will benefit hunters and other wildlife enthusiasts in that region. With turkey restoration efforts complete, we would urge the Game Commission to maintain equipment and personnel training in order to make certain that trap and transfer capability remains available as a management option for possible situations in the future.

Completion of trap and transfer efforts in the southeast region and continued planning for cooperative habitat enhancement projects on state game lands throughout the commonwealth are examples of the Game Commission meeting the objectives and strategies of the PGC Management Plan for Wild Turkeys in Pennsylvania. Future commission decisions on wild turkey management need to be based on the objectives and strategies outlined in the plan. The management plan is scheduled for review and revision in 2004. The Pennsylvania Chapter is looking forward to working with the Bureau of Wildlife Management on the revision process. In the meantime, we encourage the commissioners to consider funding a regional leg-banding study in order to begin acquiring essential data on harvest rates and survival among wild turkeys. As a supplemental method of harvest data collection, we support the establishment of a toll-free harvest reporting telephone line as soon as possible. Both accurate harvest figures and harvest rate data are important components of scientific wildlife management needs  for wild turkeys outlined in the plan.

Our organization is committed to the provisions of the Management Plan for Wild Turkeys in Pennsylvania. The plan suggests that some regulation changes might be possible in the future. We are available to discuss and explore additional recreational opportunities for Pennsylvania turkey hunters with the Game Commission at any time.

The members of the Pennsylvania Chapter of the National Wild Turkey Federation are greatly concerned about proposed changes to regulations requiring the use of fluorescent orange clothing by turkey hunters and others. Citing a nationwide decline in turkey hunting incident rates that has continued through the present, the 1997 National Turkey Hunting Safety Task Force recommended against mandatory fluorescent orange requirements for turkey hunting. Instead, the Task Force encouraged educational efforts as the most effective method of creating awareness and reducing incident rates. Educational efforts in other states and provinces have included options such as distributing NWTF safety materials and other safety messages directly to turkey hunters, thirty-second public service announcements on radio and television and even billboard messages. Some states have increased the emphasis placed on turkey hunting in the hunter safety education program, offered optional advanced hunter training on turkey hunting or established mandatory turkey hunter training sessions. Most states consider these methods to be highly effective.

Indeed, incident rates have declined in most states since the late 1980’s without regulations requiring the use of orange by turkey hunters. Pennsylvania is the only state that requires turkey hunters to wear or display orange in the spring and one of only a handful with such requirements for fall hunting.

When regulations requiring orange were originally proposed, Pennsylvania turkey hunters opposed the action. However, hunters compromised and accepted the current regulations though they were unpopular. There has not been a permanent dramatic decline in the rate of incidents associated with orange requirements here in Pennsylvania. In addition, we are concerned that additional orange requirements will cause an increase in the use of rifles for fall turkey hunting, impacting the severity of any incidents that might occur. Our membership cannot and will not support additional orange requirements for turkey hunting.

Current requirements for the use of orange are a burden to turkey hunters and are more than sufficient. Successful turkey hunting often requires the hunter to move while working a bird. Movement associated with removing and replacing orange and the color itself can significantly reduce hunter success. Total camouflage is the preferred uniform of turkey hunters. If the goal of this proposal is to promote simplicity and uniformity in the orange requirements, we would request that the commissioners reduce the required amount of orange for fall turkey hunting to 100 square inches while the hunter is moving or eliminate the requirement entirely for both seasons.

We are pleased with the relationship between the Pennsylvania Game Commission and the Pennsylvania Chapter of the National Wild Turkey Federation. The dedicated employees of the Game Commission promote wise management of our wildlife resources and increased recreational opportunities through quality research projects, habitat enhancement practices, land acquisition and law enforcement. Our membership would like to continue to work with the agency to conserve the wild turkey and preserve our hunting tradition.

Sincerely,

Carl Mowry