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Special Report

    March 2002

What is this Draft EIS all about?

The U.S. Fish and Wildlife Service (USFWS) is moving forward with the creation of a regulation that would turn the fate of Canada geese that nest within the U.S. over to state wildlife management agencies. On March 1, 2002, a Draft Environment Impact Statement (EIS) was issued for public comment.

While they claim that the purpose and intent of this regulation is to help solve problems that some people might be having with geese, nothing could be further from the truth.

[If you received a copy of the EIS document, it is because you submitted your address when you made written or oral comments or signed a petition during the 1999/2000 scoping session.]

What does this proposal actually mean for Canada geese?

The US Fish and Wildlife Service (USFWS) is attempting to make it legal for state wildlife agencies to have complete life or death control over Canada geese in their states from March 1st to August 31st. As written, the proposed action (Alternative F, "State Empowerment") would allow states to kill unprecedented numbers of Canada geese using crude population guidelines. State wildlife agencies would not need to justify killings by providing documented proof that killing is necessary or that non-lethal control methods had been honestly attempted first.

Is this transfer of power legal under the Migratory Bird Treaty Act?

No. In 1918, Congress empowered the US Fish and Wildlife Service (not state agencies or other governmental entities) to directly oversee all actions that affect migratory birds, including Canada geese. Regardless of how convenient it may be for them, the USFWS does not have the legal authority to delegate this responsibility in such a way that gives state wildlife agencies broad and virtually unrestricted power over the fate of Canada geese.

Even though the Migratory Bird Treaty Act does not afford a lower level of protection to Canada geese based on how far they migrate, the USFWS is making policy as though it does. Even so-called "resident" geese migrate hundreds of miles during the course of their seasonal activities.

If it is already possible to get a permit to kill geese, why is the USFWS pursuing this?

In part, this is an attempt to change the laws to protect the guilty. The USFWS have been violating the current regulations for years. The Migratory Bird Treaty states that geese must be shown to be "seriously injurious," not an inconvenience, before lethal control can be undertaken.

It's true, permits to kill geese are already available upon application to the USFWS. The system requires that the state wildlife agency "co-sign" the permit application. Our investigations have shown that the USFWS never validates (not even periodically) the claims made on permit applications. Every permit application we investigated contained gross exaggerations regarding the need to kill geese; nevertheless, the permits were rubber-stamped by the USFWS. They approved these permits even when provided with documented proof that the permit applications were based on fraudulent assertions.

The US Fish and Wildlife Service have clearly never fulfilled their responsibility under the Migratory Bird Treaty Act. As a result, many geese have died needlessly. They are now trying to make irresponsible and inexcusable past behavior the law.

Did they consult the public before deciding to propose massive killings?

Yes. The process of creating the draft EIS began in 1999 when they asked the public for comments on six proposed alternatives. According to their own analysis, of the 3000 written comments received, 60% were in favor of expanding non-lethal control and opposed any attempt to use or increase the use of lethality to control geese. Legitimate issues raised during the comment period were ignored.

The EIS reveals the USFWS' disinterest in those who do not agree with their proposed policy changes. The proposed action in no way reflects anything the majority of comment writers submitted. Obviously, collecting public input became a mere formality when they realized they didn't get the response they were looking for.

If they ignored public opposition to this plan, who are they listening to?

The EIS shows that the USFWS not only disregarded public comments, but it shows that they made a strategic decision to instead defer to the opinion of state wildlife agencies, the Flyway Councils and Wildlife Services (part of the USDA). There is enormous overlap in the first two organizations. Both can be accurately described as special interest groups for the hunting lobby. Neither state wildlife managers nor Flyway Councils members represent the people in their state or flyway. They represent those who kill geese and other wildlife for recreation -- a very small number of people.

Wildlife Services is a federal agency that can best be described as a government-run extermination business. They actually charge a fee for their services. Any regulations that make it easier to kill wildlife will provide economic opportunities for this agency. As is true with state wildlife agencies, their area of expertise is limited to killing.

It is completely inappropriate for agencies and individuals with such blatant biases and economic self-interest to have any say in the regulatory process. America's wildlife belongs to ALL citizens; priority should be given to those who want to protect it, not those who want to exploit and kill it.

Why would state wildlife agencies want complete control over Canada geese?

Not because it will help solve goose problems, but because they will make money from the killings. The EIS will allow state wildlife bureaucrats to offer their paying customers, hunters, longer hunting seasons on Canada geese, higher bag limits (the number of birds a hunter can kill in one day) and more ways to lure and kill them.

The decline of hunting has thrown state wildlife agencies into a state of financial desperation (recent antics). They have long sought complete control of Canada geese for the economic opportunity that killing geese affords them. Few people realize that wildlife management decisions are first and foremost acts of economic self-interest - not rational problem solving. Since hunting license fees pay wildlife managers' salaries, lethality is always the "management" choice they pursue. Another financial incentive is that wildlife agencies compete for federal funds (under the Pittman-Robertson Act) based, in part, on how many hunting licenses they sell.

State wildlife agencies have been lobbying the USFWS for control of these birds for years under the false pretense that this control is necessary to "solve goose problems." This explains why Canada geese have been slandered mercilessly by wildlife agencies and others, like Wildlife Services, who profit from their destruction.

According to the USFWS, geese are causing some serious problems; it this true?

While it is true that Canada geese do cause problems in some situations, a state of emergency - such as would be required to change federal policy, does not exist. Claims of the Canada goose population "exploding," or not migrating, or somehow being less worthy than other geese, or causing public health problems are all gross misrepresentations of the truth. The USFWS would know this if they chose to do any of their own investigations rather than rely on self-serving misinformation from second-hand sources, primarily special-interest groups looking for any excuse to kill geese for profit (e.g., state wildlife agencies, Wildlife Services, USDA, etc.). Of course, the USFWS won't do this, because they welcome the opportunity to have someone else do their job for them.

What about public health? The USFWS claims that killing geese is justified because of public health concerns.

Canada geese are not a significant threat to public health. The USFWS can not prove otherwise. But don't think they (and a couple of state wildlife agencies) haven't tried. All attempts to justify killing based on the "public health argument" are scientifically flawed. More information about public health and geese.

Will their proposal solve goose conflicts?

While the USFWS' proposal will lead to the cruel wholesale slaughter of many Canada geese, it will not have any practical impact on goose/human conflicts. In their own words, the USFWS only "believes" that their plan will help solve alleged goose problems -- remarkably weak language for such a drastic plan.

In reality, despite the lethal measures they use, state wildlife agencies will make sure that goose problems persist so that they can continually justify hunting and the revenues that it generates. This is the standard operating philosophy and economic basis for current wildlife management. The proposal will give the state agencies the authority to allow hunting in suburban areas, but they will also be able to hoodwink community leaders by saying that "not only does USFWS allow us to do this, they recommend it!"

Why does the USFWS think that reducing the goose population will solve goose problems?

They've been asked this question numerous times, and they avoid answering it. We can only conclude that they don't have an answer. They want people to think that it is self-explanatory: if the population goes down, so will the problems. If they really believe this overly simplistic view, then they are actually clueless as to the nature and severity of most goose problems. In reality, people who find geese to be a problem in certain areas don't want fewer geese (what the USFWS proposes), they want none. The USFWS plan would appear to be fundamentally flawed in this regard but given the real motive behind their proposal, it is actually a flaw by design (see answer above).

Managing wildlife using the "total population model" is an old-fashioned concept used, not to reduce, but to maintain populations of various species so they will support lucrative hunting. Since new hunting opportunities is clearly the only outcome that will result from this proposal, it is fitting that they support it with a model that is good for hunting but bad for solving wildlife problems.

They claim that the goose population is going to grow out of control if nothing is done; is this true?

Despite the fact that just about every news story about the EIS opens with some line about how the Canada goose population is "growing out of control," this is not strongly supported by mathematical models. It is simply a scare tactic to get the public to believe that the population needs to be reduced.

Notice very carefully the wording that USFWS uses : "...The population has increased dramatically during the past several decades." They go on to say that the population of "resident" Canada geese in the Atlantic Flyway has increased an average of "14 and 6" percent over the last 10 years. They always refer to large blocks of time so that if there are any large increases over a few years, they will capture them and their statement will be, at least, partly true. According to their own annual population status reports, the population of "resident" Canada geese in the Atlantic Flyway hasn't really changed appreciably since 1998. Careful wording such as "the population will approach 1.3 million in 5 years and 1.6 million in 10 years" is manipulative, because ANY increase from today's population, no matter how small, makes the statement true, even if in 10 years the population is nowhere near 1.6 million geese. The deception lies in the word "approach" which only means "move toward."

Atlantic Flyway "Resident" Goose Population Estimates
(from Waterfowl Population Status, 1998-2001, USFWS)

1998:   743,357 - 1,196,753
1999:   762,706 - 1,236,285
2000:   817,303 - 1,214,537
2001:   817,300 - 1,214,500

Didn't the same agencies who are going to benefit from this new regulation help cause whatever problems exist in the first place?

Yes. On page I-18 of the EIS, the authors openly state that:

"From the 1950s to the 1980s wildlife agencies in many Atlantic Flyway States were actively involved in relocation and stocking programs to establish resident populations, primarily in rural areas. These programs were highly successful and most were discontinued by 1990."

In the 1980s state wildlife managers are documented as having anticipated conflicts between these geese and the public increasing as time went on. Yet, their efforts to increase the population of Canada geese continued unabated. In fact, according to the quote above, some of these programs still continue to this day. Since these programs were allowed to continue through the 1980s, it is clear that state wildlife agencies were knowingly creating a conflict that they would eventually be able to benefit from economically. The EIS proposal is the culmination of their self-serving actions. The EIS would reward state wildlife agencies, when in fact they should be punished.

Those suffering significant, legitimate goose damage have just cause in legal actions against state wildlife agencies for causing the damage on the one hand, and the USFWS for not taking action sooner to mitigate the damage on the other.

Will the proposed change in regulations really make it possible to solve goose problems more quickly?

That is what they would like the public to believe. The new regulation will really only eliminate any barriers to goose killings. Under the proposal, the killing of geese will definitely be expedited, but this has nothing to do with solving goose problems. One of the USFWS' primary arguments is that under the current system, it takes too long to get a permit to kill geese and this is a problem in "emergency situations." This is absurd because such situations are extremely rare. And even if they were common, the ever-growing arsenal of cost-effective, reliable and humane non-lethal management options can be implemented immediately without any government red tape.

What can I do to help stop this proposal from becoming a reality?

See our Action Alert!

Copies of the draft EIS are available by calling the Service at 703-358-1714.


Copyright © 2002 Coalition to Prevent the Destruction of Canada Geese