Mr. Schmidt,

I submit the following comments for the proposed rule "Migratory Bird Special Canada Goose Permit" (Federal Register 31 March 1998).

In my experience, there is no justification for removing the protection of law from these birds. There is no substantive threat to human health from the presence of these birds in the community. The occasional challenge from a male goose defending his nest certainly is not sufficient to justify the widespread slaughter that is anticipated if the game departments are responsible for carrying out the functions of the Migratory Bird Treaty Act.

I would be concerned about people eating birds who reside on golf courses and parks, given the amounts of pesticides and herbicides that are present there. Geese feed from toxic waste sites and one could never know where a given bird had been before the body of the killed individual was donated to a family. I would think the practice of donating these birds to charity to be very ill advised.

In terms of the humanity of the plan, I cannot see how one could justify the separation of these birds from their offspring and mates to be crated and shipped, then slaughtered. Nor would it be humane to shoot them, leaving offspring and mates and devastating their communities. Furthermore, this proposal sends an extremely detrimental message to people, particularly our children. Our society desperately needs to foster a greater respect for the other creatures with whom we share this planet. This proposal is the antithesis of such an aspiration.

I hope that you will reconsider your proposal and not implement this rule. If you choose to implement it regardless, please consider requiring public notice at all locations and require public hearings so that citizens can be heard about their concerns.

With reverence for all life,

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