Dear Mr. Schmidt,

This letter is in response to the proposed rule "Migratory Bird Special Canada Goose Permit" (Federal Register March 31, 1998, 63, 61, 115697-15705).

I am strongly opposed to this proposal. As a citizen of Michigan, a state that is now using (experimental) nonlethal methods to control Canada goose populations, it is reprehensible to me that this "Special Goose Permit" is even a consideration.

In Michigan, several groups are working as volunteers with the MIDNR as trained "Goose Patrols," implementing nonlethal methods of controlling the Canada Goose population. With this type of volunteerism, which is typical, there should be no need for special permits for lethal means for unproven attempts to control populations. Besides that fact, I have other concerns.

The largest factors that come into play concerning the proposed rule, is the lack of facts, as well as the lack of scientific data to support much of the proposal. See the following examples:

**There is no scientific data to support the USFWS claims that geese are a threat to public safety.

**There is no biological evidence that increased killings will solve human problems with geese.

**The USFWS has been managing Canada geese in the US for increased populations for "sport hunting" opportunities, then trying to "solve" the overpopulation is an oxymoron at best, if not flagrant dishonesty.

According to the Migratory bird treaty, the Federal government may authorize the killing of migratory birds only if they are seriously injurious to commercial interest - not personal property. Otherwise, there would be no need for federal protection in the first place.

Another issue that has me perplexed; donation of goose bodies to the poor and/or elderly. To donate the goose bodies to charity without testing (which requires more manpower/workload) would be a mistake, since some geese have high levels of toxic chemicals that could cause harm to the poor and/or elderly. Many charities will not even consider accepting the bodies.

I am also concerned at the lack of a mechanism for allowing input from citizens (like myself), who may be opposed to the roundup of geese. There is no provision for publication in the Federal Register, public hearings, or comment periods. I hope if this rule is implemented, that there is an added provision that allows for public comment, as well as the publication of the permit in newspapers of the county where the permit is issued.

I would also like to request that you provide me with a copy of your final report (on this proposed rule.)

Sincerely,

Lori K. Godzik
P.O. Box 250
Algonac, MI 48001