Division of Migratory Bird Management
U.S. Fish and Wildlife Service
4401 North Fairfax Drive, Suite 634
Arlington, VA 22203
I am writing in response to the public comment period on the Draft Environmental Impact Statement (February 2002) regarding Canada goose management.
I oppose your efforts to expand the use of deadly force to address problems that some people might be having with geese. Alternative F, the proposed regulation, is unacceptable to me. I will be negatively impacted if it is implemented. Instead, I am asking that you adopt Alternative A-no action, or a non-lethal management alternative, in the Final EIS.
The Draft EIS shows that my views, and those of a majority of scoping session comment writers, were acknowledged but dismissed because they disagreed with the Service's premeditated goal of turning over its congressionally-appointed responsibility for Canada geese to state wildlife agencies.
In the DEIS, the Service admits to having given priority to the opinions of STATE WILDLIFE AGENCIES, FLYWAY COUNCILS and WILDLIFE SERVICES. These agencies DO NOT represent me, nor do they represent the public. They represent themselves. Their opinions reflect a vested economic interest in any policy that liberalizes killing wildlife. Catering to agency greed is an intolerable approach to policy making.
The DEIS blindly asserts that population reduction should be the basis for the preferred management program. It is remarkable that the closest thing to an explanation given for choosing this "approach" is the statement that the Service "believes" it might mitigate goose problems. This is an inadequate justification for such drastic policy making. Indeed, Alternative F is so poorly defined in the DEIS that statements made about its allegedly intended impact, whether in absolute terms or relative to other options, are meaningless. Only one thing is certain: many geese will be killed.
Population reduction necessarily means killing. Killing not only affords gratuitous economic opportunities for state wildlife agencies (revenues from expanded hunting) and Wildlife Services (extermination programs), but it also gives the Service an excuse to completely disregard non-lethal management options in its policy making. Non-lethal goose management was inaccurately portrayed in the DEIS as being of questionable utility while population reduction was portrayed as being of obvious utility. In reality, the reverse is true. There is concrete precedent for the effectiveness of non-lethal Canada goose management in eliminating the impact of geese. The same can not be said about killing programs -- but not for a lack of trying.
Population data are presented in an attempt to support the population reduction plan concept. However, these data are incomplete, contradictory, and of inconsistent quality. Goose population trend assertions are highly speculative, and in some cases plain wrong.
According to the Service's own reports, the Atlantic Flyway population of "resident" Canada geese has hardly changed in 4 years! Is that what the Service considers an "exploding population"? Similarly, public health concerns are still cited, even though study after study confirms that geese are an insignificant public health issue. Some of these studies were even funded by the Service for the purpose of finding something from which an imaginary "goose emergency" could be fabricated. The Service continues its attempt to justify new regulations by relying on second-hand information and damage claims that have neither been confirmed nor evaluated based on any set of established standards. Most of the "supporting data" in the DEIS come from the special interest groups who will gain the most economically from the proposed alternative.
Finally, I resent the fact that state wildlife agencies played a significant role in boosting the population of "resident" Canada geese from the 1960s onward, and in some cases, still do (DEIS, II-18). References provided in the DEIS show that these agencies predicted in the 1980s that goose conflicts would increase due to their propagation efforts. Yet, then as now, the Service allows these practices to continue. The "State Empowerment Alternative" would reward those (state wildlife agencies) who caused whatever problems exist with increased hunting revenues and Pittman-Robertson money. The "resident goose" controversy is clearly the willfully manufactured product of state wildlife agencies whose goal was to eventually demand complete life or death control of a migratory bird species. To adopt Alternative F would be to surrender to the demands of special interest groups.