Ms. Karen Laing
U.S. Fish and Wildlife Service
1011 East Tudor Road
Anchorage, AK 99503

The comments submitted herein are in response to the "Draft Environmental Assessment, Canada Goose Population Management in Anchorage, Alaska, U.S. Fish and Wildlife Service September 1997".

"Introduction" (page 2-3)

It is duly noted that the AWWG from which recommendations were solicited represents a wholly biased ensemble of interests: none of the participating groups represent "stakeholders" whose concern is the welfare of geese themselves.

The Alaska Department of Fish and Game, the U.S. Fish and Wildlife Service and Wildlife Services of the Animal and Plant Health Service are agencies whose general philosophy is that wildlife conflicts, especially those involving species managed as living "targets", should be addressed using lethality.

The Municipality of Anchorage, Elmendorf Air Force base, Fort Richardson Army base, Anchorage International Airport, Merrill Field Municipal Airport and the FAA represent interests with an administrative tendency to accept, rather than challenge, conclusions made by government agencies.

Local Audubon Society chapters are highly political and precedent shows that they can not be relied upon to adequately challenge the wildlife management establishment's philosophy of lethal control.

"I. Need for Action" paragraph 3 (page 3)

It is stated that; "In modern times, hunting usually exerts a limiting influence on goose populations by removing adults, but Anchorage geese are subject to little harvest [killing] throughout their range.........."

This is the classic wildlife management contradiction. Current wildlife management practices are designed to optimize - not reduce - populations of target species, and in turn create economically lucrative "sport" hunting opportunities. Such hunting-biased management is intent on maintaining elevated wildlife populations that bring revenues into state wildlife agencies. Local wildlife controversies are the platform upon which such agencies stand to seduce the public into thinking that, "things would be better if only there was more hunting." In reality, the goal is to offset a declining customer base of hunters and the impact that has on the economy of their (the agencies) wildlife killing business by introducing hunting into more human-populated areas. In this light, it is disingenuous of the DEA to suggest that Anchorage's Canada goose "problems" are due to a lack of "modern hunting." Indeed, it is more likely that the opposite is true.

It is stated that "Anchorage geese have learned to stay away from hunted areas....."

This statement implies that hunting in areas surrounding Anchorage may be aggravating the situation in Anchorage. Common sense dictates that hunting will cause unnatural, uneven and possibly undesired goose population distributions. Hunting is forcing geese from areas where human conflict is minimal or non-existent into more human-populated areas throughout Anchorage.

This behavior has been observed at the Alcoa plant in Masena, New York, where plant officials had successfully implemented non-lethal control tactics to keep geese out of industrial waste water treatment lagoons. Data in a report issued in 1992 by Northern Ecological Associates shows quite clearly that once regional goose hunting season started, waste water areas were inundated with geese and other waterfowl.

Paragraph 4 (page 3):

It is stated, "Exponential growth is common for resident goose populations that have colonized protected urban habitats and are not subject to harvest [killing] (Appendix A)."

The use of the term "exponential" continues to be used liberally by wildlife managers discussing increases in Canada goose populations. It would appear that the word "exponential" is being used to scare the non-mathematical public into feeling that something drastic must be done, namely killing. The implication is that if something is not done, we might wake up one morning to a situation reminiscent of Alfred Hitchcock's movie "The Birds". The fact is that nowhere in the country has this oft-cited "exponential growth" been shown to occur at a particularly high level or proceed in an open-ended fashion. In Rockland County, New York, when a controversy surrounding Canada geese started in 1993, there was much talk of "exponential" population growth despite the fact that between 1993 and 1995 the population was declining (in the absence of any lethal actions other than egg addling).

To make their point, the authors of the DEA have chosen to adopt the simple but erroneous view that no limiting factors exist within Anchorage to inhibit growth of the goose population. This is a biological absurdity which casts suspicion on the motives of those who invoke it. Are we to believe that Anchorage, while defined by measurable boundaries, is at the same time of infinite dimensions and resources? Alas, there is not an unlimited amount of goose habitat nor an ever- increasing number of nesting sites, no guaranteed goose-optimal weather patterns, nor a decrease in the territoriality of geese that moderates their nesting density.

To blame goose populations on insufficient "harvest" is just an example of rote perpetuation of the false notion that modern hunting, in all of its management-intensive artificial glory, has some sort of magical ecological balancing effect. Ironically, "goose problems" are not inversely correlated with areas/states where goose hunting is intense.

It is remarkable that in a DEA so wholly obsessed with population, that no detailed Anchorage goose population survey data were provided. Such data are hardly a luxury in a document whose premise and proposed actions are based on population. Instead of presenting information on how population data were collected, the DEA presents anecdotes from various parts of the country with no attempt to correlate them with any specific findings in Anchorage. Suspicious by its absence was information on: 1. the methods used to determine the total number of geese at any given time; 2. the calendar dates when the counts were taken; and 3. the methods of extrapolation used if and when full counts could not be made.

When it comes to Canada goose populations, there is a solid track record of inaccuracy. In 1993, officials claimed that there were between 10-12,000 Canada geese in Rockland County. Counts taken later that year by the NYS DEC and the Audubon Society revealed that there were only about 3000 geese. In 1996, the USFWS proposed changing the permitting process for the control of "injurious" Canada geese. A DEA was issued toward this end (Fed. Reg. Vol. 61, No. 171: 46431, Sept. 3, 1996). In Appendix C of this document there were exhibited Canada goose population data from various regions in the Mississippi Flyway. The striking feature of most of this data was the enormous margins of error - sometimes approaching 100%!

"Current Management Problems due to Increasing Numbers of Geese"

"Safety and Health Concerns" (page 5)

This section contains a series of weakly supported or altogether unsupported allegations regarding the impact of geese.

1st bullet point (page 5):

The death of 24 people in the AWACS crash in 1995 was an accident. A very rare, freak accident. It is stated that "Numerous non-fatal, yet costly, bird strikes are encountered annually..." "Numerous" is insufficient language upon which to launch a deadly goose control strategy. First and foremost the term "bird strikes" includes birds other than geese. Further, it is stated that, "Nationally, aviation experts predict a 25% chance of a catastrophic crash due to ingestion of birds into engines in the next 10 years." As a point of fact, only ONE aviation "expert" (Todd Curtis) has made such a prediction. Even if such a prediction is accepted as accurate, he did not say that there is a 25% chance that geese would cause a fatal crash; the word used was "birds." Therefore, the chance that such a collision would be due specifically to geese would be reduced by the number of species residing in the vicinity of the airfield. The fact is that most fatal aviation accidents are not caused by birds, rather they are caused by human error and mechanical failure.

2nd bullet point (page 5):

Traffic Hazards: The claim that "Urban geese cause vehicular hazards on highways and roads..." is unquantified and therefore of indeterminate scope. This category of concern indicates a certain level of desperation in identifying reasons to take lethal actions against geese. In the broad view of traffic safety, collisions between geese and automobiles do not result in significant damage to the vehicle or its occupants. In citing data on injuries to geese rather than data on the extent to which they significantly increase hazards to vehicular traffic, it would appear that this "concern" is more an attempt to argue that the welfare of the birds themselves is cause for action. It is disingenuous to propose that thousands of geese be killed in order to protect them from injury or death on roadways.

The Anchorage Wildlife Survey reports that 3% of those queried actually hit geese with their vehicle. If this were taken as the number of collisions that respondents had with geese in the past year, it would correspond to an average of about two geese being struck per month. However, it is impossible to apply the one-year restriction because Question 1 of the survey (as presented in Appendix C) fails to specify a time frame upon which the experiences are being surveyed. It is likely that these collisions took place over varying numbers of years, reducing a low-level occurrence even further than the survey numbers would suggest.

Motorists swerve in response to obstructions that unexpectedly appear in the path of their vehicle. Since it was pointed out that most goose/vehicle encounters occur during the brooding season, it is safe to say that the geese causing motorists to swerve are actually walking onto the roadway, not landing on it. Since geese generally walk slowly and do not run unless chased, these motorists must either be driving faster than conditions warrant, and therefore are not in control of their vehicles, or are failing to abide by one fundamental tenet of defensive driving: anticipate potential hazards by surveying the road ahead. If anything, the issue here is that of poor driving habits or inadequate enforcement of traffic laws. Proposing to kill thousands of geese because some motorists are driving too fast, or are impatient, or inattentive to their surroundings, or had to "brake" is irrational.

3rd bullet point (page 5):

Individuals who purposely kill migratory birds such as Canada geese with motor vehicles are in violation of state and federal law. Have these occurrences been fully investigated by the Service?

By citing these occurrences in the "Current Management Problems...." section, the authors are implying that the intent of the proposal to kill geese is to protect them from being killed illegally by deranged motorists.

Canada geese and fecal droppings (middle of page 5):

On the last page of Appendix B it is stated that, "It is clear that people enjoy having Canada geese in the city, but they are concerned about public safety and to a lesser extent, droppings and other health or nuisance issues." Despite the fact that the public is concerned mostly about air traffic safety, it is ironic that the "Current Management Problems...." section devotes three-quarters of its discussion to health and nuisance considerations.

There seems to be some (dubious) discrepancy regarding how many pounds of fecal material is produced by a goose per day. State waterfowl managers in New York have been saying for years that Giant Canada geese produce a pound of droppings per day. In the DEA under consideration it is asserted that the smaller, lesser geese produce three times as much - a number that defies common sense and seems to have been exaggerated so that it could be further stated that a frightening 12,000 pounds of goose droppings are produced each day. Such calculated accumulations are apparently not consistent with the observations of those who responded to the survey, since droppings were determined to be a concern of "lesser extent"relative to other factors.

From a scientific standpoint, the manner in which fecal matter weight is presented in the DEA is very manipulative. Goose droppings are greater than 80% water. It seems that the authors of the DEA were straining to make a compelling case for the killing of geese knowing full well that the public would not be moved if it were said that goose droppings are only about 3.2 oz dry weight/pound.

4th bullet point (page 5):

Goose droppings do increase nutrient levels in bodies of waters they occupy. This is a natural phenomenon, and biological mechanisms exist to process such infusions. That nutrient addition "can" cause algal blooms doesn�t say anything definitive about the Anchorage situation, nor whether geese are even responsible for such conditions. This is a speculative assertion and does not add justification to the proposal to kill geese. In most suburban areas where eutrophication is studied in detail, it can be traced to chemical fertilizer runoff from turf grass-intensive landscaping and agriculture. It is to be inferred from the absence of references to studies on eutrophication relevant to the Anchorage area that none exist, particularly none that implicate geese.

5th bullet point (page 5):

Goose droppings contain fecal coliforms. However, the relevance of this statement is unclear. It certainly does not provide rationale for killing geese, because this claim is true of all forms of wildlife whose fecal coliforms are washed into rivers and lakes, etc., after every rainfall.

6th bullet point (page 5):

The underlying assumption regarding geese and the fecal coliforms they contribute to swimming lakes is that fecal coliforms are pathogenic. This is a fallacy. Fecal coliforms are indicator organisms and they are not of health concern themselves. It is critical to note that the fecal coliform count method determines health risk by implication not direct measure. The underlying assumption in applying the fecal coliform water test is that these coliforms are often accompanied by harmful bacteria; this assumption is not always correct. In the case of Canada geese, the assumption is wrong. In fact, if it is found that geese are the primary cause of high coliform counts, this is good news for humans because studies at a variety of institutions (Harvard University Medical School/Boston University, NYU Medical School, Johns Hopkins University, etc.) have shown that the fecal matter of Canada geese rarely contains human disease-causing bacteria. On the other hand, if fecal coliform counts are due to human waste, a major health threat exists, since it is common for human excrement to contain pathogens that seriously affect humans. The state and federal standards of water quality operate on the assumption that the fecal coliforms come from species (such as humans) that are known to carry human pathogens. The truth is that the presence or even increase of goose numbers has little bearing on any public health threat. To insure the safety of water, more sophisticated methods of pathogenic bacterial measurement will be required, NOT the killing of geese.

7th bullet point (page 5):

Blaming Canada geese for "swimmers' itch" is like blaming lung cancer on ash trays. Dr. Milton Friend, infectious disease expert, USFWS on "swimmers itch":

"Recognize that swimmers' itch is an accidental situation when you get infected..... basically what happens is you've got a symbiotic parasite relationship. At the intermediate stage of this parasite's [life-cycle] it's swimming out there in the water, after having come out of snails. So if you want to go after swimmers itch, go after the snails, leave the geese alone. Because geese are only one of many hosts; any birds or mammals may participate in the life-cycle. Once it [the parasite] is in the water and the snails get infected the snails stay infected and you cannot control it by going after any species of animals."

[From the transcript of a presentation given in Rockland County, NY 9/22/93]

No evidence is presented to suggest that the parasite for swimmers' itch even exists in Anchorage.

It is stated that high concentrations of goose fecal matter in lakes, ponds, etc., is linked to, among other things, an increased health risk to other waterfowl and wildlife. This may be true in general, however, no supporting information is provided to support the suggestion that such extreme conditions exist in the areas in question. Once again the bizarre implication emerges that geese should be killed to protect them from unsubstantiated circumstances.

"Property Damage and Nuisances"

"Dense concentrations of geese trample and destroy lakeside vegetation."

1st bullet point (page 6):

This assertion is vague. What constitutes "Dense"? What is meant by "plant cover"? Are the authors implying that native species of lakeside flora are in jeopardy? Since there is no supporting information such as plant inventories of the affected area, it is safe to assume that "plant cover" in this context is just a euphemism for turf grass or other non-native, ecologically irrelevant, species. Further, there is no documentation indicating the extent of erosion or measurements regarding turbidity. If the situation in Anchorage is like other areas around the country, this item appears to be an attempt to make a pseudo-technical case for the reality that some waterfront homeowners are upset by the impact of geese grazing on their lawns.

2nd bullet point (page 6):

If the city's playing fields are "now covered with goose feces," it's because of poor landscape design and the failure to implement non-lethal goose dissuasion methods in the affected areas. The fact that 46% of survey respondents report "using fields covered by goose droppings" is not particularly significant, since such a statistic has neither frequency nor time period associated with it.

"Hand-feeding waterfowl contributes to health and safety problems....."

While hand-feeding may make geese less wary of people, it can hardly be attributed to the whole host of other problems implied (especially since most are unsubstantiated). Why would hand-feeding geese make them less wary of cars and aircraft? Are pilots really dispensing food from the cockpit?

3rd bullet point (page 6):

If hand-feeding geese is impacting the effectiveness of goose control efforts at airfields, the nature of the control program must be called into question. It is ridiculous to shoot geese because "safety personnel" are ill-informed or ill-equipped on the proper use of goose scare tactics.

4th bullet point (page 6):

The solution to "roadside feeding" and the attendant traffic delays, accidents, etc., is the enacting of an ordinance banning such feeding. To suggest that thousands of geese should be killed because PEOPLE are acting irresponsibly is an indisputable case of punishing the victims (waterfowl that are injured or killed by motor vehicles) and their relatives, rather than those willfully causing the condition in the first place. [It is noted that "accidents" is mentioned here as distinct from collisions between vehicles and waterfowl. No reports are cited showing that either vehicle/vehicle or vehicle/pedestrian accidents were caused by geese and therefore the statement must be taken as suppositional musing.]

5th bullet point (page 6):

"Geese which have been concentrated by feeding deposit more droppings and destroy more vegetation in one spot...." This statement is vague but implies that if feeding was allowed in areas where the presence of geese is not controversial, it would alleviate conflict in areas where their presence is an issue. This management option was not even mentioned.

6th bullet point (page 6):

The primary source of food that attracts waterfowl to parks and establishes regional populations is turf grass, not hand-feeding. No hand-feeding takes place on golf courses, yet they are favorite grazing sites for geese. Conversely, a park without turf grass will at best only attract the occasional goose. In this point there is a not-so-subtle attempt to link hand-feeding to population, and in turn to concern over human health and water quality. As explained above, these are ill-founded and unsupported "concerns." Those who believe that drastic action needs to be taken against geese should have their misconceptions dispelled, not reinforced. Unfortunately, the USFWS and the ADFG are willfully disseminating information in a highly suggestive and misleading fashion.

7th bullet point (page 6):

How do people's concern for the welfare of waterfowl in cold weather qualify for inclusion in the "Property Damage and Nuisances" section? The title of this section implies that the "nuisance" being discussed is caused by geese directly to the public. Who might have expected that the term "nuisance" included "resource agencies" being annoyed by citizens calling to express concern over the welfare of waterfowl in their parks? This nuisance to resource agents could be avoided if the agencies dispelled the misconception that they care about wildlife beyond managing it for regulated killing. The public probably would not appreciate this truth, but it would go a long way to easing the nuisance arising from this misunderstanding. Of course, the alternative would be that the agencies in question change their philosophy and protect wildlife in the true sense of the word.

8th bullet point (page 6):

It must be noted that two-thirds of the "Property Damage and Nuisances" section deals with hand-feeding. It is obviously the intent of the authors of this DEA to shift the blame for goose-related complaints onto those who enjoy seeing and interacting with (feeding) geese. This is a subtle way of accusing those who care about geese as being part of the problem. The fuss over hand-feeding is being used as a smokescreen to distract attention from the more biologically relevant factors influencing regional populations of Canada geese. Such sideshows are effective in directing attention away from wildlife agencies who have been completely uninvolved in providing proactive input into the landscaping design of public and private areas where conflicts involving wildlife might arise.

Final comment (page 7):

Clearly, the USFWS and ADFG believe that the opinions of those who complain about geese have higher priority than those who care about the welfare of geese. This can be traced to the operating philosophy of these agencies which relies on justifying the expansion of economically lucrative wildlife killing (sport hunting and trapping) by claiming that it is necessary to "manage" and control populations. Of course, this is circular logic because in order to generate substantial revenues, wildlife populations need to be maintained at levels that irritate the public and create the illusion that more recreational killing is necessary. Overall this section failed to substantiate the asserted notion that "The rapid increase in management problems with geese over the last decade.....justifies the need for a goose management plan in Anchorage." The phrase "management problems" is quite bizarre, since very little active management has been done in the last 10 years. It would appear that the USFWS and ADFG sat by idly and watched as the present situation unfolded. In light of this failure to exercise due diligence regarding non-lethal strategies, it is unacceptable to proceed with any proposed plan of mass destruction.

"III. Scoping/Public Participation" (page 7)

It is clear that the two surveys provided in Appendices A and B were designed to validate a preconceived plan of action. To avoid conflict with the forgone decision to implement the massive killing option, no statistical associations were built between those respondents who said there were too many geese and the all important WHY they felt this was the case. This connection is key to developing an effective management plan. For example, if, as the DEA suggests, "aircraft safety was of paramount importance to people", halving the number of geese throughout Anchorage doesn't make sense, since the primary area of management should be focused around and adapted to the airfields in question. Since geese generally congregate in flocks in the areas they use, the statistical reduction in the chance of a serious collision between aircraft and geese would be minuscule by reducing the regional population.

Further, too much emphasis was placed on what management options would be "acceptable" to the public, rather than what options would effective. Effective minimization of bona fide hazards is a matter of understanding biological phenomena, examining relationships between cause and effect, not by taking a vote of the public to see what the most drastic action is that they will tolerate.

Other problems with the survey analysis include:

1. The first survey represents an extremely small sample size relative to Anchorage's total population. The second survey is not considerably better, representing a sample only 2.7 times larger.

2. Inadequate sample sizes notwithstanding, no explanation was provided on why the opinions and beliefs of the public would be relevant to the practical issue of resolving the "problems" that geese were alleged to cause. Presumably, those who said there were "too many" or "way too many" were basing their assessment on some-site specific personal experiences. For example, people who feel that there are too many geese in their favorite park will be inclined to expand this belief into a broader conclusion that encompasses all of Anchorage. Indeed, by asking, "How many geese would you like to have in Anchorage?" the survey leads the respondents into what was apparently a foregone conclusion of the surveyors, that conflicts with geese would best be dealt with by altering the overall population. This plants in the mind of those queried, without justification, the idea that broad-based massive lethality is the only management strategy worth considering.

It's interesting to note that those surveyed were given only one specific population reduction choice, "Half as many as we have now." Since this corresponds to the same goose population target proposed by the DEA, we can conclude that surveys were designed to give rise to this particular answer.

3. That survey respondents preferred actions to reduce the goose populations that would afford public benefit (e.g., hunting, egg harvesting) is irrelevant to whether the proposed actions themselves are warranted or based on sound biology. These questions were designed to shift the focus of concern away from issues of efficacy, to further reinforce the foregone conclusion that the massive killing of geese was a must, and to pacify those whose conscience might be bothered by "waste" or killing out of unsubstantiated necessity.

4. By means unclear, the AWWG "...agreed by consensus that a level of 2,000 geese represented a balance between safety concerns, humane concerns for geese and human interests to watch geese in the city...." Further, the USFWS is said to support this consensus. From what has been presented in the DEA, this consensus appears to be a mutual guess as to the most drastic sort of plan that can be perpetrated with some level of public acceptance, nothing more.

Killing 2000 geese is a substantial action. Exceptionally substantial in light of the fact that the authors of the DEA have failed to raise "safety concerns" beyond the level of mere "concern." With the exception of one tragic plane crash, documentation pertaining to geese as a safety issue in Anchorage is seriously lacking, based on inappropriate analogy, or unconfirmed mathematical models. Further, to argue that killing 2000 geese is in any way related to a "humane concern" for them is ludicrous. Again, the reader is asked to support killing thousands of geese to protect them from being injured or killed in accidental events. The truth is, it is more humane to let them live and take their chances. [Clarification: "taking their chances" here is not referring to air traffic safety.]

Neither the AWWG nor the USFWS seems to have any idea what the practical significance of reducing the number of geese to 2,000 might be or why this represents a balance. This number appears to be completely arbitrary. If one assumes (and one must, since no studies suggest otherwise) that reducing the number of geese by half will uniformly halve the number of geese throughout Anchorage, how will relief from the "problems" caused by geese be manifest? Does the USFWS think that a homeowner with 20 geese grazing in his/her yard will be satisfied with 10? Unlikely. If someone was upset by 4 geese in their yard they are obviously so intolerant that even 2 or 1 might be too many!!

Since many of the arguments being advanced to kill geese concede that human behavior and perception are the root cause, this would seem to be where management efforts should be focused. The DEA and previous efforts (surveys, literature, etc.) have clearly been attempting to steer public thinking into the extermination mode. While it would be decidedly new territory for the Service, why not direct efforts away from such thinking? Why not enhance public appreciation for geese through education? That the attitudes of complainers, and those holding real but unjustified fears, are validated rather than challenged is an arbitrary, destructive position with no clearly defined practical purpose - except to make the agencies charged with this project appear as if they are doing something useful.

"IV Affected Environment"

"Biological Environment"

"Geese" (page 9)

It is acknowledged in this paragraph that physical changes to the Anchorage region have made conditions suitable for the lesser Canada geese to prosper; by implication, long-range moderation of their population will require addressing this cause. Use of the word "exploding" in the following line: "The presently exploding population in Anchorage is composed of lessers," is highly subjective and should not be used in a document attempting to appear factual in nature. This basically confirms that, in the language of the surveys, the DEA was authored by those who feel there are "way too many" geese. Hence, bias is revealed.

"Social and Economic Environment" (page 9)

In this section it is conceded that turf grass-intensive landscaping practices throughout Anchorage have, in combination with created lakes and the encroachment of development onto existing lakes, "increased goose habitat in the city." With this being the identified cause of elevated Canada goose numbers, it is surprising to see landscape management relegated to a relatively low-level action item compared with massive killing.

In paragraph 6 it is noted that numbers of geese grew until "they began destroying lawns and displacing other waterfowl." Biologists in the USFWS and ADFG might recognize this "destruction of lawn" as nature's way of moderating population by diminishing the food supply (lessening the amount of edible turf). This basic lesson should be the starting point for conflict resolution, not mass destruction. Nature abhors a vacuum.

Another cause for the current situation is suggested in paragraph 7, where it is noted that wildlife agencies "have little time to help other than offer advice." Presumably these agencies have too little time to help because there was no fiscal incentive. If these agencies spent less time on special interest, economically lucrative, count-and-kill management (hunting, trapping, etc.) and spent more time anticipating wildlife conflicts by proactively advising developers, city planners, homeowners, etc., most problems could be avoided in the first place.

"V. Alternatives" (page 10) paragraph 2

Comments on the concepts behind alternatives B-E:

1. There is no biological theory to support the belief that the population growth rate of geese will continue indefinitely at 12% if no action is taken.

2. Removing geese, whether all at once or over 5 years, is a symptom-based solution and therefore will not mitigate goose-related concerns. Other geese from surrounding areas will fill the available habitat thereby setting the stage for more and more killing (i.e. Minnesota).

3. "Limiting effect" refers to factors that regulate future population growth; since eggs produce geese, egg management should have the greatest limiting effect. Further, removing geese will simply draw other geese into the newly-vacated habitat.

4. Yes, killing geese is not a biologically sound solution (see 2 above) and will exact long-term financial and ethical costs while having negligible practical effect.

"Humane Concern for Geese" (page 11)

It is in this section that the authors confess that goose distributions can "be controlled using these [non-lethal] methods alone," but sour the statement by saying that "people are not willing to give up golf courses, lawn-covered yards and parks on lakes to the extent necessary to alter goose distribution." This extreme statement is manipulative in that it implies that to optimize humaneness people would have to completely give up things like golf and grass. The implication is wrong and intended to reduce the issue to an overly-simplistic case of: since people aren't willing to compromise, we have no option but to kill. No data are provided to show to what extent landscaping changes would have to be made, or how much change people would accept to reach an acceptable distribution of geese. In fact, the survey of Appendix A shows some willingness of people to support vegetation changes. Interestingly, landscaping changes were omitted as an option in the subsequent survey of Appendix B. Once again, respondents were led to choose between a series of invasive actions. Coincidence? Unlikely.

In saying that "those carrying out this Management Plan will always consider non-lethal methods first, and will use them to the greatest extent possible," is to relegate non-lethal methods to a motivationally-deficient world where determining whether or not something was "considered" is as unverifiable as proving whether someone had a thought or not. The expression "greatest extent possible" is equally immeasurable and can legitimately be defined as "nothing," so nothing need be done. Since non-lethal methods require more planning than killing, the alleged "humane concern for geese" is an empty mandate.

"Control Methods" (page 11)

"Hazing"

Since no mention was made of the use of trained border collies for dispersing geese from airfields, one is led to believe (from implications on this page) that "safety personnel" are driving around chasing geese. This implies a certain low level of expertise in the area of non-lethal goose dissuasion. Anyone well versed in non-lethal goose management knows that border collies are extremely effective, especially in large areas such as golf courses. Indeed, they are recommended by the US Armed Forces Pest Management Board to disperse geese from areas where they are not wanted.

"Egg Collections" (pages 11-12)

This section contradicts what was claimed earlier. If nesting success is so tenuous, "just a few offspring reach adulthood," why are future population trends couched in the urgent terms of "exponential" growth? All throughout the continental United States, WPAs (Waterfowl Production Areas) have been established (some efforts as a direct result of the North American Waterfowl Management Plan) where populations of certain types of waterfowl, including Canada geese, have been successfully increased by improving conditions that increase their nesting success. The reverse must also be true: that decreasing nesting success as in egg collecting, must substantially decrease population growth.

Note that at the end of the first paragraph it is said that egg collection "must be used in concert with translocation and lethal control of adults to, "...for example, cut the population in half.." Interestingly, lethality is mentioned as a definite conclusion in a section on possible control measures. The seemingly-innocent example corresponds to what eventually will become the proposed action - kill half the geese. To wit, the options in this DEA are not objectively presented.

While egg management is a useful tool for population growth, this section devotes too much attention to who would take the eggs and how they would be used. The ultimate use of the eggs has NO BEARING on whether this is a sensible management option for the situation at hand. It is precisely this preoccupation with public opinion that casts doubt on the putatively objective scientific integrity of this DEA.

The last sentence in paragraph 2 on page 12 expresses, yet again, a disingenuous concern for the welfare of geese. That the authors of the DEA actively promoting the killing of 2000 geese are concerned about geese "possibly" dying from starvation by sitting on addled eggs is not believable.

"Gosling Translocations" (page 12)

Translocated adults only return to and remain at their original home if no changes are made to the area in question that make it unusable, inhospitable, etc.

"Adult and Subadult Collections" (page 12)

According to paragraph 1, it is anticipated that the USFWS will issue a depredation permit under 50 CFR 21.42 to round up and kill geese during their molting period. None of the justifications for killing geese presented in this DEA are allowed by the federal regulations dealing with migratory birds. Further, while details concerning the collection of eggs was described in excessive detail (pages 11-12), the matter of rounding up the geese is left extremely vague. Precisely what is the American Veterinary Medical Association recommended killing method for geese? Why avoid describing it explicitly? To whom would the depredation permit be issued? Private contractors? ADFG? Who will be paying for the round up and slaughter? Will the flesh of the dead geese be tested for environmental toxins before distribution for human consumption? In

New York, geese were found to have high levels of lead two years in a row. The second year the NYS Health Department lowered its (admittedly) non-existent standards for lead and the contaminated flesh was fed to the unsuspecting elderly. Who will do the testing? Who will pay for it?

Fobbing the dead geese off onto charitable organizations is an unethical public relations gimmick to win support for an immoral plan - killing thousands of geese because they are essentially an inconvenience.

In this section it is said that "the effectiveness of lethal control on flight safety would be maximized..." Maximized?? Maximized implies that there are parameters that can be measured to confirm that killing actions are having some effect on safety. How would flight safety be measured? How is it measured at present? Using such measurements, what would be the range of acceptable risk (i.e., how will the goal be recognized when achieved)?

If the 1996 study on goose movement reveals nothing else, it says that geese are still able to feed near the flightline. Regardless of where such flocks came from, that this source of forage still exists is a blatant case of airfield habitat mismanagement. No killing should even be considered until all such attractants are removed.

The final paragraph on page 12 creates a grand illusion of adaptability and control. There is one problem however: all this fiddling and adjusting between varying degrees of killing, relocating and egg snatching are based solely on population goals (2000 geese) - goals that this DEA has yet to establish as having any relevance to resolving goose-related "problems." Once again, it would seem that this plan is based on the maximum action that the public "might" tolerate - not sound scientific problem solving.

Let the record show that of all the methods described above, only the non-lethal techniques were linked to descriptions of practical outcomes - this is no coincidence; it is a product of biological phenomena.

"Alternative A. 'Status Quo' Alternative" (page 14)

The "Status Quo" section is very informative in revealing how little has been done to date regarding non-lethal methods.

Paragraph 1 states that," The actions outlined in Alternative A....will take place no matter which alternative is selected". It is hard to understand why there would be any motivation or need to implement non-lethal measures (habitat modification, etc.) if one of the lethal alternatives (b-e) comes to pass - unless, that is, there is uncertainty about the effectiveness of mass goose destruction. This lack of confidence is justified, since massive killing can only be guaranteed to produce numerical outcomes (for an indeterminate period of time), not necessarily a practical outcome. On the contrary, thoughtful habit modification will certainly produce outcomes of practical significance because such actions impact phenomena of biological significance: what attracts geese to certain areas.

Paragraph 3 reiterates that there is much to be done in the area of habitat modification and this can only be true if very little has been done to date.

"Population Actions" (page 14)

Several of these actions (P.3 and P.4) suggest that seasonal migratory populations are of concern to aircraft safety. This would appear to be "filler" in the context of this DEA, since the lethality under consideration will have little impact on the regular influx of migratory goose populations. Indeed, the vacancies created by one of the extermination plans may well have the opposite effect of luring more geese into the areas of concern. Highly mobile species tend to repopulate usable habitats with interest. What portion of air traffic safety concern is related to migratory geese? Clearly reducing the population of geese in Anchorage will have no effect on this aspect of concern, and may even make it worse during other parts of the year.

P. 6 confirms what was said vide supra: the ADFG is, first and foremost, out to expand its hunting business into areas previously off-limits to hunters. The ADFG is apparently willing to play the real safety hazard inherent in hunters discharging firearms in human-populated areas off the mostly imaginary threat posed by geese. Predictably, the ADFG is merely using this controversy as an excuse to provide convenient killing opportunities to their paying customers (hunters) knowing full well that "special hunts" have negligible impact on goose related "problems."

"Habitat Actions" (page 15)

If action items H.1 - H.6 still remain to be carried out, it is clear that in the two years following the tragic air crash, very little has been done in the critical area of habitat alteration. This is ironic since earlier in the DEA the authors point out that habitat (mostly human-made) is the primary cause of the elevated goose population. By simple logic then, if geese are causing problems and attractive habitat is causing geese, a biologically sound proposal should focus on goose habitat not the geese themselves.

The implication in H.1 is that grass mowing (goose habitat creation) continues to take place at EAFB and other airports. This casts serious suspicion as to whether the concern for air traffic safety is genuine. By mowing grassy areas, EAFB is willfully CAUSING a hazard to airmen and women by creating areas attractive to geese. Such actions imply that EAFB management is more concerned with arbitrary aesthetics (large mown areas) than human safety and, further, more intent on blaming and killing geese than taking responsibility for irresponsible airfield management. (There are interesting legal implications here regarding liability.)

"Other Actions" (page 16)

There seems to be a preoccupation with people directly feeding geese. O.1, O.2, O.3, O.4, O.5, O.6 and O.7 all speak of efforts to educate the public about the importance of not feeding geese and to produce brochures, policy and laws to advance this goal. This is resource-wasteful and a misguided distraction to transfer the blame for goose-related problems from those who are guilty of poor landscape management and stubbornly resistant to change, to those who enjoy interacting with the geese. The only feeding of biological consequence regarding the distribution of geese is the presence of turf grass. According to H.1 - H.3 (page 15) all airfields in question continue to maintain areas of turf grass (goose food). This is the type of feeding that must be addressed. If the authors of the DEA truly believed that direct feeding from people was such a potent factor in determining Canada goose distribution, they would not be recommending killing; they would be advocating the feeding of geese in areas where they are not considered a problem to keep them out of areas where they are.

According to O.7 there is reason to believe that people are feeding geese on Merrill Field airport. If this outrageous implication is true, it shows how pathetically little effort has been made to implement even the most fundamental of non-lethal techniques - banning goose feeding in problem areas.

"Alternatives B-E" (pages 16- 20)

Alternatives B-E all call for killing hundreds to thousands of geese over about a two-year period. It is not necessary to analyze each of these alternatives separately, as they simply represent a series of incrementally increasing amounts of killing. While it is claimed that the various non-lethal methods described under Alternative A would be implemented along with the killing, it is unclear what funding would be available to implement these techniques after the very costly killing had taken place. Indeed, the DEA fails to explain not only how the "Est. Annual Costs" in Table 1 were derived, but fails to even hint at where such funds would come from. It seems likely that Anchorage taxpayers would end up footing the bill. If we are to believe that air traffic safety is the primary concern regarding geese, this entire "scheme" may very well be little more than an attempt by the military and other commercial airports to externalize their operating costs by scaring the tax- payer into surrendering his or her hard-earned money.

"VI. Environmental Consequences"

"Ecological Consequences of Alternative A" (page 21)

It is claimed that the goose population would continue to increase under this alternative. This assertion seems to be saying that the habitat modifications recommended under this alternative will not really be implemented. Aggressive goose hazing during the nest building season should force the geese to either not nest or nest out of Anchorage - which brings up an obvious omission: why wasn't large-scale egg addling/collection mentioned under Alternative A as a means to limit goose production? There was an intentional coupling of egg collection with goose killing, yet it needn't be this way.

While no studies are presented to substantiate the claim, there is concern over waterfowl diversity at "some local lakes." Even if true, the phenomenon must be recognized as biologically related to the lack of habitat diversity: a situation to which this DEA has already conceded. In this context, exterminating geese to benefit ducks is shallow, symptom-based, thinking that advocates killing one type of wildlife to force an ecological balance not consistent with the habitat.

It is said that "...high concentrations of geese would increase the spread of disease." This is an ironic statement in light of the fact that no studies appear to have been carried out regarding the current population's status in Anchorage relative to the region's carrying capacity. Further, no evidence was provided to indicate that any disease state, including Salmonellosis, exists within the local population.

It is said that under this alternative, more geese will be killed on roadways. Even if this were true, the number would be minuscule relative to willful killing associated with alternatives B-E.

It is said that water quality in local lakes is likely to decline, however no studies were done to determine what the status of the current water quality was or, once again, the relationship between the current goose population and the biological carrying capacity for geese.

"Social Consequences of Alternative A" (page 21-22)

It is said that Alternative A would "greatly increase the likelihood of another fatal accident to humans." It is unclear how such risks are being measured, let alone how increases are being predicted. The rarity of fatal bird strikes makes it very difficult to draw conclusions regarding the mathematical relationship between population and risk. In any event, if the airfields in question were to implement, rather than resist, habitat modification, the question of goose population would be moot. Apparently, airfield managers would rather complain about the number of geese they had to haze and disperse than face the reality that they are mismanaging their facilities. Since the numbers of geese dispersed in 1996 also included geese passing through, the impact of the so-called local population on safety can not be accurately evaluated, nor can the lethal control actions be proposed. Overall, it would appear that landscaping rituals are more important to airfield managers than human or goose lives.

It is said that by 2007, the population of geese will reach 15,000. This number is a product of pure mathematics and is based on unfounded assumptions of constant population growth and a complete lack of biological limiting factors. The authors seem to be willing to throw anything into this report to support the massive killing of geese. It is also said that "flight operations would have to be halted during periods of migration." There is no explanation given as to why we should believe that any of the killing-intensive alternatives will impact migration.

It is incredible to read that there is a golf course, undergoing expansion no less, in the vicinity of the military airfields. Surely, it is understood that the very existence of such goose attractants is a hazard to aviation. Are we to believe that golf is more important than the lives of humans or geese? If airfields are so irresponsible as to maintain such hazards, perhaps federal laws should be written to forbid them.

Paragraph 4 (page 22) fails to point out that if egg management activities were carried out, population growth could be controlled and the unsubstantiated issue of "agricultural damage" in Oregon could be mitigated. In the same paragraph it is suggested that hunting is actually forcing local geese out of the refuge and into areas where concern is greatest about nuisance and safety. Such activities should be discontinued, unless the message is to be that hunting is more important than the concerns of the general public.

Paragraph 5 (page 22) assumes that the current level of ineptitude regarding non-lethal control measures would continue; it also assumes that local airports would continue to scoff at habitat changes, many of which would reduce the amount of noisy hazing techniques required. That homeowners and businesses are anticipated to make hundreds of calls (incidentally, no call records were provided to substantiate whether such influxes occurred in previous years) is testimony to the ineffectiveness or nonexistence of ADFG education programs on what factors bring geese into areas where they are unwanted.

"Economic Consequences of Alternative A" (page 22)

In the first paragraph in this section, the authors have gone from talking about geese in particular to speaking of costs associated with "wildlife hazard management activities." The costs mentioned apparently have non-goose-related expenditures included. It is said that as goose populations increase, these (composite) figures would need to increase to maintain a safe environment for aircraft. This statement is deceiving because it assumes that the only options are do nothing or kill hundreds or thousands of geese. Of course, this perspective is merely an artifact of the authors' killing bias. Alternative A puts forth non-lethal actions such as habitat changes that, if utilized properly, can reduce the number of nesting areas and reduce the number of geese where they are perceived to be a threat to air traffic safety. Indeed, it egg management were part of Alternative A, one could envision an effective, long-term program of goose control without killing. Obviously, egg management was left out of this Alternative so that it would have no provision for population control, so that in turn it would be unappealing relative to the killing options.

What is presented on page 23 is the depiction of that which the public loathes so much: government waste and inefficiency. According to the DEA, 24 staff members were taken from regular duty to haze geese.

There are some major informational deficiencies in what is provided here:

1. Are 24 staffers used ALL year-round, or ONLY during the migration period (spring & fall)? It was conveniently omitted that during the molting period hazing is discontinued, as the geese can't fly.

2. If the problems are worse in the spring and fall, as implied, what is the point of killing locally nesting geese if migrants are the labor-intensive part of the problem?

3. Why is Elmendorf AFB spending more than "$155,000" and using 24 staffers to do the job of 4 staffers (or contractors) with four $3,000 trained border collies? It's not only cheaper but far more effective. (By USFWS/ADFG feeding-logic it can be explained by saying that geese are still afraid of border collies because they never feed the geese).

Aside from backfilling depressions that form goose-attracting water holes, it is not clear why Elmendorf is spending large sums of money turning the conceptually simple notion of habitat changes into a tour de force program of "goose research," and "vegetation trials." Is Elmendorf an air force base or an agricultural research station? Elmendorf appears to be doing literally everything in its power to spend as much money and consume as much manpower as possible to show that hazing and habitat changes are just not viable. Of course, anyone can fail if they try. The discussion on page 23 (paragraphs 2 and 3) was clearly designed to make habitat changes seem like the complicated and expensive undertaking that they are not. Many of the most effective vegetation changes cost nothing to implement and actually reduce the maintenance-intensiveness of an area. For example, large mown areas (prime goose habitat) should be allowed to grow to 24 inches or taller. Most grasses at this length are too fibrous and too low in protein to be of interest to geese. In addition, geese are fearful of areas that make predator visibility and take-off trajectories difficult. The typical argument against such a habitat change is one of aesthetics. When air safety is of concern, aesthetics must be given very low priority.

In paragraph 4, page 23 it is stated that neither the USFWS nor the ADFG "have staff or funds assigned to respond to hundreds of calls which currently come in,..." Those looking for help with geese are usually frustrated because neither the USFWS and ADFG have very much hands-on experience in dealing with suburban wildlife conflicts. This lack of experience also manifests itself in the frustration of those in the agencies responding to the calls for help.

The statement that MOA's expense for goose repellent for turf grass would rise under Alternative A is false. Goose repellent use is a function of turf grass area, NOT goose numbers.

"Consequences of Alternative B: Population Goal of 4,000 Geese"

"Local airport managers believe the safety hazards to aircraft are still severe at this population level..." Believe is the key word. Since no measurable standards have been advanced to transform this belief into meaningful risk assessment this conclusion is speculative.

"Consequences of Alternative C: Proposed Action: Population Goal of 2,000 Geese"

Lethal control will be objectionable to MOST residents when they find out that non-lethal control measures can alleviate or minimize concerns regarding geese. Providing the dead geese to food pantries has no bearing on whether the killing is based on sound biology or necessity.

"Ecological Consequences of Alternative C"

1. Lower concentrations of geese CANNOT diminish a risk, such as posed by parasites, etc., if no risk is shown to exist in the first place; none has been demonstrated.

2. Lower concentrations of geese will not significantly influence the spread of the parasite responsible for swimmer's itch, even more so since the presence of the parasite has not been shown to exist in Anchorage the first place. Indeed, addressing swimmer's itch via goose populations is the least-effective way to address this situation.

"Social Consequences of Alternative C"

It is said in this section that "Local airport managers believe [emphasis added] the safety hazards to aircraft are still significant at this population level....." No information has been provided to rule out the possibility that airport managers believe that any number of geese in Alaska are too many from a safety standpoint. The authors are attempting to make this, the proposed action, appear as some sort of concession on the part of airport managers. Indeed, that no commentary or beliefs are expressed on behalf of airport managers in the sections, "Social Consequences of Alternatives D and E" suggests that even under the alternative with the most killing (E), airport managers would not be satisfied. Airport managers must realize that if on any given morning 75 of the remaining 500 geese should appear out of nowhere to graze in the vicinity of the airfield, all assumptions about optimal populations are off.

The belief that halving the population of geese in Anchorage will geometrically halve all cost and nuisance problems is overly simplistic. Population reductions create more vacant habitat and this in turn may trigger compensatory recruitment from other flocks circulating in the area. Indeed, after a massive extermination, it is likely that the flight activity of the remaining geese will increase as flocks circulate among the now-vacant feeding areas. That is, geese will expand their feeding territories and explorational activities, hence spending more time airborne - a decidedly detrimental situation regarding air traffic safety.

"Economic Consequences of Alternative C, D, and E"

Under Alternatives C, D and E, the economic benefits would be negligible because killing geese is a symptom- not cause-based approach to problem solving. As long as inefficient hazing techniques are utilized and habitat modifications are stalled on the hope that a magical solution will appear out of nowhere, no measurable advances in air traffic safety will occur, whether there are 4000 geese in Anchorage or 50 (with thousands on their way).

Final Comments:

The document under consideration, Draft Environmental Assessment, Canada Goose Population Management in Anchorage, Alaska, US. Fish and Wildlife Service, September 1997, is a highly deceptive ensemble of information. It was clearly not the intent of the authors to fairly assess all options and combinations thereof from a standpoint of efficacy, rather, it was their mission to justify a pre-determined goal of wildlife extermination: the long-standing tradition of the wildlife management establishment.

The alleged necessity for goose killing was integrated, often subtly, into every aspect of the DEA. The authors even went so far as to blame people who feed geese for making them less fearful of motor vehicles and aircraft. More words were spent blaming goose feeders for all of Anchorage's goose problems than were spent talking about well-defined strategies to curb the proliferation of turf grass - the only feeding that really matters. The DEA used people who feed geese as symbolic of those who value the lives of the geese and would stand in opposition to any form of wholesale slaughter. This clearly a means by which anticipated opponents to lethal actions could be indirectly attacked throughout the DEA.

From a scientific standpoint, the DEA is anemic. While many statements were made regarding "concern" over water quality, the spread of disease to both humans and other waterfowl, rates of eutrophication, etc., no assertions were supported with actual studies from the area in question. In fact, as pointed out vide supra, many statements were wholly misleading. For example, the idea of controlling swimmer's itch by killing geese is biologically absurd and even goes against the position of USFWS waterfowl disease expert Dr. Milton Friend. The DEA attempts to draw upon an ambitious list of unsubstantiated concerns to justify a very REAL and deadly act of killing hundreds to thousands of geese.

The DEA raises some very serious questions about the efficiency of currently implemented hazing programs at airports. Further, there seems to be some attempt by airport managers to make a big production out of implementing habitat changes. This suggests that the ADFG and USFWS are exacerbating the frustration of airport personnel by failing to provide useful information on the most expeditious means of making areas unusable to geese. While the USFWS may be feigning no practical knowledge, they do know exactly what must be done to make areas unsuitable for geese. They have brokered enormous resources under the North American Waterfowl Management Plan doing precisely the opposite.

A complete lack of confidence emerged on the part of airport managers when it was revealed that goose feeding still takes place at one airport and that a golf course is being expanded in the vicinity of another. There seems to be a general reluctance to remove the goose attractants from areas where the risk to human life is believed to exist: around airfields. Translation: there is a clear unwillingness to address the cause of the problem and this puts people at risk.

In other areas (i.e. non-airport), there appears to be very little effort being made to implement proven non-lethal control measures, including the use of border collies and strategic landscaping changes. The DEA attempts to cast landscaping changes in a negative light by suggesting that people will have to give up golf or sports. This exaggeration is intended to draw out public resentment toward the geese to facilitate massive lethality.

By design, the DEA only speaks of egg addling as part of a plan that also includes killing. It is quite reasonable to expect that through egg addling and site-specific goose dissuasion techniques that human-goose conflicts and concerns about public safety can be minimized or eliminated. In contrast to the recommendations of the DEA, this would be genuine problem-solving. The authors realize that to make the case for killing they must obsess over the total population and avoid taking a strategic site-specific approach. Preoccupation with exterminating a large number of geese obscures the truth that only a small fraction of the geese are causing problems for a small number of people in a well-defined number of places.

The sweeping actions proposed in Alternatives B-E are primitive, non-strategic actions for which the large scale loss of wildlife is the only guaranteed outcome. There is no reason to believe, and no explanation was given, why such a crude form of problem-solving would produce anything other than a perpetual cycle of killing and cruelty. Geese are not an inventory in an outdoor warehouse. They are highly developed creatures that live in flocks with complex social structures, form strong family bonds, and engage in intricate patterns of behavior. To reduce their existence, distribution, and activities to a simple mathematical paradigm is unscientific, unethical and completely unacceptable.

The USFWS and ADFG has a responsibility to the citizens of the United States to uphold the highest standards of restraint, intelligence and compassion when confronting human-wildlife conflicts. The DEA under consideration does not reflect this commitment. It wantonly disregards basic principles of wildlife biology and ecology in preference for principles of manipulative psychology and sociology.

While the DEA has failed to show why programs of mass destruction are necessary, it has shown with certainty that very little effort, and in some cases no effort, has been made in the area of non-lethal control, habitat modification, and egg addling. Under such circumstances, all Alternatives (A-E) proposed in the DEA must be rejected.

Thank you for full consideration of these comments.

Sincerely,

Gregg B. Feigelson, Ph.D.