I shoot 4 last year. All on the ground. Well, 3 on the ground, one on a fence post. Now, in the past I never considered it sporting to shoot a sitting dove or duck or goose. But that was gun hunting. With a bow, it's a different story. You're still 30-50 yards away. And a dove ain't very big. I was thrilled with the ones I got.
I'm also too cheap to try and shoot them flying. At my dove field, there's a pretty narrow window you have in which to shoot and still be able to find your arrow. Otherwise, it'll be over the river, or in the briar patch, or stuck in some tree.