P.O. Box 917
Pearl River, NY 10965-0917
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Coalition to Prevent the Destruction of Canada Geese P.O. Box 917 Pearl River, NY 10965-0917 |
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May 3, 1998
Mr. Paul R. Schmidt, Chief
The following comments are submitted in response to the recently proposed rule [Federal Register: March 31, 1998 (Volume 63, Number 61) Pages 15697-15705]. For clarity of reference, comments have been inserted into the text of the proposed rule in bold. [Page 15698] DEPARTMENT OF THE INTERIOR Fish and Wildlife Service
50 CFR Part 21
Migratory Bird Special Canada Goose Permit This statement is false: The proposed rule does not establish a "management program". Further, no aspects of the proposed rule are either explained or justified in terms of sound biological principles. In fact, quite the opposite is true. In substance, the proposed rule addresses a matter of bureaucratic inconvenience; no biological or scientific arguments, nor studies, nor data are presented anywhere within the document (or supporting materials) to explain why reducing the administrative work load of the Service would lead to a practical or biologically sound outcome. Problem solving, whether biological or otherwise, can only take place when CAUSES are addressed, not SYMPTOMS. The proposed rule promotes the massive killing of geese (a symptom-based approach), while virtually ignoring the causal origins of the alleged problems: inappropriate suburban landscaping; state and federal wildlife waterfowl propagation programs; farmer feeding incentive programs, etc. ...and more cost-effective... This statement is unsupported. "Cost-effective" is a multidimensional attribute yet no specific cost attributes are specified. The word "more" leads the reader to believe that the current proposal is being compared to some established process that has already demonstrated some level of cost-effectiveness. Yet, no information is provided to suggest that a cost-effective system exists in the first place, let alone whether the proposed permitting process will have any meaningful cost impact or who the beneficiary would be. In principle, symptom-based problem solving, or killing as facilitated by the proposed rule, should generally cost more in the long run. ...and efficient method for the control of locally-breeding (resident) Canada geese... There is no scientific information provided to support the notion that the proposed rule will enhance anything but the efficiency with which geese can be killed on a massive scale. The word "control" must be taken to mean killing, since killing is the ONLY outcome that the proposal facilitates with certainty. Such word-play is being used to water down the true motive of the proposal, which in essence, is to promote unregulated killing of migratory birds. Controlling Canada geese requires that they be alive. Dead geese can't be controlled, and they certainly can't teach other geese to stay out of "problem areas." Further, no biological principles or theories are presented to suggest that killing would give rise to practical effects that resemble "control." It must therefore be concluded that the regulation serves not to address "problem" geese, but rather the fact that the Service is unable handle its responsibility. ...that pose a threat to health... This phrase suggests that Canada geese and, presumably, their droppings are a public health threat so substantial that the massive killing that would result under the proposed rule is warranted. This type of hyperbole suggests that the Service is not above using dishonesty to pursue its goals. It is well established that Canada geese are rarely carriers of human pathogens - a point that has been made in numerous scientific studies and, ironically, by the Service's own Dr. Milton Friend. ...and human safety... There are no cases of Canada geese posing a threat to human safety that cannot be addressed adequately under the present regulations. ...and are responsible for damage to personal and public property. The complaints about Canada geese referred to in the proposed rule are poorly documented. The "damage" that geese are said to cause primarily has to do with goose droppings on turf grass. It is indeed remarkable that the US Fish and Wildlife Service would promote the destruction of wildlife because of allegations that turf grass - an ecologically-invasive collection of non-native plants - is impacted. Any agency that claims to value wildlife while advocating that it be killed on behalf of an irrelevant plant species, clearly lacks the integrity and fortitude to provide the general public with positive wildlife values commensurate with the late-20th century. DATES: The comment period for this proposed rule closes June 1, 1998. ADDRESSES: Comments should be mailed to Chief, Office of Migratory Bird Management, U.S. Fish and Wildlife Service, Department of the Interior, ms 634--ARLSQ, 1849 C Street NW., Washington, D.C. 20240. The public may inspect comments during normal business hours in room 634- Arlington Square Building, 4401 N. Fairfax Drive, Arlington, Virginia. FOR FURTHER INFORMATION CONTACT: Paul R. Schmidt, Chief, Office of Migratory Bird Management, U.S. Fish and Wildlife Service, (703) 358 1714. SUPPLEMENTARY INFORMATION: Background Numbers of Canada geese that nest and reside predominantly within the conterminous United States have increased exponentially in recent years (Rusch et al., 1995; Ankney, 1996).
This statement has no intrinsic practical value. The use of the term "exponential" is a purely manipulative device used to scare the non-mathematical public into feeling that something drastic must be done, namely killing. The implication is that if something is not done, we might wake up one morning to a situation reminiscent of Alfred Hitchcock's movie "The Birds". In fact, nowhere in the country has this oft-cited "exponential growth" been shown to occur at a particularly high level or proceed in an open-ended fashion. In Rockland County, New York, when a controversy surrounding Canada geese began in 1993, there was much talk of "exponential" population growth by state and federal wildlife managers, despite the fact that between 1993 and 1995 the population was declining (in the absence of any lethal actions other than egg addling).
The authors of the Proposed Rule have chosen to adopt the simple but erroneous view that no limiting factors exist to inhibit the growth of regional goose populations. This is a biological absurdity which casts suspicion on the motives of those who invoke it. Are we to believe that areas where geese live, while defined by measurable boundaries, are at the same time of infinite dimensions and resources? Alas, there is not an unlimited amount of goose habitat nor an ever-increasing number of nesting sites, no guaranteed goose-optimal weather patterns, nor a decrease in the territoriality of geese that moderates their nesting density. These geese are sometimes collectively referred to as ``resident'' Canada geese. These increasing populations of locally-breeding geese... The language and spirit of the Migratory Bird Treaty Act sharply contrasts the Service's current attempt to argue that locally-nesting geese are somehow deserving of less protection than others. The Migratory Bird Treaty is quite clear on the issue of protecting Canada geese and their nests, and does so without bias regarding where such nests occur (locally, etc.), nor does it stipulate some minimum migratory distances to which the birds must travel to receive protection. The Service obvioulsy realizes that it must continue to dignify this distinction even though the MBT does not set forth any such distinction. ...are resulting in increasing numbers of conflicts with human activities,... It is apparent that the Service is relying exclusively on the number of complaints to derive sweeping conclusions about the impact of geese. No information is provided to suggest that the Service, as required by the Migratory Bird Treaty Act, has done anything to verify the legitimacy of these so-called conflicts, or that they are in compliance with the conditions set forth in the MBT. ...and concerns related to human health and safety are increasing (Ankney, 1996). "Concerns" are beliefs and often have no basis in reality. The Service has done nothing to correlate "concerns" with reality. People who do not understand the principles of infectious disease may incorrectly presume that goose droppings are a serious health issue. We expect the Service to clarify these misconceptions and defend geese, rather than dignify ignorance and advocate rule changes that will lead to the extermination of wildlife. To date, the Service has attempted to address this growing problem through existing annual hunting season frameworks and issuance of control permits on a case-by-case basis. While this approach has provided relief in some areas, the Service realizes that sport harvest will not completely address the problem...
The Service has attempted to treat the symptoms of a "problem" by relying on the classic wildlife management contradiction. For the record, I remind the Service that wildlife management practices are designed to optimize - not reduce - populations of "target" species, and in turn create economically lucrative "sport" hunting opportunities. The intent of this hunting-biased management is to maintain elevated wildlife populations that bring revenues into state wildlife agencies.
Conspicuous by its absence was any mention of the ongoing efforts by the Service and state "game" agencies, directly and cooperatively, to increase the breeding success of "resident" Canada geese on federal and state wetlands. The proposed rule document confirms the idea that regional wildlife controversies have been, and continue to be, used as public relations gimmicks to con citizens into thinking that, "Things would be better if only there were more hunting." In reality, introducing hunting into more human-populated areas is promoted to offset a declining customer base of hunters and the impact that this has had on the economy of this government-sponsored wildlife killing business. In light of this fiscal motivation, and lack of regard for biological principles, it is no wonder that "sport" killing will not address the concerns of goose complainants. ...and that the current permit-issuance system has become a time-consuming and burdensome process for both applicants and the Service. The current MBT based permit-issuance system exists for a reason. It was designed to insure that the Service would properly fulfill its obligation under the MBTA by carefully evaluating the circumstances surrounding each depredation permit application. Contrary to the backward spirit of the proposed regulation, the MBTA and MBT both place the importance of protecting migratory birds above the convenience and operating comfort of the agency. Therefore, the Service is proposing changes to the way permits for control and management of resident Canada geese that either pose a threat to health and human safety or cause damage to personal and public property are issued under the Migratory Bird Treaty Act by the Service. The Service has a poor track record when it comes to checking the validity of claims that geese pose "a threat to health and human safety or cause damage to personal and public property." Prior to issuing a permit for the killing of hundreds of geese in Clarkstown, NY, this organization informed the Service's permitting officer, George Haas, that many of the town's claims were exaggerated, fraudulent and politically motivated. No effort was made by the Service to investigate this highly controversial situation. Indeed, our concerns were ignored and the permit was rubber-stamped. It appears that under the present permitting system, the Service has abused its authority and issued permits to kill geese despite improper validation of the conditional requirements described under 50 CFR 21.42. It is precisely because such malfeasance has been exposed recently that the subject rule change is being sought with renewed vigor. Presently, the regulations governing the issuance of permits to take, capture, kill, possess, and transport migratory birds are authorized by the Migratory Bird Treaty Act and are promulgated in 50 CFR parts 13 and 21. The geographic scope of this proposed rule is restricted to the conterminous United States and to the two subspecies of Canada geese (Branta canadensis) that nest and reside predominately within the conterminous United States (B. c. maxima and B.c. moffitti), the ``giant'' and ``western'' Canada geese, respectively. Nesting geese within the conterminous United States are considered members of these two subspecies or hybrids between the various subspecies originating in captivity and artificially introduced into numerous areas throughout the conterminous United States. No evidence presently exists documenting breeding between Canada geese nesting within the conterminous United States and those subspecies nesting in northern Canada and Alaska. The geese nesting and residing within the conterminous United States in the months of June, July, and August will be collectively referred to in this proposed rule as ``resident'' Canada geese. The argument of "no evidence" does not mean interbreeding does not occur or to what extent. As worded, the Service is plainly indicating that it doesn't know to what extent the different populations of geese interbreed or otherwise interact. The remaining 9 subspecies of Canada geese recognized in North America nest, for the most part, in arctic and sub-arctic regions of Canada and Alaska (Lack 1974). These subspecies are encountered in the conterminous United States only during the fall, winter and spring of the year, or as a result of human placement. This statement is contradictory. If the 9 subspecies in question nest "for the most part" in Canada where does the lesser part nest? By saying that the these subspecies are encountered in the conterminous US "only" during the fall, winter and spring the implication is that they disappear altogether (off to Brigadoon perhaps?) or can't be unaccounted for. Generally, the Service has stressed the need to manage geese on a population basis, guided by cooperatively-developed management plans. Managing wildlife based on overall population continues to be the primary, yet futile, operating philosophy of the Service. It is a commodity-centered philosophy that utilizes cooperative management so that hunters in different states don't kill each other fighting over the conviction that hunters in other states are being allowed to kill more birds than they are. The significance of this exercise is irrelevant when it comes to resolving conflicts with geese in suburban/urban areas. However, resident Canada goose populations and the development of a resident Canada goose damage management program present several potential problems with this approach. The problems cited regarding population identity are moot, as the total population approach is intrinsically flawed. It is understood that goose "problems" are more site dependent, than they are population dependent (e.g., if by this approach the Service, with regard to the total Canada goose population of a given state, permitted half of the geese to be killed, why would this be expected to provide any significant relief "goose damage"? From a practical standpoint, would a public park with 100 geese be significantly better off with 50? This is doubtful.) Because resident goose populations interact and overlap with other Canada goose populations during the fall and winter, these other goose populations could potentially be affected by any management action or program targeted at resident Canada geese during the fall and winter. Therefore, to avoid potential conflicts with existing management plans for other goose populations,... By this we are to assume that the Service will continue to attempt to increase the population of arctic and sub-arctic nesting geese by creating nesting opportunities in the so-called "resident" range of the conterminous US? The proposed rule should have included studies showing that various waterfowl propagation programs (e.g., The North American Waterfowl Management Plan) are not exacerbating the problem to which this rule making attempts to address. ...the temporal scope of this proposed rule is restricted to the period March 11 through August 31 each year. These dates encompass the period when sport hunting is prohibited throughout the conterminous United States by the Migratory Bird Treaty (1916) and resulting regulations promulgated under the Migratory Bird Treaty Act (1918). Injury/damage complaints occurring during the period September 1 to March 10, the period open to sport hunting, are outside the scope of this proposed rule and will continue to be addressed through either migratory bird hunting regulations or the existing migratory bird permit process. Population Status/Public Conflicts In the early 1960's Hanson (1965) rediscovered the giant Canada goose, then believed to be extinct (Delacour 1954). Hanson (1965) estimated there were about 50,000 of this subspecies left in both Canada and the United States at the time of his survey. In recent years, however, the numbers of these Canada geese that nest predominantly within the conterminous United States have increased tremendously. The term "tremendously" is subjective and has no place in a document alleged to be backed by scientific thinking. Recent surveys in the Atlantic, Mississippi, and Central Flyways (Nelson and Oetting, 1991; Sheaffer and Malecki, 1991; Wood et al., 1994; Caithamer and Dubovsky, 1997) suggest that the resident breeding population now exceeds 1 million individuals in both the Atlantic and Mississippi Flyways and is increasing exponentially. The available data is of woefully inadequate quality to make such strong statements or promulgate regulations. Indeed, it is astounding that the Service might attempt, for one instant, to claim that their policy was based on sound science, given the statistically meaningless data at their disposal. I point your attention to one of the works being relied upon to advance the proposed rule change: "Results of the 1994 Spring Giant Canada Goose Survey in the Mississippi Flyway" Wood, J. C.; Rusch, D. H.; Samuel, M.). Tables 2-9 contain population statistics that are very revealing. Precisely what conclusion can one draw from data whose margin of error frequently approaches and exceeds 100%? For example, in Table 9, a population figure for non-breeding geese in Stratum A of Wisconsin is given as 12,500 with a margin of error of � 25,000. Low-quality data of this sort appears to be the rule regarding so-called resident geese, rather than the exception. This reference does not confer legitimacy to the proposed rule; rather it exposes the decidedly flimsy assertions regarding population. Information from the 1997 Waterfowl Status Report (Caithamer and Dubovsky, 1997) shows that in the Atlantic Flyway, the resident population has increased an average of 17 percent per year since 1989 and currently exceeds 1 million geese. The population figure of 1 million geese appears to be made up. Nelson, H. K. and R. B. Oetting. in "Recent urbanization of Canada geese" indicated that the Fall population of "Giant" Canada geese in the US was a nice round 100,000. This number was not only provided without reference to its scientific derivation, it was suspiciously presented as the sum of non-existent population numbers from all AP states (each state population was denoted with a "-"). While no confidence limits were provided for the population figure, Nelson and Oetting noted on p. 2 that, "While our information on the current population size and distribution of resident Canadas is incomplete, it is clear from field reports that this resource is immense and growing." This is a delicate way of saying, "we don't have a handle on this but anecdotal information indicates something is happening". In the Mississippi Flyway, the resident population of Canada geese has increased at a rate of about 6 percent per year during the last 10 years and also currently exceeds 1 million birds. In the Central and Pacific Flyways, populations of resident Canada geese have similarly increased over the last few years. In some areas, numbers of resident Canada geese have increased to record high levels. The notion of "record high levels" is meaningless from a practical standpoint. The Service is concerned about the rapid growth rate and large sizes of resident goose populations, especially in parts of the Atlantic and Mississippi Flyways. It is unclear that the Service has any accurate idea what the population of "resident" geese is. There are clearly widely-varying methods used to determine population, most of which share one thing in common: they are fraught with exorbitant estimation. Further, in some regions, the management of these large populations of resident Canada geese is confounded by the presence of migratory Canada goose populations that are considered to be below management objectives. A case in point is the migratory Atlantic Population (AP) of Canada geese which [[Page 15699]] nests in northern Quebec and winters in the Atlantic Flyway. The number of breeding pairs of migratory AP geese declined from 118,000 in 1988 to only 29,000 in 1995. While numbers of this migratory population have since increased to 63,000 in 1997, as stated above, Atlantic Flyway resident Canada geese are estimated to have a population now exceeding 1 million. Traditional methods of dealing with the growing resident Canada goose population in the Atlantic Flyway, such as hunting, are not available in areas with migrating and wintering AP geese. The difficulty and challenge faced by the Service and State wildlife management agencies is one of striving to increase the migratory population while simultaneously addressing the problems caused by the growing resident population. Once again, the Service avoids confronting the very real possibility that efforts to enhance the long-range migrant population may be increasing the short-range migrants ("resident") population. In many areas of the country, these burgeoning populations of resident Canada geese are increasingly coming into conflict with human activities. The urban/suburban populations have a relative abundance of preferred habitat provided by current landscaping techniques (i.e., open areas with short grass adjacent to small bodies of water),... The authors of the proposed rule have correctly identified man-made habitats as the primary cause of goose-human conflicts. Ironically, having made this determination, the Service then promptly disregards its significance, preferring instead to continue on toward the goal of facilitating massive goose killing as would transpire under the proposed rule. It is noteworthy that, while various references cited in the proposed rule claim that "resident" populations were showing signs of growth as early as 1986, there is no evidence that the Service attempted to initiate education programs for suburban/urban planners toward the goal of curbing certain landscaping practices. Indeed, to this day, the Service has failed to initiate any programs to educate the public on the possible consequences of certain landscaping practices in certain places by homeowners and those who design outdoor municipal areas. It is remarkable that, while so many consumptive wildlife programs initiated by the Service are long-term in nature, suburban wildlife conflicts are inevitably dealt with in crisis- management mode. ...and this habitat availability combined with the lack of natural predators,... There is no lack of predators for Canada geese in most suburban environments. The primary mode of predation on waterfowl does not lie with the killing of adult geese as much as on gosling predation and egg depredation. Snapping turtles and hawks are abundant throughout the range of "resident" geese, as are raccoons, foxes, gulls, crows, etc., that raid nests for eggs. To suggest that predation mechanisms do not exist or that mammalian predators do not constitute a significant part of population moderation within waterfowl populations is pure fallacy. ...the absence of waterfowl hunting in many of these areas,... The Service readily admits vide infra that hunting is not an efficient means to address the issue of "problem" geese. ... and free handouts of food by some people has served to increase resident Canada goose populations exponentially. This assertion is unsupported by scientific information and makes no sense. It is evident that the Service regards people who feed geese as evil deviants, while regarding those who kill geese for recreation as being of healthy mind. Turf grass must be the form of feeding that impacts regional goose populations, not bread and popcorn. Problem habitat examples include public parks, airports, public beaches and swimming facilities, water-treatment reservoirs, corporate business areas, golf courses, schools, college campuses, private lawns, amusement parks, cemeteries, hospitals, residential subdivisions, and along or between highways. The first two words of this sentence are the most accurate in the entire proposed rule. Yes, the problem is HABITAT, not geese. The proposed rule does NOTHING to address the issue of existing habitat imbalances, nor does it address the creation of future conflict-laden habitats. As a consequence, injury complaints related to agricultural damage and other public conflicts are increasing as resident Canada goose populations increase. The Service has NOT adequately demonstrated the need for the proposed rule through carefully documented goose "problem" assessment. Complaint counts are too superficial upon which to base policy. To date, the Service has attempted to address injurious resident Canada goose problems through existing hunting seasons,... The truth is, the Service always tries to solve wildlife "problems" using weaponry. Ironically, there is little evidence in the wildlife literature that this economically-motivated bias has ever produced a practical outcome for the general public. ...the creation of new special Canada goose seasons designed to target resident populations,... These "special seasons" were designed to force hunting into areas previously off-limits to hunters. Since 1994, the Coalition has monitored these "special Canada goose seasons" in northern New Jersey: an area alleged to be "overpopulated" with geese. At Ringwood State Park, the same scenario was observed on every occasion: 10-15 armed park rangers and NJ DEP personnel closed down a public park so that 3-5 hunters could try to kill some of the 5-12 geese. ...and issuance of permits allowing specific control activities.
The overall guidance for all existing and special hunting seasons
is provided in a 1975 Environmental Impact Statement and a 1988 Supplemental Environmental Impact Statement (U.S. Department of Interior 1975, 1988). In general, the Service's approach has been to support special seasons, and as experience and information are gained, to allow expansion and simplification consistent with established criteria. The original intent of these special seasons was to provide additional harvest opportunities on resident Canada geese while minimizing impacts to migrant geese. This is inconsistent with previous statements of "intent" that claimed that these hunts were to address "nuisance" conditions. Indeed, the Service under pressure from greedy state game agencies, pushed for early and late seasons to provide convenient hunting opportunities to their customers, the "sport" hunters.
The criteria were necessary to control harvests of non-target populations and required States to
conduct annual evaluations. Initially, all seasons were considered experimental, pending a thorough review of the data gathered by the participating State. Early seasons are generally held during early September, with late seasons occurring only after the regular season, but no later than February 15. They are popular with state game agencies because of the revenues these hunts generate through license fees and P-R funds.
Harvest of Canada geese during these special seasons has increased substantially over the last 8 years. In the Atlantic Flyway, 16 of 17 States hold special Canada goose seasons, with harvest rising from about 2,300 in 1988 to almost 124,000 in 1995 (MBMO, 1997). In the Mississippi Flyway, 10 of 14 States hold special Canada goose seasons, and harvest has increased from less than 10,000 birds in 1986 to almost 150,000 in 1995. Michigan currently harvests in excess of 50,000 locally-breeding Canada geese per year. While the opportunities are not as significant in the Central and Pacific Flyways, as areas and seasons have expanded, harvest has increased from approximately 1,300 in 1989 to over 20,000 in 1995. This statement is unsupported. Where have these hunts "helped to limit" the problem? Why are there no references to document this critical claim? How was the problem measured before the hunt and what criteria were used to establish that some "limiting effect" had been achieved? ...many resident Canada geese remain in urban and suburban areas throughout the fall and winter where these areas afford them almost complete protection from sport harvest. The Service realizes that harvest management will never completely address this problem... Of course not. "Harvest" management will never significantly impact geese considered bothersome as long as the Service, individually and cooperatively, continues to manage waterfowl, including Canada geese, for nesting success on wetlands throughout the conterminous US. Further, since the Service has yet to establish any formal criteria for measuring the outcome associated with any lethal action, they are acting out of ignorance and will never address whatever problems exist, or are said to exist, regarding Canada geese. ...and permits to conduct otherwise prohibited control activities will continue to be necessary to balance human needs with expanding resident Canada goose populations. Nothing in the proposed rule or its supporting documents explains how a state of "balance" between human needs will be reached. On the contrary, the proposed rule will accelerate the killing process and create a state of wanton destruction, NOT BALANCE. The imbalances alluded to are due to irresponsible habitat creation and wildlife management; since killing does not address either of these realities, it is by definition illogical and therefore, unacceptable. Complex Federal and State responsibilities are involved with Canada goose control activities. Whatever complexities exist in federal responsibilities regarding Canada goose control do so for a reason, because wildlife is complex and those charged with managing have a tendency for self-serving behavior. The current regulations were designed to provide careful consideration of all actions; the proposed rule will short-circuit the spirit of the MBT in favor of shallow bureaucratic expediency and pressure from state wildlife agencies. All State and private activities, except techniques intended to either scare geese out of or preclude them from a specific area, such as harassment, habitat management, or repellents, require a Federal permit, issued by the Service. Additionally, permits to alleviate migratory bird depredations are issued by the Service in coordination with the Wildlife Services (formerly Animal Damage Control) program of the Animal and Plant Health Inspection Service (APHIS/WS). APHIS/WS is the Federal Agency with lead responsibility for dealing with wildlife damage complaints. In most instances, State permits are required as well.
In practice, the USFWS relies almost exclusively on recommendation/approval by state fish and game agencies in deciding whether to approve a depredation permit. Due to inadequate permit investigation by the Service, it has approved permits that were not in compliance with federal regulations. Indeed, a federal court recently revoked permits issued to the Minnesota DNR for violating these federal regulations. Even when individuals and organizations have pointed out to the Service that certain permit applications were highly questionable, the Service paid no heed. In 1997, a depredation permit was before the Region 5 office for the round up and slaughter of 350 geese from the town of Clarkstown, NY. This organization presented, in writing, to Mr. George Haas compelling reasons as to why the permit should be denied. Haas provided only the most superficial of responses and no investigation was initiated. The Service is clearly collapsing under pressure from state wildlife agencies. This gives rise to a reckless disregard for the provisions of the MBTA and the general public.
The proposed rule is essentially an admission by the USFWS that it is unwilling to uphold its responsibilities as mandated by the MBT. Rather than addressing its own administrative inadequacies and standing up to state wildlife agencies, the Service has chosen to erode the regulations and pass the cost on to geese. A brief summary of the complaints/requests for control permits placed with APHIS/WS indicates the increasing number of public conflicts. The mere fact that the number of complaints are increasing in no way constitutes sufficient justification to make depredation permits easier to get. The Service is operating on several unacceptable assumptions. While it is easy (and the proposed rule teaches us that the Service likes easy answers) to compile numbers of complaints, there is no reason to believe that each complaint is equal in substance. Indeed, experience has shown that many complaints are grossly exaggerated. Before the proposed rule can even be considered, the Service must establish strict guidelines on what conditions constitute a "valid complaint." That no detailed analysis of the complaints was provided suggests that it is the existence of complaints themselves that the proposed rule addresses, not the biology behind the complaints.
In 1996, the APHIS/WS received 3,265 complaints of injurious goose activity (APHIS/WS, 1996). In response to those complaints, APHIS/WS dispersed 513,585 Canada geese. In addition, those 3,265 complaints resulted in APHIS/WS recommending the Service issue 321 permits. Those recommendations included 93 for take, 5 for capture/ relocation, and 238 for egg/nest destruction.
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