Wisconsin Animal Educational Network
180 West Main Street, Stoughton, Wisconsin 53589
[email protected]
Temporary address (through March 9, 1999)
PO Box 62252, Honolulu, Hawai'i, 96839
Cell phone: (808) 386 7772

January 28, 2000

Mr. Michael Marnach, Director
Sioux Falls Regional Airport
2801 Jaycee Lane
Sioux Falls, South Dakota 57104

Dear Mr. Marnach:

Thank you for providing the Coalition to Protect Canada Geese a copy of the report you commissioned with PBS Environmental. My comments are based on four years experience working with citizens protecting waterfowl. I have had significant experience reading the various reports by communities and the Environmental Assessments issued by US Fish and Wildlife Service and USDA APHIS Animal Damage Control ("Wildlife Services") concerning Canada geese. Most of my comments are posted on the web page of the Coalition to Prevent the Destruction of Canada Geese at the web site listed above. In addition to my work monitoring the situation of Canada geese in the United States and Canada, I have a Ph.D. in Human Ecology from Michigan State University and am Professor of Education and Human Services at the University of Wisconsin Oshkosh.

I have reviewed the report "Wildlife Habitat Utilization and Risk Analysis for Sioux Falls Regional Airport" by PBS Environmental, a letter to Friends of Waterfowl at Covell Lake by Ron Rathburn (copy to you and Janet Brekke) dated 1/6/99 (but probably meant 2000) and the Sioux Falls Argus editorial "Dog Could Scare Away Airport's Bird Problem" (1/16/00) recommending the use of border collies at the airport.

The issue in question is Canada geese (Branta canadensis) a migratory bird protected under the Migratory Bird Treaty. There is provision in the Treaty and in federal law for individuals or groups experiencing serious injury from the protected birds to get a permit to harass or shoot the geese to protect crops "or other interests". These permits cannot be used to create a hunt. The US Fish and Wildlife Service (USFWS) has gone to great trouble to protect the migratory population which in some areas has experienced reproductive losses. In some instances, hunting seasons have been curtailed.

The threat to airport safety in Sioux Falls seemed to arise very suddenly in 1999. This report looked only at "bird strikes" in 1999, suggesting that it is a new phenomenon. Since no historical data is given concerning bird strikes at the airport, the need for a study is not apparent.

There are four major problems I encountered in analyzing the data and PBS Environmental's conclusions and recommendations:

  1. There is no legend for the "Wildlife Data". Though Sec. 1.2 identifies a goal of the report as a "framework for reviewing parties to assess the scientific approach, findings and recommendations", the data cannot be independently reviewed without a legend.
  1. There is no identification to link the survey questionnaires and location of the fields around the airport. Thus, one cannot reconstruct the locations of the fields and make one's own conclusions. The one page map is too tiny to be useful except for general locations and does not identify the various fields. One must trust PBS Environmental's conclusion. This is inappropriate in a study commissioned by Sioux Falls citizens who want to make their own analysis and expect to see the argument for PBS claims.
  1. PBS Environmental failed to define the term "local geese", although the term is used several times. Not only is there no definition of the term "local", we don't ever know to what population in Sioux Falls, PBS Environmental is referring. Is it the few breeding geese in the summer who, as PBS claims, leave for northern counties? Is it the 1,900 who are said to be there in the winter who are said to be outside the migrant stream? If they were the geese which were stocked (captive bred? as part of the Dakotas Restoration project?), they would likely be the geese which breed in the spring and summer and fly south in the fall.
  1. There are numerous factual errors, claims which are not supported, misinterpretations of data, and inconsistencies between the figures and the narrative. Many of the statements made are not supported by fact, using personal communication with game agency personnel who have a vested interest in the outcome of the study.

Terminology:

I note first that the study is entitled "Wildlife Habitat Utilization…" yet the only "wildlife" that is discussed is Canada geese. In fact the data section with counts of Canada geese is entitled "Wildlife Data". Are we to understand that there is no issue with other wildlife at the Sioux Falls Airport? If so, why not title the study "Canada goose habitat…."…"Canada goose data"? I would hope that policy makers are not going to generalize to other animals or birds from a study focused on Canada geese. I note that some of the emphasis on bird strikes is about birds in general, not Canada geese. Whether intentional or not, it leaves the impression that all birds are Canada geese, so that the numbers are deceptively large when in fact the number of Canada geese compared to gulls, for instance, is small.

The fact that Canada geese are selected out for a $19,500 study is curious. It leaves the impression that there might be a political agenda here.

Purpose of the study:

The Introduction says the purpose 1.1 (no page number) was "to complete an analysis of Canada goose (Branta canadensis) flight patterns and habitat use near the Airport."

The methodology section 3.0 (p.2) states that the "wildlife" evaluation was designed to address:

--the number and seasonal occurrence of Canada geese in the study area;

--the habitat characteristics and other factors attracting geese to the study area and

--the flight zone conflicts between aircraft and Canada geese;

with the intent to provide a "series of recommendations to assist in the management of the geese populations."

So within one page of the document, the study focus changes from "flight patterns and habitat near the Airport" to "a series of recommendations to assist in the management of the geese populations." By the time PBS Environmental gets to the Recommendations 5.0 (p. 15), there are two "issues": the attraction of geese to the habitats at the airport; and the "large and increasing population of geese residing in the greater Sioux Falls area from late summer through winter". Neither in themselves are problems, merely topics. The inclusion of "large and increasing populations…" does not by definition constitute any problem.

So a citizen might be suspicious that other, political, motives may underlie the study. Historically, the issue of airport safety appeared to be the public relations motive for some other issues about the geese. It should be noted that airports already have federal authority to manage "wildlife", including Canada geese, through the US Fish and Wildlife Service and can obtain permits to shoot geese that are demonstrated to pose a serious injury to airport safety. The airport owns land that is leased to farmers to raise corn and soybeans, so already possesses the authority to withhold land from rental agreements to protect citizens if crops present a risk to air traffic safety. Of course, having used citizen's money to fund a study, it would be inappropriate to proceed with any lethal measures without seeing the outcome of the study and consulting with citizens.

The report did not make clear if it is intended to be used as an Environmental Impact Statement (EIS) required under federal and state law for government actions that have a significant environmental impact.

The appropriate outcome goal for this study would be to determine if there is a risk to airplane and passenger safety at the Sioux Falls Airport, the nature of the risk and how to reduce risk if it exists. It should follow the guidelines for an EIS including public disclosure and public hearings.

Claims for such emergency (and the justification for the study) is said to be "four separate incidents of aircraft colliding or maneuvering to avoid geese at the Airport in 1999" (4.8, p. 15). The only Federal Aviation Administration (FAA) study in the references is dated 1976, clearly inappropriate here. All the sources of information about the alleged bird strikes are personal communication from airport personnel. The fact that there is no reference to any official FAA bird strike reports leads one to worry that the safety aspect is being exaggerated for reasons unrelated to the purpose stated in 1.1, but may be related to the purpose stated in 3.0 and 5.0. The use of the Elmendorf air crash attributed to Canada geese is another attempt to raise emotions about the geese, even though the situation occurred hundreds of miles away. In the Elmendorf crash, the FAA attributed to the failure of airport staff to scare the geese off the runway during a landing. The procedure in place was not followed. Is there an assumption here that the objective is to remove forever all Canada geese around and on the airport? Is there an assumption that any acceptable solution will be to eliminate any responsibility of airport staff to make sure the runways are clear of Canada geese, other birds and other animals?

Methods:

A key phrase in the methodology section is alarming: "The study's limited time frame and budget necessitated a qualitative evaluation of the issues"(3.0, p.2) That is explained by "a computerized literature search and review, as well as interviews with local citizens, and state, federal and university waterfowl biologists of the region." The inference here is that the study will be mostly impressionistic and general.

Section 3.1 outlines the "Field Analysis" which includes "Habitat Mapping" and "Goose Surveys". The habitat mapping included surveys to landowners with farmland and other non-residential property within two miles of the Airport to get information on crop types, rotation schedules, and goose occurrences. There is no evidence of systematic interviews with those who submitted the questionnaires to determine the authenticity of their statements or bias on the part of the landowners. (Would anyone admit to be causing problems for air traffic safety?). The goose survey involved various volunteers and PBS staff collecting observations about the location, time, number of geese, behavior, initial and final direction of flight and approximate height and distance from the observer, location and time of harvest of corn and other grain fields and incidental observations (3.1, p.3).

Section 3.2 outlines the "Office analysis"…including history and historical patterns of Canada geese in South Dakota, specifically Sioux Falls area and interviews with game officials. "All wildlife surveys were analyzed and synthesized for relevant time periods, and appropriate tables and figures were created from relevant data" (3.2, p.3).

What is missing from the study is:

Notwithstanding the simplistic nature of the data collection, the most astounding finding is that the nesting population present in the summer is very small and not a hazard to the airport. PBS Environmental reported that 16 adults and nine goslings were observed. At the sludge ponds associated with the sewage plant, about four adults and seven goslings were observed. Geese were found but not definitely known to nest on Dawn Lake and the Elmwood Golf (sic!) south of the Airport." "After the breeding season ends in mid summer and breeding geese have completed their nesting, most disperse to northern counties to larger lakes for the post breeding period. Goose numbers remain low in Sioux Falls until late summer…they have not been reported to be a risk at the Sioux Falls Regional Airport from early spring to late August/early September"(4.5, p.9)

So the geese that breed in Sioux Falls are few, not a risk to airport safety, not apparently breeding on the airport property, and "disperse" at the end of the summer.

PBS Environmental laid out the patterns of flight across the airport that airport managers claim to be interfering with aircraft and pose a safety problem for passengers. Geese fly mainly between two fields: one adjacent to St. Michael's cemetery one-half mile east of the airport. This field was cut earlier than usual in 1999, according to PBS, because a new housing development began at this site.

The second site is at the southwestern corner of the Airport, though the report is not identifiable in the appendix. "This field has been used increasingly by geese since 1996" (citations omitted). It leads one to wonder if the geese used the east-of-airport site in previous years at all. Geese have used other agricultural fields within a few miles of the Airport that cause them to fly through the approach zone of the Airport, according to airport personnel, but those fields are not identified in the report and the source of the information is unacceptably vague - FAA personnel (4.4, p. 7). The narrative does not give any counts of geese on the Airport except for the sentence: "Small flocks of Canada geese have also occasionally landed on the grassy areas of the Airport during the day."(citation omitted) (4.4, p.8).

The study was being conducted just as one of the main feeding sites - on the east side - was being transformed from agriculture to housing. So it is possible with the loss of the cornfield on the east side the geese will move away from the airport with no changes at all? Was this a one-time problem due to the unique situation on that field? Were there geese on the airport prior to this time? PBS Environmental does not give any data.

Most farmers denied that there were geese on their property. Conflicting reports were given by Col. Rayburn and FAA personnel that there were geese in harvested cornfields near the airport in previous years. (4.4, p. 7). Landowners might not want to acknowledge having geese on their land for fear that they would be forced to change their planting practices. However, if this were the emergency the airport managers said it was, land owners, farmers and everyone would have to comply with efforts to make the airport safe for planes and passengers. To take their assertions of no geese on their fields as fact, especially in light of contradictory claims by airport personnel, is a flaw in this study. Due to the lack of a legend for the "Wildlife Data" section, it is not possible for the reader to determine if the data supports the flight patterns identified

The stated objective: airport safety

PBS Environmental's gives three general solutions for the specific question of airport safety: 1) not planting crops, 2) planting crops that are not attractive to geese and 3) altering existing farming methods to include clean harvest and plowing that reduce the amount of feed available after crop harvest (5.2, p.16). PBS claims that the first two are most likely to be successful because the food source would be eliminated. Is he suggesting the crops be removed or replaced on just the two fields in question (one of which now has housing)? Or is he suggesting eliminating or replacing all the crops in the area? If the former, the geese may simply move to another field if one is eliminated. PBS Environmental does not identify crops that are not attractive to geese or assess the feasibility of switching crops. With regard to "clean plowing and harvest", PBS Environmental does not discuss the feasibility of this or offer any research literature to show this works to keep geese away.

PBS Environmental appears to contradict itself on the matter of people feeding the geese. He claims (but gives no evidence) that the Canada geese were attracted to Covell Lake by people feeding them. "Eliminating feeding of geese at the park may decrease the attractiveness…" but PBS acknowledged that the geese use the park primarily for roosting, not feeding. (5.3, p.16). PBS cites Cooper and Keefe, 1997, as claiming that "restricting feeding programs was not found to be effective in controlling geese." So if that is correct, why - with no data supporting any connection between Covell Lake feeding and the presence of geese - does he even suggest this?

The recommendation to attract geese to other parks and ponds is a puzzle since PBS claims that the literature shows that feeding programs do not maintain the goose population and that the presence of the geese causes controversy among citizens. (5.5, p.18). No scientific literature is given that would allow speculation on aeration of lakes. The recommendation to use border collies is appropriate, but seems to be incidental to PBS.

Since there is little detail here, the airport ends up with a report containing information that they themselves provided and solutions that they already knew about. The data sheets add no information because of the lack of a legend. Essentially, there is no new information to help the airport deal with geese over the airport. In fact, the available evidence suggests that the current so-called safety emergency at the Sioux Falls Regional Airport is exaggerated and situational. The authors did not tell citizens in a straightforward way that the airport already has means at its disposal to solve the occasional situations at the airport. The authors did not tell citizens that the airport already had a depredation permit from US Fish and Wildlife Service to kill geese that were a problem with aircraft and that "about a half dozen" in fact were killed in 1999. While a permit would be required to use a border collie, no permit is needed to negotiate with land owners on crop selection and placement or withholding leases of airport land to farmers.

The second agenda: Population Control 5.6.

PBS Environmental claims that:

However: PBS Environmental does not document the "stocking programs", a major flaw in the study. PBS said these stocking programs have been going on for the past twenty years (p. 5) and situated near the airport. If true, it appears that major goose restoration programs were going on at Sioux Falls, may still be continuing and may be the source of the airport problems (if problems exist). The location, identity, history and processes of "stocking" should have been included as a major source of the airport situation. However, no evidence is given for this claim.

 However, PBS acknowledges that a migrant stream is identified on radar by airport staff as close as 15 miles west of Sioux Falls (p.11). There is would be no way to show, short of banding studies, which geese were part of the alleged "stocked" geese and there is no evidence they are separate from the migrant stream. PBS wants us to believe that, apart from a few strays, that this is some kind of proprietary flock of geese that has its own pathways.

"Showing predictable patterns and congregate in a few areas" would not be any evidence of being a "single coherent population of essentially the same individuals".

The number of "nesting" geese in Sioux Falls has increased from 15,000 in 1980-1984 to 80,000 in 1995-98 (Figure 4, p. 5) though PBS narrative claims they found about 20 breeding pair in Sioux Falls in their study (4.5, page 9). It should be noted that PBS Environmental has misrepresented the data. Figure 4 claims to be the "Canada Goose Breeding Population Data for Sioux Falls." But in the narrative on page 4, PBS claims this data to be South Dakota breeding population data. In any case, there is no data to support the statement that Canada goose nesting populations have dramatically increased…locally. Figure 4 (4.2, p. 5) does not list a citation, but if it is Lee et al, 1984, (from the narrative), citizens should be interested in this publication. It is "the book" on Canada goose restoration in the Dakotas. This was not a series of observations, but a "how to" book on increasing Canada goose populations.

Figure 7 (4.6, p. 11), reported the Sioux Falls Audubon Christmas bird count to be almost none in 1986-1992, leaps to 650 between 1992 and 1993, then drops back to about 200 in 1994, increases slightly to 300 in 1995, drops to under 200 in 1996, increases to 300 in 1997. It is curious that the Audubon Christmas Bird Count for 1998 is not reported here.

Then, PBS Environmental reports a count of 1,600 the first week of October 1999 and a range of 1,600 to 1,900 geese between 27 October and 1 November, a space of three days. Are we to believe that this "single coherent population of essentially the same individuals" of geese went from 300 in 1997 to 1,900 in two years? In 1999, the Sioux Falls Canada goose population "declined to about half of the estimated peak by the second week of November" a time identified as a time with "this subspecies migrates south" (4.6, p. 10). Certainly this is not evidence of a "single coherent population of essentially the same individuals". And which population is it that is migrating south?

Moreover, it should be noted that PBS Environmental misrepresents the data. While stating in the narrative (4.6, p.10) that the goose population declined to half the second week of November, the chart (Figure 6, p. 8) shows that the population dropped more than a half in the second week of October and to more than two-thirds by the third week of October. No data is collected ("Wildlife Data") after November 2.

PBS Environmental additionally misinterprets the Audubon Christmas bird count for South Dakota. "The mid-December count…has usually varied from between 100,000 and 400,000 …and the January count has varied from 40,000 to 300,000" (4.2, p. 5). Figure 5 (4.3, p. 6) shows the December count ranges from 25,000 to 400,000 and the January count between 50,000 and 150,000. Thus a dramatic drop in population from December to January calls into question the accuracy of the comparisons PBS Environmental made between Sioux Falls and South Dakota population.

PBS Environmental is trying to argue the case that the geese that fly in to Sioux Falls are a special group that originated there and are somehow "local" and are increasing at a higher rate (and are therefore in need of "management"). No evidence is given that would allow generalizations that the population is increasing in a way outside the patterns of the normal migratory population. If it were, the study should have examined the causes of such increase.

Conclusions:

The importance of PBS Environmental's study is that it confirms what airport managers and Friends of Wildlife at Covell Lake knew all along: that in 1999 there was a flight pattern over the airport between corn and soybeans fields adjacent to the airport. Although PBS Environmental suggests that Covell Lake halt aeration of the lake, it gives no analysis of why Covell Lake is aerated, or how long, or the correlation of aeration with presence of the geese. Their suggestions on withholding feeding at Covell Lake are based on no evidence of the situation and conflicts with their own stated literature. There is no way for the reader to be convinced about the effectiveness of this strategy.

The solutions presented here are but a laundry list of so-called solutions that have been bounced around game agencies for the past few years in the hopes of continuing the Canada goose restoration programs to increase hunting and the federal and state revenues that are based on land area and number of hunters (Pittman Robertson Act).

Some deserve special comment. (See also a chart of Coalition comments for their entire list.

Citizens should be concerned about proposals advocating hunting on the airport. Wouldn't that create even more risks during the peak sunrise and sundown heavy airport traffic? In any case, there is no evidence presented here that a hunting season on the airport grounds or even in nearby fields would reduce the population of geese on the airport. PBS Environmental may have missed a sentence in its own report (4.1, p. 4) "Once geese have established fall flight patterns to feeding sites they will not readily abandon them even with hunting pressure" (citation omitted). In fact, one should be suspicious that hunting around Sioux Falls might be attracting the geese to the city airport.

What is important here is that even if the Sioux Falls were a discrete body of geese outside the migrant stream, most of PBS Environmental's conclusions will not work, namely hunting, capture and relocation, capture and slaughter.. The airport can protect its flight path and passenger safety with human and border collie harassment and modification of source of food.

It appears that South Dakota taxpayers have funded someone's political projects: to institute revenue-making urban hunting or create revenue-making projects for agencies such as USDA APHIS Animal Damage Control "Wildlife Services" which is usually lurking in the background of these goose kill schemes waiting for contracts to kill and relocate.

 

PBS Environmental's references: The scholarly references are two to three decades old. The "studies" cited are virtually all game agency publications and conference proceedings. Cooper, who has been researching his own round up and slaughter of Canada Geese in Minneapolis and relocating goslings for restoration projects since 1995, has not produced any evidence that hunting, capture and kill or capture and relocate are effective in reducing the number of geese at the Minneapolis airport. Many of the claims in this report, in the guise of data, are from the game agencies that have a vested interest in the goose restoration, urban hunting and capture and kill programs.

The study should be rejected. The suggestions for removing or changing adjacent fields of corn and beans are worth consideration. The Sioux Falls Argus' recommendation of border collies is sound. For those wanting information on a successful case study of goose management, I recommend the "Non-Lethal Controls for 'Resident' Canada Geese" Prepared by the Rockland County Executive Committee of the Canada Geese Citizens' Advisory Committee. This document is available on the internet, along with other references concerning Canada Geese. A copy of the summary of the report is attached.

In a letter to Friends of Waterfowl at Covell Lake, Ron Rathburn, Senior Investigator for PBS Environmental admonishes Friends of Waterfowl to stand aside and not get in the way of implementation of his recommendations. He said: "Because human life is more valuable than human life (sic!), the option of killing geese to protect humans and aircraft needs to be available." Whether Freudian slip or characteristic carelessness, Rathburn reveals the bias underlying his report. The issue of whether a human's life is more valuable than a Canada goose's life is not the question. Rathburn and PBS Environmental never showed that if geese were killed human lives would be protected. So Rathburn would have taxpayers pay for killing geese in programs that will not protect humans. I return at last to the second, but ulterior, motive for the study: the promotion of hunting and the restoration/relocation programs, and the secret $cooky-jar capture and kill programs.

If you have any questions or comments, I would be glad to be of further assistance.

Sincerely,

Ann Frisch, Ph.D., National Coordinator