1/18/98
Public Comments Submitted on the Plan to Kill Geese in Anchorage are in!

Last fall, the Anchorage, Alaska branch of the USFWS and the Alaska Department of Fish and Game prepared an official proposal (called a Draft Environmental Assessment) recommending that 2000 Canada geese in Anchorage be killed. The story was presented on this web site back in October. Here is the story if you missed it.

In accord with federal regulations, the US Fish and Wildlife Service was obliged to accept public comments on this proposal. These comments were due by November 30, 1997. In advance of this deadline, we encouraged our supporters to write in opposition to the proposal and provided this Action Alert to help with the letter writing process.

After the deadline, the Coalition formally requested, under the Freedom of Information Act copies of all comments received on the Draft Environmental Assessment. The request was granted, and on January 17, 1998, the Coalition received a complete set of the public comments. A summary of nearly 360 comments is presented below.

Overall characteristics: Comments submitted by those in favor of a humane, rational, non-lethal approach to resolving conflicts with geese consistantly reflected a higher level of reasoning (and literacy) than those who wrote in favor of goose extermination. Suspiciously, not a single advocate of goose killing managed to raise any questions about the validity of the Draft Environmental Assessment's assertions - the document was accepted at face value. Indeed, those who expressed the belief that killing was a sensible thing to do, seemed limited in expressing this sentiment by restating the misleading ideas that the authors of the DEA had previously disseminated through the local media and public meetings. Those who made the effort to deconstruct the DEA and challenge its logic found many serious flaws - items that the authors are obliged to address before proceeding any further.

Because the responses fall into a number of different categories, drawing conclusions requires more effort than just counting the number of reponses in favor of killing vs. those oppposed to it (although this type of tabulation is provided). Each category must be evaluated separately. The responses were divided into the following groups, in order of descending number of responses received. Each category will be discussed in more detail below.

• 119 were from students of Anchorage's Wendler Middle School
• 83 contributors filled in a survey form or mailed in a form letter
• 79 Anchorage Bowl (local) individuals
• 52 Alaskans from outside Anchorage
• 12 Alaskan organizations
• 10 individuals and organizations outside of Alaska
• 6 miscellaneous comments received after the deadline

Each Category Analyzed

Wendler Middle School: 119 Letters from Students.

It was deduced (it wasn't stated explicitly) from these letters that the students were given an assignment to write to the US Fish and Wildlife Service in Alaska in response to an article on this issue that appeared in the local newspaper. Further, it appears that the students were asked to include suggestions on how they would handle the goose situation.

Due to the brevity of student comments, they could be categorized based on what form of control they favored. Most students favored non-lethal control.

Examples of student letters are provided below. Please note that the text of these letters is reproduced as the students wrote them.

More Letters Like This One

More Letters Like This One

83 Form Letters

This, the second largest category, was dominated by a form letter obviously created by members of the DEA booster club:

Form Letter 1

Anchorage Goose Management Plan Comments Ms. Karen Laing U.S. Fish and Wildife Service Migratory Bird Management 1011 E. Tudor Road Anchorage, AK 99503 Dear Ms. Laing, Of the five options that were presented in the Environmental Assessment I believe the option checked below would be best suited for our community. A: Status Quo - No Goose Management Plan B: Population Goal 4,000 Geese C: Population Goal 2,000 Geese D: Population Goal 1,000 Geese E: Population Goal 500 Geese Because: ____________________________________________________________________ ___________________________________________________________________________ ___________________________________________________________________________ Please keep me informed for further discussion and opportunity for public input. Please send me a copy of the final environmental document and Management Plan. Thank you for the opportunity to comment. Sincerely,

A version of this form letter appeared in the local newspaper on two different occasions. In one printing, it was part of a paid propaganda advertisement put out by Elmendorf Air Force Base.

This campaign was obviously spearheaded by US Fish and WIldlife Service collaborators. These responses should be completely disregarded because:

1. In principle, form letters do not constitute "comments" of substance regarding the DEA - they represent an attempt to take a vote on an issue that can not be reduced to a series of check-boxes. While the form letter tried to extract a justification from the respondents by including a few blank lines, very few people wrote much of substance.

2. The form letter forces respondents to choose between Alternatives A-E of the DEA without mentioning that most of them involve massive killing. Why wasn't a "None of the above" choice offered? Indeed, the only information provided is how many geese will allegedly result under each option.

3. The form letter leads the respondent to believe that the Alternatives presented are the only options available. In statistical circles, this bias is often referred to as "asking a leading question."

Among these letters was a small number of another "form letter," one whose origin is unclear. The letter (below) asks that non-lethal methods of goose control be used.

Form Letter 2

Given the manipulative nature of Form Letter 1, no meaningful conclusions can be drawn from the responses in this category. Nevertheless, the overall counts are as follows:

[Note: The 19 anonymous submissions would have to be discarded for the following reasons: 1. There is no way to know if they are duplicate submissions, and 2. Admissible comments on a DEA must include the submitter's name.]

79 Anchorage Individuals (comments on the DEA from local residents)

This is perhaps one of the most significant categories because it consists of people expressing their personal thoughts on the DEA. Those in favor of non-lethal methods of control dominated.

52 Alaskans Outside of Anchorage.

This was a very strange category. Respondents were mostly from an area called the Kenai Peninsula (in particular towns called Homer and Soldotna). Apparently, the vast majority of people in this region WANT the Anchorage geese. Their letters read like requests: "Could I get 400 geese for my property." Only one or two of the many letter writers requesting relocation of the geese to their area mentioned hunting opportunities as the motivation, although the consistency of the requests was very suspicious. Unless they said "I'm against killing," "relocation" was placed in a separate count category. One possible explanation for the desire to import geese is that native people living in this region desire the geese for subsistence purposes.

12 Alaskan Organizations

The data for this category are all over the place. Those familiar with the politics of local Audubon Chapters will be surprised to see that the Anchorage Audubon Chapter called for a two-year moratorium on killing to give non-lethal methods a chance. This is in contrast to the wishy-washy Alaska branch of the National Audubon Society that, for no particular reason, advocated both lethal and non-lethal methods. The organizations requesting relocation were from the regions described above.

The breakdown is particularly scattered, although lethality did not prevail:

10 Individuals and Organizations from Outside Alaska

This category was dominated by very detailed comments regarding the DEA, including the comments submitted by the Coalition. It will be interesting to see how the US Fish and Wildlife Service responds.

6 Miscellaneous Late Submissions

Final Comments