J. Gary Oldenburg, State Director
USDA APHIS ADC (Wildlife Services)
720 O'Leary Street NW
Olympia, WA 98502
Dear Mr. Oldenburg:

Please include my comments in the Environmental Assessment (EA) for the management of conflicts associated with non-migratory (resident) Canada geese in the Puget Sound area.

I found, in reviewing your claims that there are problems with the population of the Canada goose (Branta canadensis), a complete lack of integrity and scholarship. Having read the files recovered under the Freedom of Information Act (5 USC 552), and knowing that you had a statement from the Humane Society United States and a copy of their Virginia ADC Environmental Assessment, there is little excuse for such assertions. Your own assertions in the Environmental Assessment do not match the documentation in your own files.

Purpose and Need for Action (p.1-12):

By its own admission, United States Department of Agriculture Wildlife Services (also known as Animal Damage Control)(USDA-WS(ADC)), humans are responsible for the presence of the locally nesting Canada geese. The EA claims that the geese are not native to Puget Sound, but that one of the sources of the present population is "through a program to remove eggs from rising water levels" (of the McNary and John Day Dams on the Columbia River) (p.5). It is not clear to the reader how the geese could be non-native and be introduced from the Columbia River basin. It is not clear how the geese could be non-native and have been "released" from (source unspecified) damage areas. Nor is it clear how they could be non-native and also have been subject to " natural expansion of their range from eastern Washington." These statements should be explained so citizens can get a true picture of this phenomenon.

The use of USDA APHIS ADC Annual Tables is unacceptable. It is widely known that ADC counts and gathers estimates but does not verify. A memo from Ron Kokel, Office of Migratory Bird Management, to the Coalition to Protect Canada Geese, confirms that the data is unreliable. "ADC doesn't verify, only reports," said Kokel.(1)

Your agency convened The Seattle Waterfowl Management Committee and prepared a report in 1998. The data from that is not included in the Environmental Assessment except for selected letters from Manuwal,1988, Manual (sic) 1989 and Manuwal,1990. The charts you present to document the large number of geese (Figures 1 and 2) from the same source (Audubon Society) In Figure 1, you claim the number of geese in 1998 is about 13,500 for Puget Sound. In Figure 2, you claim the number of geese is in 1998 about 5,500 in the Olympia, Seattle and Tacoma area (though your narrative states 6,591 in 1997 (p. 6). Your Figures 1 and 2 carry no date, only an internet page which I was unable to access. Does Audubon count birds in July? If so, why did you not give the months when the count was conducted? What is your area of concern? Puget Sound, the three-city area? An increase in the number of Canada geese in itself does not constitute any kind of identifiable problem.

Your estimate for July in the Seattle Waterfowl Management Report is about 1,050(1) Park by park, the number of geese does not seem to pose an emergency. Why did you not cite this data?

Resident birds are defined (p. 5) as "those geese which nest and reside predominantly within the coterminous United States". To conclude that they are non-migratory does not follow. Your own preferred sources (game agency conference proceedings and journals) do not agree. Ankney, 1996, writes in Journal of Wildlife Management: "These molt migrants now number in the thousands on brood rearing areas and are derived from populations throughout much of southern Canada and the US. ...Such molt migrants, of course, were virtually non-existent before the recovery of giant Canada goose populations in the 1970s." (3) So the non-breeding offspring (at least) of US "resident" Canada geese do migrate according to your own sources. In addition, I note in your own data from the Seattle Waterfowl Management Committee 1998 that the number of geese in the parks ranges from 416 in January 1998 to a high of 1104 in September 1998.(4) How do you account for that discrepancy? I note you did not include that data in your Environmental Assessment.

You claim that dogs displace the geese onto neighboring areas and that not all the geese relocated returned to their home area calls into question the notion of "residence". The fact that many of the relocated geese return to their home area suggests that they are migratory.

Your plan to exterminate geese relies on a concept of resident meaning that the geese do not leave the area. It defies an understanding of the verb "to fly" and your own observations.

In your section Threat to Human Health (p. 7) you claim that "genetic testing (RNA analysis) of samples taken from Juanita Beach in 1998 identified geese and ducks as the primary source of fecal contamination". Use of the Seattle Pilot as your source of information underscores your lack of scientific foundation for this report. Notwithstanding, with reference again to your Seattle Waterfowl Management Committee Report, your chart shows that there were no geese at Juanita Beach during the months of April, May, June, July and August 1998. But there were 214 in September, presumably part of the Arctic migration. How do you explain this data? Though your chart does not identify the area (Seattle?, Puget Sound?), your highest number for in the entire survey was in September 1998. Are you planning to kill the Arctic population?

What is most astonishing is your data on the dramatic decline in Canada goose population in your survey area in July. In July 1996 you claim to have 1600 in the parks; in July 1997 less than 1100; in July 1998 around 1000. The only month in which the goose population of Puget Sound increases is September, presumably including the Arctic population, but one that would not be causing beach closings. Why no mention of this fact?(5)

You cite Mr. Frodge (not referenced) in your statement "Health departments currently rely upon the Ten States Standard for ensuring public health and beaches are closed whenever coliform counts exceed the standard, regardless of source species." It means public health departments are obligated to close the beaches regardless of the source of coliform contamination. You did not cite him as source of the RNA data. Since the beaches were closed before the RNA data was obtained, citing him on this standard is to lure the citizen into believing there was a proven health threat related to the geese. There is no threat to public health demonstrated in this document. In the instances in other communities where these claims were made, human fecal contamination was the source even though Canada geese were present.

You make references to a number of potential health threats (cryptosporidiosis, giardia lambia, salmonellosis, chlamydiosis, "swimmer's itch" (cercarial dermititis), influenza A and myobacterium avium. One should think that with this highly infected area, one would have some documented cases of illness. Yet there is no documentation of any real infections or illnesses in the Puget Sound area. In fact, there appear to have been no attempts to analyze data that might have shown the source of the perceived problems. Citizens note that your citation for swimmer's itch (hardly a lethal condition) concerns swimmer's itch in Michigan. (Note: one author of their cited study is a student or teacher at Hudsonville High School, Michigan). How does this support your contention that there is a problem of swimmer's itch in the Puget Sound area and that it is caused by Canada geese?

Curiously, some of the people who commented in your earlier call for comments referred the the large population of gulls as well as Canada geese. One of the statements in your files (recovered under the Freedom of Information Act) asserts that a high school senior alleges that he got an (unspecified) infection while playing football on the Reton High School field. Why was that not investigated and verified? Are we to believe that a high school senior (as reported by high school operations manager Joe Lamborn) is qualified to determine the source of infections? I notice that there is no claim that the infection is caused by geese, but that there was no report in your files of investigation by health authorities, suggesting a lack of concern about the real causes of the reported infections.(6)

You cite "public involvement" as the source of information about the closing of a King county cafeteria, which was closed for coliform contamination from goose fecal matter. There is no citation of any health department order or scientific analysis of the problem. Likewise a statement from Kit Ledbetter asserting that lifeguards got sick due to the Canada goose feces. Was there no public health investigation to determine the actual cause of the illness? The geese were blamed without any determination.(7)

One letter in your files, which you failed to note, states the following:

"While I believe the problem is not getting any better, various agencies are trying increased control measures on their own, i.e. Kirkland is expending $60,000 this year to increase applications of Turf Shield (a repellant) and employ a canine (dog) patrol under contract. While these efforts are being evaluated, it would (I think) be difficult to sustain a case for "lethal control" until the results of these efforts are evaluated. Additionally, we are still seeking definitive health data to make a direct correlation between Canada geese and human risks. Until we have this in place, I do not believe that we can successfully proceed to a kill.(8)

In the absence of any scientific data on health problems associated with Canada goose or their feces, I believe you must either provide it or eliminate human health claims from your report.

If the public believes that there is a health hazard, perhaps it is because government officials such as you have been promulgating the idea and inciting the population whom otherwise might sweep their decks without comment. Even some animal rights groups have bought into your fraudulent claims of disease and assisted you in alarming the general population. I am referring to a letter from Karin Bennett, PAWS, dated August 5, 1997,(9) who circulated with Seattle authority's explicit approval, alarmist and derogatory fliers in the parks blaming the Canada goose-appreciating public for health problems. No evidence was presented in this document to show that the population of Canada geese on Puget Sound lives on breadcrumbs. No evidence is presented that without breadcrumbs, the population would return to the hunting fields. Given your statement that "Geese are herbivores...They graze on plants or parts of plants that are high in protein such as grass shoots, seed heads and aquatic vegetation" (p.5), so the "don't feed the geese" campaign is fraudulent and alarmist . In your Current Alternative section (p. 21) you mention feeding geese as a solution to "temporarily attract wildlife away from more valuable resources (i.e. crops)". You claim that lure crops would lure geese away from other crops, but there is no documentation that the geese can differentiate the lure crops from the "valuable" crops. At least you acknowledge that there is abundant food for geese in the form of crops and that the pond feeding and the disease threat are your deception scheme. You claim that "no opportunity to utilize lure crops has been presented in the Puget Sound area." Are you claiming that there are no "lure" fields, i.e. fields that are left unharvested and flooded for the purposes of attracting geese for hunting?

Lack of analysis that the geese create a health problem and lack of data to show that citizen feeding of geese helps you to justify such extermination (hence revenues for your extermination services). In fact, most if not all your application for permits to USFWS to kill geese last year were for fraudulent health and safety reasons. The lack of analysis completely omits any investigation into the root cause of the population growth and creates a self-serving illusion that there is a health problem (there is not!).

Threats to human safety: airports. Your alarmist claims about the threat to human safety at airports is undermined by your own data. Your own count (Seattle Waterfowl Management Committee 1998) of geese at Reton Airport is:

January 1998: none
February 1998: none
March 1998: none
April 1998: none
May 1998: 16
June 1998: 14
July 1998: 17
August 1998: 6
September 1998: 24
October 1998: 10
November 1998: 6
December 1998: none

You claim that on August 31, 1998, "a flock 5-6 Canada geese was struck by a medical transport jet while landing at Renton Municipal Airport", though there is no reference to any FAA report. This would appear to be the entire population of geese at Reton Airport in August. I believe during this time you were killing geese that were a problem under USFWS permit. Why did you allow that situation to take place? If the geese were killed in that incident, why then were there 24 in September if all the geese are "residents"? Citizens would like you to resolve some of these discrepancies.(10)

Some airports where there are such claims of damage were built in wetlands (Minneapolis) or near wildlife sanctuaries (Reno, Kansas City). Another airport (Sioux City), there was verification that the airport itself was leasing the land adjacent to the airport to a farmer who was growing soy beans. Why is there no analysis of the context of the situation when it is apparent you cannot keep even six geese off the airport runways even with permission from US Fish and Wildlife Service to do so.

Why did you fail to include the Reton Airport experimentation with Turf Shield that apparently has been quite successful?

You cite Jim Cooper and Dennis Keefe 1997 elsewhere in your paper, but you do not make reference to their Canada goose cleansing program at Minneapolis airport. Cooper and Keefe receive large grants to keep the airport free of geese. Yet in a widely circulated document from the Metropolitan Airport Commission. John Osmun, says "One question that comes to my mind as I review all of the data is - Why are we seeing an increasing number of geese at MSP, when all of Dr. Cooper's data shows that the number of geese around the airport are being kept at a level of 95%+- below that of 1984." (11)

If geese are a problem in the summer months, why are they not a problem during the seasonal Arctic migration? Are you planning to kill those geese too?

Alternatives 1, 2, 3, and 4, pages 18-35, are all essentially the same. Current Program Alternative already involves killing geese and much more would have occurred in 1998 had it not been for the suit against USDAWS (ADC) Virginia by Citizens for the Preservation of Wildlife and the Humane Society United States. The difference between the Alternatives 1 and 3 is described as "The Current Program uses lethal control sparingly, and only in instances where human health and safety are threatened. This alternative (Non-lethal methods first) requires that all non-lethal methods must be exhausted at each damage location before lethal control is used. There is no human health and safety restriction on lethal control under this alternative (Non-lethal first)." (p. 30). So, under the Alternative 3, geese could be killed for pooping.

"However, the important distinction between the Non-lethal Methods First Alternative (Alt. 3) and the Current Program Alternative (Alt. 1) is that the former alternative would require that all non-lethal methods be recommended or used before any lethal methods are recommended or used. " (p. 17). The careful wording suggests that USDAWS (ADC) could use lethal methods after only recommending (but not using) the non-lethal methods. This suggests that USDAWS (ADC) while sorely lacking in their ability to gather and analyze data and do a scientific study, is very good at crafting words to make it legal to do whatever they want to do.

Alternative 2 Non-lethal and Technical Assistance only Alternative claims that homeowners would take the matter into their own hands (no evidence is provided) if implemented. US Fish and Wildlife Service already has a remedy for that - federal prosecution. If USDAWS (ADC) has information that illegal actions have been taking place, they should document and show their reports to USFWS for prosecution.

Alternative 2 also allows some lethal control. The authors do not acknowledge or are ignorant of the fact that a federal court has ruled the use of the special permits not legal in these instances.

Alternative 4 Expanded Program Alternative: "Under this alternative WS would possibly remove up to 3,500 geese from the 12 county area surrounding Puget Sound area (Figure 1) in the first year." So according to Figure 1 estimate of the population, USDAWS (ADC) would remove one quarter of the population of Canada geese in Puget Sound. The document does not say what USDAWS (ADC) is allowed to do in subsequent years. The document does not address the question of killing of juveniles. Does the program under any alternative allow the relocation of juveniles before they learn to fly? This is an important omission.

Alternative 2 and Alternative 5 (No Action) both claim that there would be greater inhumane treatment of geese by renegade and illegal actions by homeowners if they are not allowed to slaughter 3,500 in the first year. Are they suggesting that homeowners are using butcher knives or paddles to kill these geese, in the face of USDAWS (ADC) claims that the geese themselves are threatening to the homeowners?

USDAWS (ADC) also claims (p. 27) that under the Non-lethal Methods only individuals implementing control methods may pose a greater possibility of affecting non-target, Threatened, and Endangered Species. They do not explain how this could happen nor do they document any occurrence. Federal prosecution is always available for these illegal actions.

USDAWS (ADC) fails to mention the previous failure of lethal action to keep geese away from the parks at Clarkstown, NY, and the subsequent success of the use of border collies and other non-lethal methods.(12)

Cumulative Impacts: Figure 3 (p. 35) describes the projected population growth for the Seattle area, said to be based on Ettle (1993). Cooper and Keefe (1997) cited elsewhere in this document, address this issue, but the authors of this EA do not address it. Cooper and Keefe made a similar projection of "exponential" increase in the goose population in Minneapolis. They claim that their program (relocation, non-lethal methods and hunting) dramatically reduced the population around Minneapolis prior to the massive slaughter programs instituted in 1996. Why did the EA authors not discuss Cooper and Keefe's claims?

There are three alarming oversights in this document.

Humane trapping and slaughter. Under the "Impact of the Current Program Alternative (p.18) USDAWS (ADC) claims that humaneness refers to different perceptions of harm or pain inflicted on an animal and that some people may see it differently (p. 18). The author cites Robert Schmidt, 1989, and Alice Wywialowski, 1991. While both of these references were written almost a decade before the EA discussion of massive slaughter of Canada geese, the references themselves suggest that USDAWS (ADC) has not given any consideration of the perspective of the animals themselves. Schmidt and Wywialowski do not in any way represent any animal rights constituency. Schmidt is a wildlife professor and most recently on an ADC paid sabbatical to interact with the animal rights activists. Wywialowski represents USDA APHIS Policy and Program Development. There is no discussion of the trauma and dislocation suffered by the Canada geese in the decades of relocation. There is no discussion of the trauma of trapping and death in slaughterhouses.

There is no description of the slaughterhouse process that would torture and kill these 3,500 geese. It takes a great stretch of imagination to see how the trapping, separation of geese from offspring and mates, confinement in tiny quarters, slitting of throats, hanging of the geese by their legs, removing feathers and immersing in scalding water before all are dead can be seen as a humane process. Clearly, there is no way in which this is any way humane by any definition. It is only in the fantasy and deception world of USDAWS (ADC).

USDAWS (ADC) cites Berryman, 1987, as saying that it is "painfully clear that public decisions, prompted by the animal rights movement, are disrupting sound, professional wildlife resource management programs..." To what could they be referring in 1987? The slaughter proposals of Canada geese did not emerge until mid 1990s.

Food Bank program. A second omission is any discussion of the USDAWS (ADC) plan to feed the geese to the homeless and hungry of Seattle/Puget Sound area. Their treatment of this important subject is left to two sentences in the section "Capture and Euthanasia" (page 15): "Geese suitable for human consumption are donated to qualified charitable organizations whenever feasible. Geese found to be unsuitable for human consumption and geese taken under circumstances where donations are not feasible are buried or incinerated." Two years ago, Seattle food banks refused to take the geese when they learned of the political implications of this charitable donation.

There is no discussion in the proposed plan of how determination would be made about the suitability of the dead geese for human consumption. In New York, following the slaughter of several hundred geese destined for human consumption, the game agency discovered high levels of lead.(13)

Dr. Warren P. Porter, Professor and Chair, Department of Zoology University of Wisconsin, and Professor of Environmental Toxicology, commenting on the Cooper and Keefe "study" of the potential for contamination of Canada geese said "After reviewing 'The Potential Health Hazards of Consuming Metropolitan Twin Cities Canada Geese' article by James Cooper, I find no evidence that the geese are necessarily safe for human consumption. If they are consuming and storing golf course herbicides listed in Cooper's document (Dicamba, Diquat, Glyphosate, Mecoprop, Paraquat and 2,4D), their fats should definitely be checked for these compounds, the contaminants that co-occur due to manufacturing processes and the 'inert ingredients' that are added to promote dermal and lung absorption of the compounds' I say this based on broader concerns than cancer risk. Specifically I have added concerns about potential neurotoxic effects (1,2,3), reproductive and developmental effects (suppression of tissue growth and lesions in fetal hearts) (4,5,6) and mutagenic effects (7,8,9,10,11). As far as I can determine there is no information on possible fat contamination by a number of herbicides, especially dicamba and its contaminants, 2-7-dichlorodibenzo-p-dioxin (manufacturing contaminant tied to non-Hodgkin's lymphoma in farmers two decades after exposure (1,2) and dimethylnitrosamine (a powerful carcinogen present in the dimethylamine salt of dicamba, the form used by at least two of the major lawn care companies nationally). Dicamba products can also be contaminated with up to 20% of 3,5-dichloro-2-methoxy benzoic acid, an isomer of dicamba. This isomer is retained longer than dicamba in the bodies of laboratory animals." (14)

If the geese are to be distributed to the poor (already at a nutritional and medical disadvantage), all the geese must be tested for all of these toxic chemicals. Since USDAWS (ADC) is claiming that the geese are residents and stay on parks and golf courses, there would be by their own claims, very high risk of being contaminated by toxic chemicals. The Expanded Program Alternative offers no means of assuring the vulnerable poor that they are not being used in a public relations pawn to make this goose slaughter palatable.

It is ironic that USDAWS (ADC) makes repeated and fraudulent claims about health hazard to the public while it plans to inflict the contaminated geese to the poor.

Costs of the program. Finally, there is no discussion of how much citizens and taxpayers are going to have to pay for this action, not counting the administrative time already spent in the last ten or more years. Documents recovered under FOIA found that killing of up to 200 geese at Fisher Mills cost the company around $3,032 ($15 per bird).(2) Removal of 6 geese at the Madigan Army Medical Center cost $150.00 ($25 per bird).(2) It appears that this 3,500-goose-slaughter could be expensive. It appears that the cost for one year alone would be from $52,500 to $87,000 not counting the toxic testing. Even a conservative estimate of toxic testing could be well over one million dollars. What will be the cost to citizens of court suits if poor people are hurt or their health (or that of their children or fetuses) is impaired? Who will pay is not discussed (though much of this would fall back on the taxpayer); who would benefit is clear: USDAWS (ADC). USDAWS (ADC) has been looking for other ways of keeping their untenable bureaucracy going. For two years, there have been major challenges to their budget by Congress. Clearly, this is a fund raiser for USDAWS (ADC).

This Environmental Assessment should be scrapped. Taxpayers have spent a good deal of money with no apparent scientific analysis of the situation. If there is intent to pursue this, an Environmental Impact Statement should be ordered.

The Alternatives 1-5 leave citizens with no alternative. If there are problems of "goose poop", let it be documented. Similar claims were made about duck poop by ADC at Melrose Court, Neenah, in 1995, but outside observers found no such evidence. (See Environmental Assessment USDA APHIS ADC EA, 1995). Because of the lack of scientific data, that Environmental Assessment was scrapped and ADC withdrew from the plan.

If USDAWS (ADC) intends to pursue this action, then the study should include at a minimum:

History and nature of previous relocations of Canada geese and their impact on the present population.

--How long have the Washington State game agencies been propagating Canada geese? How long have they been relocating Canada geese and how might this be part of the situation in the Puget Sound? Surely there are substantial records on these relocations. Michigan, for example, has relocated 42,000 Canada geese from the early 70s through the 1990s (MI DNR Annual Report 1996).

--History and nature of introductions of Canada geese, including the state game agencies and their cooperating conservation groups.

--History and nature of "lure" planting by game agencies and their cooperating conservation groups.

--History and nature of the impact of "lure" fields on the population of snow geese, vultures, and other waterfowl that are now said to be a problem elsewhere.

--History and nature of hunting in and around Puget Sound. While this document infers that the reason for the increased population is due to lack of hunting, it may be that hunting outside the area is responsible for an increase in population within Puget Sound.

--Policies of the Flyway Councils (made up of game agency representatives, USFWS, state game agencies, etc) to increase the population of birds that could be hunted. The failure to increase birds in the hunting areas and the reproductive losses in the Arctic should be examined in light of Flyway Council objectives regarding Canada geese and other migratory birds. There is a hint of an underlying motive which has surfaced in other communities (Wisconsin and Minnesota, for example) that urban hunting is a game agency objective.

--The relationship between the "locally nesting geese" in light of evidence that the molt migration may result in food taken from the Arctic population, or that there is inter breeding between the molt migrants and the Arctic population either to their detriment or to their benefit. You should assess the relationship between the continued relocation of goslings, such as in Minnesota in conjunction with their slaughter of adult birds.

The ecology of the present situation including:

--Present efforts to increase population in Wildlife Management Areas (WMA) and hunting areas through propagation, enhancement of the environment through mowing, planting of grasses and grains, and other techniques.

--The cost of these efforts to increase the population of locally nesting Canada geese for hunting and the cost to taxpayers (through federal and state taxes and other funds.

--Park to park comparisons to determine why geese are in one park but not in another.

--The experience of states which have conducted mass slaughter of geese. Jim Cooper claims to be researching this question in conjunction with his slaughter of adult geese and relocation of juveniles.

--The impact of gosling relocation programs in light of the claims by Canadian cities (Mississauga, 1997, 1998) of molt migrants (see Ankney's claims) landing on their shores. Minnesota has relocated goslings recently to South Dakota, which has claimed that it has problems with geese. Kansas is still relocating goslings for their hunting programs, while neighboring Smithville, MO, argued they should be allowed to have urban hunting to control their numbers).

---The definition of "resident" should be examined. What is USDAWS (ADC)'s evidence that the locally nesting geese do not migrate? What is the evidence that if they kill some geese at Juanita Beach that there will be no geese at Juanita Beach? This is particularly important in light of assurances that there would be no significant impact on the total population of Canada geese. The assumption that there will be the same number of Canada geese overall but that the Puget Sound area will have a reduced Canada geese is based on the geese being non-migratory, a claim that is not proven here.

--The relationship between the presence of Canada geese and the presence of "gulls" (presumably ring tipped gulls), ducks, mud hens (#143). Why is USDAWS limiting the scope of the Environmental Assessment to Canada geese? Are you planning to broaden the scope at the last minute as Wisconsin did in their "Urban Waterfowl Task Force" (The discussion was entirely about Canada geese, but the final resolution to kill, as amended by the game agency staff, was changed from Canada geese to "waterfowl"). What is the relationship between the large number of Canada geese and snow geese which are said to be a problem for which the solution is increased bag limits?

--The effects on the Canada goose families and communities of these killings.

--The criteria and evidence of humaneness in these alternatives.

Partializing and isolating the situation from its larger context, avoiding data from other Canada goose slaughters, creating indefensible definitions, avoiding examining the relationship between the increase in other bird populations and the increase in the Canada goose population, making claims that Endangered and Threatened species will not be affected is an attempt to avoid conducting an Environmental Impact Statement. It is not defensible.

Should USDAWS (ADC) proceed to adopt their "humane" killing program, the Coalition to Protect Canada Geese will ask for documentation on the capture and slaughter-house procedure in the form of videotape and organizational observer status for their documentation on humaneness.

Should USDAWS (ADC) proceed to adopt this plan, each goose carcass must be tested for all potential herbicides, not to mention mercury and PCBs. Food Banks should be alerted to the potential for health hazard to the poor and the poor must be notified of that health threat. Follow up studies must be conducted and treatment services offered. Funds should be set aside to fight court suits for damages must come directly from USDAWS (ADC) budget, including court costs to defend ADC and to represent the plaintiffs and including damages awarded to plaintiffs.

Should USDAWS (ADC) proceed to adopt this plan, all revenues should be returned directly to the US Treasury. The agency should not be allowed to use this to keep an archaic and often-criticized agency in business.

Once again, I ask for a sixty-day extension on your Environmental Assessment. The public has not been adequately notified about the intent of this proposal.

Once again, I ask you to post this document on the USDAWS (ADC) web page so that citizens may be advised of the quality of this document.

Please send me a copy of your final report.

Sincerely,

Ann Frisch, Ph.D., National Coordinator