US Fish and Wildlife Service (USFWS) Proposes to Turn Over Control of
Canada Geese to State and Local Governments

DEADLINE FOR WRITTEN COMMENTS WAS NOVEMBER 22, 1996

Here is the The Draft Environmental Assessment with original document page numbers included (without graphics or all appendices):

Section 1
Section 2
Appendix

(Note: These documents have been removed from the server. They are available upon request.)

OUR SUMMARY

Under the current system, towns, cities, etc., may apply for a permit, called a depredation permit, to kill Canada geese that are considered a nuisance. The application process begins at the State level and then requires Federal approval. Permits are issued on a case-by-case basis (a separate permit for each action). This process is lengthy enough for wildlife protection groups to monitor the process and head off (in many cases) the wholesale slaughter of geese. This is not to say that when a permit is issued there is an announcement -- quite the opposite. The current permitting process is essentially done behind closed doors and considerable effort is necessary to obtain (through the Freedom of Information Act) copies of the permits that have been approved.

The US Fish and Wildlife Service (USFWS) is currently proposing three "alternatives":

1. No Action; things would remain as they are -- not a good situation.
2. New Proposal; described below -- would initiate a massive amount of goose killing.
3. Further Restrict permits; would make it harder to obtain permits to kill geese.

The USFWS is seeking to enact "Alternative 2." This change would make permits to kill Canada geese easier to get (and harder to track). It would allow yearly permits to be given to State wildlife agencies or State divisions of the ADC (Animal Damage Control). With oversight from the USFWS gone, and with the fate of Canada geese turned over to the States, local authorities in towns and cities would continue to be able to get permits to kill geese without proving that the geese are in fact causing harm (which is illegal, not that they care), but under the proposed rule they would be able to get these permits faster.

Translation: If this proposal is adopted, suburban Canada geese will be slaughtered on an enormous scale all over the country.

Action: Write to the US Fish and Wildlife Service. They are taking comments on this proposal which must be received by October 18, 1996. (DEADLINE WAS EXTENDED TO NOV. 22nd.) Every comment is critical!

Start by REJECTING ALL THREE ALTERNATIVES and request that Canada geese receive the full protection they are entitled to under the Migratory Bird Treaty: None of the alternatives fulfill this obligation. Demand that any new proposals include the requirement that a public hearing be held before anyone can apply for a permit to kill geese.

Points to consider including in your letter:

--In the new proposal, the USFWS is abandoning its obligation under the Migratory Bird Act of1918. According to this Act, the USFWS cannot legally pass on to state and local governments its responsibility to migratory birds such as Canada geese. The proposal is therefore in violation of the Migratory Bird Act.

--The Migratory Bird Treaty of1916 does not give permission to the USFWS to redefine for their own purposes what constitutes a migratory bird. The artificial concept of "resident" Canada geese is not recognized by the Treaty. Destroying these birds based on such a discrimination is therefore illegal. Claims about Canada goose "sub-species" are based on feeble scientific evidence and are largely unproven. (Most banding studies evaluate less than 1% of a given population.)

--The proposal refers to "injurious" Canada geese and assumes that complaints about Canada geese are equivalent to an "injurious" condition. This is not the case. Complaints and allegations against Canada geese concerning human health, population growth, and economic loss are grossly exaggerated and usually invalid. In substance, the complaints in question amount to inconvenience or intolerance, not "injury". The Treaty requires that killing be limited to "extraordinary conditions" that are "seriously injurious."

"Seriously injurious" conditions do not exist.

--The proposal does not set guidelines nor provide precedent for what is meant by "injury" nor standards upon which permit granting would be made.

--The ongoing 1986 North American Waterfowl Management Plan is devoted to increasing the "carrying capacity and productivity" of wetland areas for migratory birds such as Canada geese. Since most of these areas are located in the United States, the USFWS and state wildlife agencies are actually producers of "resident" Canada geese. These efforts are designed to improve hunting opportunities.

--Proposals that liberalize the use of lethal methods to control Canada geese while ignoring hunting-biased wildlife management practices that are the root cause of population imbalances are ineffective and dishonest.

Write to:
Chief
Office of Migratory Bird Management
US Fish and Wildlife Service
Room 634
Arlington Square
Washington, DC 20240

FAX: 703-358-2217