Last year, the US Fish and Wildlife Service (USFWS) set out to change federal regulations regarding Canada geese that reside in the United States during the spring and summer.

Despite its lack of legal authority to do so (under the Migratory Bird Treaty), the USFWS continues its efforts to whittle away at what little protection is left for these birds and to make it easier to kill them under federal regulations.

Wildlife protection organizations have argued for years that even under the existing system, killing permits are much too easy to obtain and are being issued under false pretense. The USFWS has routinely ignored documented examples of permit application fraud.

Representatives from the USFWS have stated publicly that they do not validate the justification provided by killing permit applicants -- they rely on the discretion of state wildlife agencies. State wildlife agencies are required to "co-sign" the permit application before the USFWS will approve it. Once the state agency "co-signs," the USFWS rubber stamps the permits without question. State wildlife agencies have proven to have a not-so-subtle bias toward killing in all but the rarest of circumstances. Indeed, they actively engage in spreading inaccurate and misleading information about Canada geese to justify killing programs.

Many geese have been needlessly and illegally killed under permits from the USFWS. It is clearly already too easy to obtain killing permits without legitimate justification.

The USFWS has, in the past, proposed various changes to federal regulations that would make it easier and easier to kill Canada geese. These attempts have succeeded despite majority opposition during written public comment periods. Apparently, even bureaucrats at the USFWS may have recognized that this pattern of ignoring the public looks a bit suspicious. In their most recent attempt to create policy that would facilitate an unregulated slaughter of Canada geese, the USFWS chose to broaden the scope of public participation by adding oral comment sessions around the country. The obvious goal was to pad the lethal comments by tapping into their traditional lethal-minded supporters (e.g., hunters and farmers) to offset the usual public opposition.

To begin the process, the USFWS asked the public which of six alternatives, A-F, for managing Canada geese they would prefer. The Alternatives ranged from leaving the killing-centered system "as is," in Alternative A, while adding successively more destruction, killing and unaccountability, culminating in Alternative F. Their approach was tantamount to asking a no-win question such as: "Have you stopped cheating on your income tax yet?" Either way you answer, you lose. In this case, geese end up paying the price.

The Coalition developed the idea of a counter-alternative called "Alternative G."

According to the USFWS analysis of written comments, public support for "Alternative G" exceeded the support received from all other proposed Alternatives -- A - F combined. While not all commenters chose from among the USFWS Alternatives or Alternative G, overall 1,758 out of 2,979 (ca 60%) of the written comments received by the USFWS supported non-lethal control -- these respondents most probably also expressed opposition to the expansion of lethal management policies.

What will the USFWS do?

The Coalition anticipates that, true to past performance, they will disregard majority public opinion completely, ignore scientifically valid challenges to their policy proposals and proceed with plans to create regulations that would lead to the wanton destruction of our country's wildlife.

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