Mr. Roger Woodruff
U.S. Department of Agriculture, Wildlife Services
720 O'Leary Street NW
Olympia, WA 98502

Dear Mr. Woodruff:

The following comments are submitted in response to the Environmental Assessment (EA) dealing with the "management of conflicts" associated with Canada geese in the Puget Sound area.

For the reasons outlined below we are forced to reject all of the Alternatives, especially Alternative 4.

General

Let it be clear at the outset that we recognize that the act of commenting on an EA that the authors claim is unnecessary under Federal statute as being tantamount to a fool's errand. If, as claimed, WS believes that it is under no obligation to formulate an EA for the proposed plans, it follows that it feels no obligation to consider comments generated from a "public comment period. " We also note that in choosing a mere 30 day public comment period on such a controversial issue, there is the implication that WS's interest in thoughtful public input is something less than genuine. We would also like to go on record as having said that we believe that one reason the formal EA protocol was employed was to give the illusion that some semblance of due process was in place. Despite all of this, we submit comments because the U.S. Court System will recognize them as part of an effort to "exhaust our administrative remedies"" in preventing the needless killing of wildlife as promoted by the EA.

We suspect that WS is not entirely confident in its exempt status regarding the preparation of an EA regarding goose management in Puget Sound. It is stated on page 4 that "individual wildlife damage management actions are categorically excluded from the requirement to prepare an EA." WS would have a hard time defending the notion that a vague management plan (as presented in the EA) for an area the size of Puget Sound constitutes a well-defined "individual management action. " A bona fide EA and EIS are certainly in order.

If the EA were prepared as a preemptive measure, it fails to fulfill the basic EA criterion that "concise" information be presented so that the impact of the proposed action on the environment can be deduced. While the EA under examination includes various plans or "Alternatives," these are so vaguely and informally described (even by qualitative standards) that no meaningful conclusions can be drawn regarding environmental impact or what actions would actually be carried out or where. More importantly, many of the cause and effect statements made regarding the outcome of certain procedures, while stated with great conviction, are unsupported and appear to be tailored to appeal to misconceptions of the public and are designed to achieve a state of "buy in." There appears to be a shortfall in the application of sound biological principles.

Conspicuous by its absence is any significant mention that Wildlife Services will be the primary fiscal beneficiary for most of the "control" actions described, especially in their area of expertise, lethality. Given this obvious conflict of interest -- the agency recommending an action plan is also a possible profiteer -- a section should have been devoted to explaining just what precautions were taken in the crafting of the EA to avoid opportunistic conclusions or proposals. Clearly, the more field work ("goose management") that WS deems necessary, the more revenues it stands to gain. Moreover, long-term management plans offer the promise of sustained funding for the agency. We find that the intrinsic conflict of interest between sound decision making and the lure of contract dollars is reflected in the way Puget Sound's Canada geese are portrayed in the EA. The EA reads more like promotional material that resulted from a "business plan, " rather than a true environmental assessment

Information gathering

While we appreciate the attempt to provide references to allegedly factual sources throughout the EA, detailed information dealing with the situation in Puget Sound is apparently scarce. There is heavy reliance on anecdotes gathered in connection with the "public involvement letter" or single incident citations.

The fundamental assumption behind the EA and the proposed "Alternative" is that there is, indeed, a "Need for Action" regarding geese in the Puget Sound and that this need is so extreme that deadly force needs to be employed on a routine basis (i.e., Alternative 4). As this constitutes the foundation of the EA, extra care should have been made to thoroughly document this point by presenting specific data or a reference to a detailed written record of all alleged conflicts and itemized claims regarding economic losses. Moreover, how many problems or alleged economic losses due to geese were actually validated? Who did the validation? Were multiple "complaints" from the same person counted multiple times? Rather than address these issues, the reader is provided with a boilerplate history of geese that culminates in the conclusion that they are now widely considered a menace. Merely saying such things does not make them so.

The fact that only 77 out of 377 recipients of the "public involvement letter" could conjure up enough enthusiasm to respond belies the fact that, regardless of the goose population numbers cited, geese affect relatively few people, in a few well-defined places -- this is certainly neither a mandate nor an emergency situation warranting the use of lethality. It's interesting to note that 10 of the respondents called for the complete extermination of geese. It is more than likely that this small (13%), irrational, and probably very vocal component of your sample is responsible for driving public officials crazy and disseminating the idea of using lethality. While their "alternative was removed from further consideration," the proposed alternative rests entirely in its shadow.

It would be instructive to know exactly what the distribution was for the mailing of 377 "public involvement letters" among recipients in the Federal, state, county, municipal, business, animal rights, animal welfare and individuals categories. Quality conclusions can only be derived from impartially chosen, significantly sized data sets. The information presented in the EA does not allow the reader to know whether or not the information was gathered in a statistically meaningful manner. For example, in addition to distribution, how were these 377 recipients chosen? Why were government entities included? Since government agencies generally support one another (especially if it means that another agency will handle a "situation" for them), it's not outlandish to assume that these were included to pad the input to advance the proposed action. We have enough experience on the issue of urban geese to know that a few complaints from the public are amplified many-fold through local government officials.

Population Data

Much is said about goose populations in the EA. There is not only discussion on its magnitude and trends for the future, but the authors even editorialized on occasion (page 5, last paragraph, "The overabundance of Canada geese... "). Remarkably, none of the population data included is presented with confidence limits. Further, no mention is made regarding the extent to which extrapolation was employed in processing the data, nor anything about the survey methods used or whether the same methods were even used from year to year. It is one thing if the authors just want to point out that the number of geese is growing; it's quite another to suggest that, based on some informal observations of the Audubon Society (or the like), a mathematical model for future growth can be advanced. Just what IS the exponent in the assertion that the goose population is "growing exponentially" and what level of statistical confidence does it carry? In the final analysis, the overall population is largely an irrelevant distraction, since usable habitat will always redistribute a regional population of geese into places where the most intolerant will find them a bother.

The Trumped-Up Case Against Geese

Throughout the EA there are numerous places where key statements are made about geese in an attempt to build a case against them, yet many of the most important statements stand alone without substantiation or further comment -- as if self-evident. (E.g., "Sometimes relocations resulted in problems elsewhere..."How often? Where? When?) Some of the references cited even appear to advance ideas of dubious quality and questionable motivation. Some referenced statements do not even appear to comply with the rudiments of common sense and some rely on the power of suggestion rather than substance. Human health constitutes a fine example of this.

Threat to Human Health?

While this section appears to be well-referenced and based on sound findings, it lacks a context that places the information in realistic perspective for accurate public health risk assessment. The process of determining risk from microbiological hazards is complex and not part of the expertise of wildlife managers, wildlife damage managers or even academic biologists. Indeed, that the information is presented suggestively (with an emphasis on clinical manifestations), in a manner that forces those not trained in public health to draw the worst possible scenario conclusions is no mere accident. Despite presenting two pages of information, no evidence was presented to suggest that the geese, or their droppings, in Puget Sound carry any of the potentially harmful organisms cited. Further undermining the general health argument is the use of weak language such as "ould, might, may, can," etc. The authors appear operating on the safe bet that this vague language will slip by ordinarily sensible people and help justify lethal actions against geese. It is apparent that WS is using public health to make a more serious case against geese than reality will support. That the authors feel compelled to make such a fuss over public health is actually a subtle acknowledgement that exterminating geese because people feel they are messy is insufficient at best and possibly deranged at worst. As it turns out, the chief complaint about geese IS that they can be messy; health arguments always follow during the formalization process. The health information presented is just too weak to provide justification for wildlife extermination as specified in the proposed alternative.

The Scoop on Poop -- how deep do those inconsistencies run?

It would be nice if government "wildlife experts" would get their story straight on the amount of feces that geese produce per day. Here in New York, our "experts" at the DEC say geese produce one pound per day. To our south, in New Jersey, a local health officer with close ties to the head waterfowl manager in the state proclaims that their geese produce 1.5 lbs. of droppings per day. Up in Alaska, where they have the lesser (i.e., smaller) Canadas, the USFWS claims that these birds produce two pounds of feces per day. With the USDI claiming 3 pounds, our earlier concern about the sources and scientific integrity of the data used throughout the EA is justified. We notice the EA did not mention that goose droppings are greater than 80% water by weight. Was this omitted because ca. 9.6 oz. dry weight / day doesn't sound as menacing?

It is not "uncertain" whether or not geese harbor pathogenic E. coli: it is well-known that they are rarely carriers of bacterial pathogens of concern to human health (Friend, 1993, Address to Blue Ribbon Panel on Canada Geese, Rockland County, NY). Coliforms, the enteric organisms used in the archaic water tests described in the EA, are not pathogenic either.

Have bacterial organisms of concern to human health actually been isolated from goose feces in the Puget Sound area? If not, why the fuss?

That an anecdote is on record that someone thinks they became ill because of swimming in a contaminated area does not constitute a scientifically valid example because no causal relationship was established. Perception is not more important than fact.

Coliforms: It is interesting to note that at Juanita Beach geese and ducks were found to be the primary source of fecal contamination. Primary? What were the other sources? If geese and ducks were the only source that would be good news, because geese rarely carry pathogens of concern to human health. If human waste was even a minor source of contamination, a serious health risk would have existed because human waste ALWAYS contains pathogens. Geese are often blamed for health risks associated with faulty septic systems, outhouse leaching and farm animal run-off. In the Fall of 1998, a 70 year-old Waterford, CT woman was issued a Cease and Desist order from the Commissioner of Health for feeding geese, ducks and swans in her waterfront backyard. She was publicly accused of compromising water quality because of her actions. While water tests showed that coliform counts were elevated on certain days, to the health department's embarrassment, it was later found that the contamination was from human sources.

Cryptosporidiosis: Has Cryprosporidium parvum been isolated from goose droppings in the Puget Sound area? If not, why is this being mentioned? The CDC quote was sloppily written, if the CDC, indeed, wrote it. Waterfowl CAN carry the Cryptosporidium parasite, but they are by no means the only vector for its transmission. All wildlife and humans are also included as hosts. Further, the prevalence of C. parvum oocyts in the environment has become quite common; 65-97% of all surface waters tested in the US contained this organism.

We suspect the authors of the EA didn't actually read Gradczyk, 1998. He was studying MIGRATORY Canada geese and surmised that the organisms in question were picked up by geese stopping over and feeding in and around farmland contaminated with animal waste.

Since the authors of the EA assert that the geese in Puget Sound are non-migratory, the relevance of these citations is not clear. Since geese are not hatched harboring either Cryptosporidium or Giardia and it is asserted that the birds are "resident," they certainly can't be implicated in importing harmful organisms. If there is Cryptosporidium or Giardia in the Puget Sound area, the presence of these organisms is independent of geese. Please note that geese are only mechanical vectors (and poor ones at that), not systemic hosts. If disease is truly a concern and not just a justification gimmick, perhaps the EA should be addressing migratory birds instead.

Salmonellosis: "Salmonella is a potential enteric (intestinal) pathogen that in the United States is transmitted primarily by person-to-person contact with human carriers of the bacteria, and increasingly, by food-borne outbreaks. Wild or aquatic birds are not a documented source of transmission, nor do they act as intermediate vectors (carriers) of disease. The bacteria can be transmitted to humans from the environment by consumption of contaminated water supplies, which is the route most frequently seen in developing nations with inadequate sanitation. However, salmonellosis is actually more common in industrialized nations because of the unsanitary conditions of 'raising, shipping, slaughtering, and marketing' of poultry and dairy products. Thus, geese pose no threat to the integrity of the water supply in terms of salmonellosis." [James Craner, M.D., Board Certified in Internal Medicine]

"Swimmer's Itch": Canada geese are not responsible for the condition known as "swimmer's itch. " While the parasite responsible for this condition does spend part of its life cycle in an intermediate host (which can include a large variety of warm-blooded animals, including birds), the critical and primary host is a snail. If the parasite is present in a body of water it can not be controlled by addressing potential intermediate host species such as geese. Indeed, standard public health measures to control the spread of schistosomiasis do not include "control" of intermediate host vectors, such as birds (Goldsmith T., Heyneman D., Tropical Medicine and Parasitology, 1989). The inclusion of "swimmer's itch" as a health issue is the proverbial "red flag" indicating that the EA has traded accuracy for the opportunity to throw in every fear factor "including the kitchen sink" to justify the proposed alternative. Has the schistosome responsible for "swimmer's itch" even been detected in the Puget Sound region?

Chlamydiosis: "Psittacosis, the name of the infectious disease produced by the bacteria Chlamydia psittaci, ... is harbored by many avian (bird) species and transmission to humans occurs by inhalation of the birds' droppinqs or secretions. Nearly all cases seen in the U.S. occur among individuals who have repeated intimate contact with birds, such as pet-store owners, poultry workers, and owners of exotic birds. Such extensive contact between humans and Canada Geese, who are wild animals (or their droppings), would be extremely unlikely. Psittacosis resulting from such a transient environmental exposure is a highly improbable event, and certainly does not warrant extraordinary public health measures." [James Craner, M.D.] While we are certain that there are those who feel that there are a lot of geese around, the conditions are far from the level of intensity needed to justify using the threat of Psittacosis/chlamydiosis as reason to exterminate geese.

The remaining organisms noted in the EA are either irrelevant or possess infinitesimally small levels of risk under such rare circumstances that they do not dignify further comment.

Threat to other wildlife?

The EA states that, "In large concentrations, resident Canada geese, feral geese, and hybrids create a reservoir for disease and pose a health threat to migrating waterfowl. " Actually, large concentrations of any type of wildlife and even humans can serve as a reservoir for infectious agents. This section goes one step further by implying that "resident" Canada geese have been responsible for large-scale die-offs of migratory birds. It further implies that the population has reached a theoretical critical mass from which disease might emerge. This assertion is not directly supported. It is not readily apparent why the AAWV's resolution on the spread of avian disease would put so much emphasis on taking action against resident and feral geese. Indeed, even those with minimal biological training should recognize that those species that move around the most (i.e., migratory birds) have the greatest potential for picking up and distributing harmful organisms and triggering die-offs. This being the case, migratory birds are more of a health risk to "resident" geese than the other way around. Statements from the AAWV such as the one quoted can usually be traced to political arm-twisting by "game agencies" who are eager to justify revenue-generating "special" hunts for "resident" geese or to kill domestics, etc. that lure "target" species away from hunt areas. Of course, using the argument that we have to kill wildlife to save it is ludicrous.

Threat to human safety

While much is said about the threat of geese to aviation safety, there is no way to fully eliminate this risk. Bird damage will always be an operating cost of flight. However, despite the claim that only a "limited number of bird strikes are reported," geese comprise a relatively small fraction of the total. Indeed, most discussions on this topic lead with the generic cliche, "Bird strikes cause an estimated..." instead of "Canada goose strikes caused an estimated..." Predictably, the authors of the EA included the story of the AWACS jet in which 24 crew members were killed. Not mentioned was that, according to the Air Force investigation that followed, the accident, while it did involve geese, attributed the disaster to human error on the part of the ground crew. Several Air Force crew members were discharged as a result.

Most analyses of the relationship between geese and air traffic safety focus on the geese themselves (the symptoms) rather than the cause (human stupidity). In Sioux Falls, SD, our investigation revealed that the Municipal Airport Authority was leasing land adjacent to the runways to farmers. These fields were enticing geese to fly over the runways from a nearby lake in search of food. In Anchorage, AK, not far from where the AWACS jet crashed, we discovered that a golf course (a good goose attractant) was built at the end of the airfields at the municipal airport. In Minnesota, where thousands of geese have been killed for several years, a recent memo by the local airport manager questions the effectiveness of goose kills as a "control" measure.

We recently learned that the non-lethal control measures being used at the Puget Sound airfields have produced excellent results, so the issue of air traffic safety is weak at best.

Attacks / Hazards

Geese should not be slandered for protecting their nests or young. Humans need to be educated about geese in a positive way so that during this brief period (in the spring and summer months) they understand what is going on and that the geese need to be given extra space to avoid confrontation. This includes using temporary barrier methods (e.g., fencing) if a nest is in a less than convenient location for humans.

Slipping hazards are easily addressed by cleaning the affected surfaces.

Killing geese is not a substitute for common sense.

Damage to Property

We have investigated enough "goose problems" to know that the so-called "quality of life" angle is largely the concoction of people who, upon closer scrutiny, don't want to implement even the most basic of goose dissuasion techniques to address their particular situation. Even facility administrators, who feign to have "tried everything," prove to have zero inclination to get non-lethal techniques to work. There is a mentality that someone else, the government, should step in and deal with the geese.

The claim that fecal loading from geese is negatively impacting phosphorus levels in the Puget Sound and causing "ecological damage" is suspect. As the number of geese is NOT that high in the Puget Sound area (relative to the surface area of the water), it is more than likely that turf grass maintenance chemicals -- which are a far more potent source of Phosphorous than goose droppings -- or other ecological imbalances are the cause of the imbalance. While geese decidedly add some phosphorus to surface water sources, far more information from research on the relative contributions from various sources would be necessary for this argument to carry any weight.

When taken in the context of the big picture and other sources of environmental impact are weighed, arguments that suggest geese to be an ecological problem are, at best, frivolous. The real irony to those capable of understanding ecological issues is that WS is essentially proposing that more geese be killed in an attempt to prevent damage to an invasive, resource intensive, biologically irrelevant, non-native plant species -- turf grass. From an ecological standpoint, turf grass destruction caused by geese is not "damage" at all. Indeed, it's quite the opposite.

Impact of Proposed Program

Humaneness of lethality Unlike other topics covered in the EA, WS seems to have carefully extricated itself from making a definitive statement about the humaneness associated with corralling and cramming wild Canada geese into enclosed vehicles/confined spaces followed by having knives jammed into their throats at a slaughterhouse. Are agencies of the USDA forbidden by policy to comment on the brutality and inhumaneness of agribusiness? Rather than hiding behind terms such as "euthanasia," and clinical statements proclaiming that the killing will be carried out "following methods recommended by the AVMA," the authors of the EA should have actually described the possible killing procedure in detail. While there is little doubt that to survive in such an agency, WS agents must accept, dignify and institutionalize the taking of life in the name of (highly subjective!) "practical ideals," we are certain that the public would promptly reorganize its priorities if it had to bear witness to the proposed bloodshed. We feel that those parties who advocate/request the killing of geese on their property (i.e., homeowners, town board members, upper managers of corporations, property owners, etc.) be required to watch the killings in person as a condition for the use of lethality in their respective cases. Further, animal organizations should be permitted to video tape or film these killings so that the true cost of these programs can be laid bare for all to see.

Impact on target species The removal, and presumed killing, of "up to 3,500 geese from the 12-county" Puget Sound area appears to be an arbitrary figure of no particular biological significance. Further, it's unclear what specific criteria the ADC Decision Model (Appendix 3) would utilize to determine when lethal control would be "necessary." Since these criteria lie at the foundation of the whole EA, why wasn't a detailed description of the factors (e.g., number of geese in a specific area, dollar amount of damage, etc.) and measurable thresholds presented upon which lethal recommendations would be based?

It is not self-explanatory why the number of geese killed after the first year would necessarily drop or why geese removed from problem areas would give rise to reduced "problems" and diminished requests for assistance. The assumption behind such claims is false for one simple reason: geese fly. In Clarkstown, NY similar claims were made by Bryan Swift, Waterfowl Specialist, NY State Department of Environmental Conservation. Within weeks of having all of the geese from several town parks removed and killed, other geese from surrounding areas just moved in to fill the vacancy. At several sites, the population repopulated with interest. This futile exercise was repeated two years in a row. No practical results were achieved in the town until non-lethal methods were fully implemented. There is clearly a reservoir of geese in the Puget Sound area and beyond to keep the problem areas restocked with geese. Killing as a site- specific way to address goose problems reflects extremely simplistic thinking characterized by an ignorance of goose behavior.

It is asserted under the proposed alternative, "that local concentrations of geese would be reduced in the control areas. " It has been our experience that there is a wide range of tolerance regarding "acceptable numbers" of geese and in most cases the actual quantitative aspect of this point is not taken into consideration. How would killing all or some of the geese in a given "control area" where zero tolerance exists ever be expected to produce satisfactory results? In areas where "some" geese are acceptable how will lethality keep other geese from joining the remaining flock? Border collie company owners will freely admit that in many cases, as the number of geese is reduced using border collies in a given area the tolerance level of their clients for what used to be an acceptable number of geese falls even lower. Unlike killing however, border collies can keep areas almost goose free -- something that killing cannot achieve.

In the following section (3.44) it is stated that, "The potential for negative aesthetic impacts from excessive goose feces in residential and public areas would be expected to decrease under this alternative. " No reduction in goose feces was achieved in killing every single goose at any of the parks in Clarkstown. By the time the feces of the dead geese had broken down, other geese just moved in as though nothing had happened. Why would merely reducing the number of geese at certain sites be of any practical value?

Effectiveness of control measure in reducing or minimizing damage The claim is made that, because the proposed alternative facilitates the use of more lethality, it will be more effective in reducing or minimizing damage caused by geese than alternatives offering less killing. By promoting an extreme measure such as killing with the prognosis of mediocre results "reduce or minimize" damage by an unspecified amount) as an acceptable outcome, it can be inferred that, in general, the "problems" caused by geese are of questionable magnitude. By saying that there are situations where "non-lethal methods would not resolve the damage" implies that lethal methods would. It would be instructive to know under exactly what sort of circumstances would only lethal methods be effective? The recurring theme of justifying killing to reduce goose damage warrants far more elaboration. How will damage be measured? Is all damage considered legitimate grounds for goose extermination? If not, what criteria will WS agents be employing?

Is the notion that "killing enhances the effectiveness of non-lethal control" a new development? If not, why have various wildlife agencies been advocating for some time that goose complainants "try" non-lethal methods first? The problem with this "new" concept is that once killing has taken place, one has to then implement non-lethal control. Since killing does nothing to prevent repopulation, and the cost of non-lethal control is essentially independent of the number of geese, this lethal-non-lethal scheme presents itself as cost-ineffective.

In the final sentence of paragraph 1 on page 32, it is stated that if habitat alteration "was not employed," repeated killings would be carried out. It's not clear what this statement was meant to mean, but it says that not using habitat alteration is a license to have repeated killings on the unsupported hope that the killings would taper off as time went by. Actually, the more time that passes the more time other geese have the opportunity to move into the area. This sounds like a contract dollar "perpetual motion machine" for WS.

It is asserted that exclusion techniques only displace geese from one damaging situation to another. As evidence that assertions such as this one are grossly overstated, I point out that the only reference that might support this point is Swift, 1998. Our organization followed Swift's attempt to scientifically slander non-lethal methods of goose control in great detail. We encourage you to review his data in more detail, as you will surely find the results of his efforts are quite underwhelming. In an area whose goose population has been so well-studied and distribution is so well elaborated, it is remarkable that so few of the displaced geese could be found, let alone said to be causing any significant damage. Swift was having such a hard time "getting his conclusion," he even put up DEC money to extend the (mostly) town-funded experiment with border collies for an additional two weeks.

Concluding Remarks

There is no question that this EA is the product of an agency whose very existence is predicated on the philosophical notion that wildlife should be held accountable and acted on for damage that it unwittingly causes, when, in reality, the root of such damage is known to be of human origin. WS can not effectively argue that managing with an emphasis on the symptoms (i.e., the geese) rather than the cause -- the proliferation of goose habitat -- is either scientifically based or biologically sound.

Suspiciously, WS appears to have intentionally avoided defining what would constitute a valid "goose problem" for which killing would be promoted. Moreover, not a single example was provided to exemplify the sort of serious situation for which lethality had to be dispensed. The vague and highly subjective "ADC Decision Model" is not a substitute for a well-defined paradigm that indicates what responses are justifiable for what situations. In other words, there is far too much reliance on "professional opinion" when well-defined criteria could be constructed. With economic incentive looming heavily in the background, the EA offers no material reassurances that ability to pay isn't the only criterion.

At best, the EA offers a false hope about the effectiveness of lethal methods, especially if as suggested, it has to be followed up by non-lethal methods or more lethality. We stand by our assertion that only a few geese in a few places are causing problems for a few people. The EA did not satisfactorily convince otherwise.

Once again, we reject WS's attempt to expand the use of lethality for resolving what are primarily aesthetic conflicts, ostensibly to "control" geese or the damage they are allegedly causing.

Please send us copies of any other documents relating to this EA that are published in the future.

Thank you.

Sincerely,

Gregg B. Feigelson, Ph.D.