YOUR LETTERS URGENTLY NEEDED!

If this proposal is approved, tens of thousands of geese will die.

Once again, the federal agency charged with protecting our country's wildlife, the U.S. Fish and Wildlife Service (USFWS), has taken a wrong turn. The consequences for our gentle Canada goose neighbors will be devastating.

On March 31, 1998, the USFWS published their intent to move forward on a proposal to create a new federal regulation that would take away what little protection Canada geese have under the Migratory Bird Treaty Act.

As it stands now, if an individual, company or municipality wants to kill geese because they feel they are a problem, all they have to do is get two permits: one from USFWS, and one from their state wildlife agency. Under present regulations, USFWS by law must consider each permit on a case-by-case basis. In practice, anyone who requests a permit ultimately gets one because the USFWS rarely confirms that the claims on the permit application are valid. In fact, thousands of geese have been rounded up and killed in slaughterhouses under the existing federal regulations.

One reason the USFWS is pursuing this change in regulations is precisely because of the fierce opposition that the Service, and state wildlife agencies, have received over goose killings in the recent past.

If the proposed rule is approved, the USFWS will issue permits directly to state wildlife agencies on a yearly basis, who, in turn, will give out permission to individuals, companies or municipalities to kill geese. For all practical purposes, the regulation removes federal oversight and leaves the geese at the mercy of ruthless state agencies.

THE AMOUNT OF KILLING THAT WILL RESULT WILL BE UNPRECEDENTED!

The USFWS is currently accepting comments from the public on this deadly proposal - without written opposition, the proposed rule is a done deal. If you care about geese, PLEASE WRITE and express your opposition!

While comments were originally due by June 1, 1998, the comment period has been reopened. COMMENTS ARE NOW DUE BY SEPTEMBER 21, 1998 TO:

Mr. Paul R. Schmidt, Chief
Office of Migratory Bird Management
U.S. Fish and Wildlife Service
Department of the Interior
MS 634--ARLSQ
1849 C Street NW
Washington, D.C. 20240

INCLUDE THE FOLLOWING REFERENCE AT THE BEGINNING OF YOUR LETTER:

"The following comments are submitted in response to the recently proposed rule "Migratory Bird Special Canada Goose Permit" [Federal Register: July, 1998 (Volume 63, Number 141) Page 39553]."

To assist you in writing, we have compiled the following list of important points that you may use to simplify the letter writing process. You may use them as is, or preferably, restate them in your own words. Use as few or as many as you like.

1. Start by telling them you completely oppose the proposed rule!

2. State wildlife agencies are bullying the USFWS to make permits easier to get because they are eager to kill more geese. By giving state agencies the power to decide whether or not to kill geese, the USFWS is illegally passing on its repsonsibility under the Migratory Bird Treaty Act.

3. While they argue that this new regulation will help "manage" suburban and urban geese, the USFWS provides no evidence to suggest that by increasing the amount of killing, people will experience fewer problems with geese.

4. They claim that the geese are a threat to public health and safety, although they have no scientific data to support their claim. In fact, studies have shown that the opposite is true.

5. They claim that they have to make permits easier to get because so many people are complaining about geese (the Service finds these complaints annoying), yet they have no studies showing that the complaints are valid or that increasing the amount of killing would even address the concerns of the complainers. The proposed rule favors a solution (easier access to killing permits) to a situation they have not adequately documented and, therefore, do not understand thoroughly.

6. They argue that the geese targeted in the proposed rule are "resident" geese, although they admit that they have no idea to what extent long-range migrants intermix with geese in the U.S.

7. Under the proposed regulation, state wildlife agencies be the ones making the case-by-case judgments whether to kill geese or not. This runs contrary to the Migratory Bird Treaty Act that says that the USFWS is to make such decisions regarding Migratory Birds, not state wildlife agencies.

8. The Migratory Bird Treaty says that the Federal government may authorize the killing of migratory birds only if they are "seriously injurious" to commercial interests - not personal property as claimed.

9. Even under the present permitting system, the USFWS has failed to document or establish a formal criterion of what constitutes a "seriously injurious" condition. If they have no guidelines for determining when to issue such permits, how can they expect state agencies to exercise uniform judgment?

10. The USFWS manages Canada geese in the US for increased populations to create favorable "sport hunting" opportunities. They are contributing to a problem they are pretending to solve - this is very dishonest.

11. The permits issued to state wildlife agencies are too broad and give too much power to state wildlife managers. In practice, the new regulation amounts to an unlawful delegation of federal authority to the public via state agencies.

12. Under pressure from USDA/APHIS-WS, the USFWS removed all restrictions pertaining to how the geese could be killed (although hunting is not allowed). Since there would be no mandatory oversight during any killing, anything could happen.

13. While they deny it, the premise of the proposed regulation is based on saying that some Canada geese are not migratory birds and therefore are not entitled to as much protection as other geese. This discrimination is not allowed by the Migratory Bird Treaty.

14. The USFWS is putting its own administrative convenience and pressure from state agencies before the protection of wildlife; a clear violation of their mandate.

For more information please contact the Coalition.

If you are interested in reading some of the comments submitted on the Proposed Rule, we offer the following:

Comments submitted
by Gregg B. Feigelson, Ph.D.
Coalition to Prevent the Destruction of Canada Geese

Comments submitted
by Don Feare, J. D., Executive. Director
Wildflight Rescue Foundation

Comments submitted
by Ann Frisch, Ph.D., National Coordinator
Coalition to Protect Canada Geese

Comments submitted
by Linda Hatfield, Issues Coordinator
Friends of Animals and Their Environment

Comments submitted
by Nancy Zierenberg
Wildlife Damage Review

Comments submitted
by David Cantor

Comments submitted
by Lori K. Godzik

Comments submitted
by Nedim C. Buyukmihci, V.M.D.
Professor of Ophthalmology (University of California)

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One hundred of the Canada Geese currently being held at Carlos Avery Wildlife Area (Minneapolis, MN) were illegally "dosed" with lead on August 4, 1997, according to department of Natural Resources ("DNR") records recently provided to the Minnesota Humane Society, Friends of Animals and Their Environment (FATE) and The Humane Society of the United States.

Currently pending before the US Fish and Wildlife Service ("USFWS") is an application submitted by Dr. James Cooper, of the University of Minnesota Department of Fisheries and Wildlife for a "Scientific Collecting Permit" to dose geese with lead and analyze the results. This permit has not been approved. Yet it appears from the DNR's own records that this research already began over two months ago--without a legal permit or any legal authorization to do so.

Says Linda Hatfield, Issues Coordinator for FATE, "It is very disturbing that these wild birds appear to have been illegally dosed with lead while supposedly under the care and supervision of the Minnesota Department of Natural Resources." Erin Jordahl, Executive Director of the Minnesota Humane Society states, "We call upon the US Fish and Wildlife Service to do a full investigation and file criminal charges against all persons responsible for this blatantly illegal act."

The comments submitted to USFWS by the attorney for the animal protection groups regarding Dr. Cooper's pending permit application is available by request to Linda Hatfield, [email protected].

Please call University of Minnesota President Mark G. Yudof

Office phone: (612) 626-1616
FAX: (612) 625 3875

Please ask him to stop the killing and poisoning of Canada Geese.

Please also call Steve Wilds, Migratory Bird Coordinator USFWS

Office phone: (612) 725 3313
FAX: (612) 725 3013

Ask him to free the geese and investigate James Cooper, the University of Minnesota and the Minnesota Department of Natural Resources for violating the Migratory Bird Treaty.

For more information call: Erin Jordahl Executive Director Minnesota Humane Society (612) 641 6158; Linda Hatfield, Friends of Animals and Their Environment (612) 822 2720

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If you missed the story it's available here. The Alaska branch of the US Fish and Wildlife Service is taking comments from the public on their proposal (called a "Draft Environmental Assessment" or DEA) to kill more than 2000 Canada geese in Anchorage. Comments are due by Nov. 30, 1997.

The DEA puts forth five "Alternatives" A-E. Each is summarized as follows:

Alternative A: Status Quo - However, recommends expanding hunting (e.g., hunting on golf courses, etc.) and continued research into non-lethal options. The 300 geese killed annually at local airports would continue.

Alternative B: Maintain population of 4000 by the year 1999 - Optimize "sport" hunting or kill 580 geese the 1st year and reduce the gosling population by 350/year over 2 years by a combination of egg collection and relocation.

Alternative C: THIS IS THE PROPOSED ACTION - Reduce the population to 2000 by the year 2001 - Optimize "sport" hunting or, over 4 years, kill 730 geese/year and reduce the gosling population by 290/year by a combination of egg collection and relocation.

Alternative D: Reduce the population to 1000 by the year 2001 - Optimize "sport" hunting or, over 5 years, kill 860 geese/year and reduce the gosling population by 400/year by a combination of egg collection and relocation.

Alternative E: Reduce the population to 500 by the year 2001 - Optimize "sport" hunting or over 4 years kill 890 geese/year and reduce the gosling population by 290/year by a combination of egg collection and relocation.

NOTE: In all cases except A some killing (40-150 geese) would continue after the target date to "maintain" the population goal.

Some points you may wish to consider in your letter

1. Be certain to identify that your comments are in reference to the "Draft Environmental Assessment, Canada Goose Population Management in Anchorage, Alaska, U.S. Fish and Wildlife Service, September 1997."

2. You may wish to remind the USFWS that migratory birds, such as Canada geese, are "protected" by Federal law for all citizens regardless of where they or the geese live.

3. The Draft Environmental Assessment (DEA) makes a lot of claims about geese that are not supported by facts or studies relevant to the situation in question.

The DEA provided no evidence that........

.....goose droppings contained bacteria that would cause disease to humans;
.....goose droppings contained bacteria that would cause disease to
    other waterfowl;
.....geese were causing eutrophication;
.....geese were a serious traffic hazard.

4. The authors of the DEA admit that the current goose population is due primarily to man-made changes to the environment, such as the proliferation of turf grass, yet proceed to attack the geese rather than what attracts them in the first place.

5. The DEA fails to mention that the Alaska Department of Fish and Game (ADFG) profits from high populations of huntable species like geese and have actively promoted population increases through habitat management activities. The authors also note that hunting has forced geese into the city from more rural areas.

6. The DEA assumes that by reducing the population of geese, the "problems" associated with geese will be reduced. This is an overly simplistic view that fails to acknowledge that goose "problems" are site-specific, not uniformly distributed.

7. It is clear from the DEA that non-lethal measures and strategic habitat modification have only received limited attention. Resorting to killing is an extremely drastic proposal at this point.

8. None of the groups consulted in putting together the DEA represent groups concerned with the welfare of the wildlife. Most were groups claiming to have "problems" with geese. The committee was biased.

9. Ironically, throughout the DEA there is talk of "humane concerns for geese." Since one of the main options is to round up geese and send them to be slaughtered, this "concern" is obviously just for show. The lethal actions proposed in the DEA are extremely cruel. Geese are very social creatures that form strong family bonds. When geese are rounded up they become panic stricken as family members - lifelong mated pairs, parent geese and their offspring, and combinations thereof - are separated. This is only the beginning. What is eupehmistically referred to as "processing" is the horror that these very sensitive birds must endure in watching their family members having knives jammed in their throats or their necks broken. The proposed action is the embodiment of cruelty and the DEA a document of excuses to justify it.

10. The Coalition recommends that ALL ALTERNATIVES (A-E) BE REJECTED. The USFWS and the ADFG have a responsibility to do more than just "consider" non-lethal methods, but to see that the proven methods are implemented correctly, in the right places, at the right times in the most cost-effective manner. No lethality should be considered until such time as the above is demonstrably true.

SEND COMMENTS BY NOV. 30, 1997 TO:

Karen Laing
U.S. Fish and Wildlife Service
1011 East Tudor Road
Anchorage, AK 99503
FAX: 907-786-3641

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The Coalition will be joined by other wildlife groups to protest goose hunting at Ringwood State Park in New Jersey. These hunts have been steadlily expanded in length since 1993 when the hunt lasted 8 days. These hunts now span two whole months, January and September, during which time the park is closed each day for four hours.

During these goose hunts the parks are closed to the public under armed guard. Typically, the number of rangers, police and DEP personnel outnumber the 4-5 hunters in the park by about 3:1. Similarly, there are usually about 15-30 protesters (sometimes more). All who witness the spectacle remark at how blatantly wasteful the event is of state resources - all so that a special interest group can play out their war game fantasies with gentle geese as the victims of their bloodlust.

While local park officials are quick to verbally defend these hunts as part of some "necessary" program of population control, the head of the NJ Department of Parks has admitted to the Coalition in writing that they have not carried out or considered any population surveys or data in deciding to close the park for hunting. Indeed, they admit outright that the event is about little more than providing wildlife killing opportunities at the expense of the general public.

The purpose of these demonstrations is twofold: to show public outrage over the transformation of a public park into a killing field, and to also save the lives of geese that attempt to fly into the hunt area. Demonstrators stand facing the main road in front of the park, which also happens to be the direction from which geese are known to approach. When geese are spotted heading toward the park, protestors begin using noisemakers to turn the flocks around. This has effectively saved the lives of many, many geese.

JOIN US AT RINGWOOD STATE PARK, NJ!

Saturday, September 27, 1997, 6:00 AM

In addition to protesting, demonstrators will turn flocks of geese away from the hunt area with noisemakers. Signs will be provided. Participants should plan to arrive 10-15 minutes early. The hunt is scheduled to last from one half hour before sunrise to 10:00 AM.

For more information contact the Coalition at 914-425-7116.

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City fathers and mothers in Mississauga, Ontario are the latest pawns in the North American War on Wildlife. The Canadian Wildlife Service, according to the Mississauga News, will issue the city a permit to slaughter 1,000 Canada Geese for pooping on manicured city lawns. Notwithstanding the pressure for the kill, some council members have expressed misgivings about the action. Liz White of the Animal Alliance has argued that neither relocation nor killing the birds will solve the problem of overpopulation which has resulted in damage to waterfront and private properties.

Please e mail the authorities and call the Mayor to urge time for fact finding. More information below.

Tell them citizens do not have to be inconvenienced by the geese if the natural resources departments will stop "growing" them for hunters. Neither killing nor relocation will work if there are baited fields nearby or if US states are relocating them and restoring populations for hunters.

Mayor Hazel McCallion (905) 896 5555 and Bruce Carr, recreation manager (905) 896 5058.

E-mail to city council, including the mayor: TO:

[email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected]

1. Killing will not solve the problem because Michigan is going to be relocating 12,000 Canada Geese to public lands in the eastern part of the state. 6,000 of whom will be relocated in the next month if the US Fish and Wildlife Service issues a permit. Michigan has, according to its own year end report to the USFWS, relocated 43,000 since 1972. Relocation doesn't work and is basically used to reestablish geese on public hunting lands.

2. The International Association of Fish and Wildlife Agencies has just released a report to the USFWS recommending the legalization of state government practices of planting fields of grain to bait geese, deer and other animals just prior to hunting season. Baited fields are illegal, but common. (This can be found on the web at http://dnr. state.il.us/baiting/default.htm and http://dnr.state.il.us/baiting/final.htm). Geese move from rural to urban frequently so the presence of these baited fields near urban areas may be in fact what is maintaining these large urban populations.

3. With interest in hunting declining, so do revenues to state natural resource departments, who are dependent on license fees and taxes on ammunition, guns (including Saturday night specials) and other hunting and killing equipment. In order to continue their funding, they need geese (and deer) close to urban areas because hunters prefer to have close to home hunting.

4. Slaughtering Canada Geese is prohibited by the Migratory Bird Treaty Act. The Act permits hunting and permits killing geese if they are causing damage to fisheries, horticulture and agriculture.

5. Relocation and slaughter separates goose parents from their offspring. The juveniles are taken before they learn to fly to public hunting areas where they have high mortality rates due to hunting and predation. John Hadidian, Urban Suburban Wildlife Director, Humane Society of the United States, said in testimony before the Michigan Natural Resources Commission in May , "The HSUS maintains that there are more humane and equally available methods for managing geese that exist already, but simply are not being given a chance to work... (W)e disparage the actions of driving wild geese into holding pens, separating dependent young from adults and adults >from one another to destroy the tightly knit family units that geese establish, and the subsequent delivery of these wild birds, as if they (were) simply a farmable cash crop, to slaughterhouse processing lines. These actions are inhumane and cruel."

6. Feeding them to the poor is not advisable due to occasional high levels of toxic chemicals in the geese. Dr. Warren Porter, Chair of the Zoology Department and Professor of Environmental Toxicology at the University of Wisconsin has urged caution due to potential for developmental and mutagenic effects of the chemicals. Geese have an unknown trajectory and eat from our toxic laden golf courses and lawns. Food banks across the country are being asked to refuse to participate in the cruelty to animals or the poor. In Clarkstown, NY, citizens served a Notice of Dangerous Condition of Action on the town council alerting them to the potential for legal action if there were adverse effects of the consumption of geese.

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New York State Governor George Pataki is planning to slash $275,000 that is used to manage pheasant populations for hunting from the state's budget. Hunting groups like the New York State Conservation Council, Inc. have sent out an alert for hunters to call the governor and demand that the money be restored in his supplemental budget.

Please call, write or fax the governer and tell him to stay the course and make the budget cut as planned. Pheasants are not native to the ecology of NY state and are maintained exclusively for sport killing.

Contact the Governor:

The Hon. George E. Pataki
Executive Chamber
The Capitol
Albany, NY 12224

Phone: 518/474-8390
FAX: 518/474-1513