GARY L. PEARSON, D.V.M.
1305 Business Loop East
Jamestown, North Dakota 58401

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May 30, 1999

 

Mr. J. Gary Oldenburg
State Director, WA/HI/AK/GU
U. S. Department of Agriculture
Animal and Plant Health Inspection Service
Wildlife Services
720 O’Leary Street, N. W.
Olympia, Washington 98502

Dear Mr. Oldenburg:

I would like to request that the following comments be included in the official record of review of the ENVIRONMENTAL ASSESSMENT Predecisional Document for Public Review, April 22, 1999, for the Management of conflicts associated with non-migratory (resident) Canada geese in the Puget Sound area prepared by the United States Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS), Wildlife Services (WS), in consultation with the United States Department of [the] Interior, Fish and Wildlife Service and Washington Department of Fish and Wildlife.

Because the EA/PD is based on the same premises and proposes the same kinds of actions as-- and incorporates a number of statements virtually verbatim from--the U. S. Fish and Wildlife Service’s ENVIRONMENTAL ASSESSMENT: PERMITS FOR THE CONTROL AND MANAGEMENT OF INJURIOUS RESIDENT CANADA GEESE, I would request that the enclosed copy of my comments on the Fish and Wildlife Service’s AUGUST, 1996, DRAFT ENVIRONMENTAL ASSESSMENT: PERMITS FOR CONTROL OF INJURIOUS CANADA GEESE be included in the record as an attachment to these comments.

1.0 PURPOSE AND NEED FOR ACTION

1. Introduction

According to the ENVIRONMENTAL ASSESSMENT Predecisional Document (EA/PD):

". . . as [Western Canada] goose numbers increased, so did many of the problems that they caused [citations omitted]. Concentrations of geese in the vicinity of airports have posed threats to safe aircraft operations [citation omitted]. Canada geese and their droppings have caused property damage in both public and private settings [citation omitted] public beaches and swimming areas have been closed, and numerous parks and athletic fields have been contaminated with fecal matter. Pubic involvement has also documented a negative impact on the quality of life of many residents, due to what many consider an overabundance of Canada geese." (p. 1)

and:

"The purpose of this Environmental Assessment (EA) is to evaluate issues and alternatives for managing damage caused by resident Canada geese, and to develop future management options in the greater Puget Sound area." (p. 1)

1.4 Need for Action

In the Section 1.4 Need for Action, the EA/PD states:

"Increasing populations of these locally-breeding geese [citations omitted] are resulting in increasing numbers of conflicts with human activities [citations omitted], and increasing concerns related to human health and safety [citations omitted]. There is a direct link between the number of resident Canada geese and the amount of damage inflicted upon a community. This direct link sometimes requires that WS indirectly manage local populations while fulfilling its authority to manage damage." (p. 5)

In evaluating the EA/PD, it is necessary, therefore, first to consider the "damage inflicted" by Western Canada geese in the Puget Sound area that is identified in the EA/PD as the basis for the actions which are proposed.

Threat to Human Health

Coliforms

The EA/PD states that a foraging Canada goose produces approximately three pounds of feces every day (p.7), but it fails to point out that the cloacal excrement of birds contains both fecal and urinary components and, therefore, has a high water content. Consequently, to be meaningful, comparisons of fecal output from Canada geese with that of mammalian species would have to be done on a dry weight basis with the urinary component subtracted. In addition, it is necessary to distinguish between the fecal output of the various subspecies of Canada geese, which range from the three-pound cackling Canada goose (Branta canadensis minima) to the nine-pound Western Canada goose (B. c. moffitti) to the 12-pound giant Canada goose (B. c. maxima) (Belrose, 1976). Consequently, the general statement that a foraging Canada goose produces three pounds of feces a day provides little useful information.

The EA/PD cites eight beach closings in two counties in 1998 resulting from high fecal coliform levels, and says that geese and ducks were identified (by RNA analysis) as the principal source of the fecal contamination at one of those beaches (p. 7). In addition, it cites one apparently undocumented incident where a cafeteria "was also closed due to coliform contamination from goose fecal matter being tracked in" (p. 7.). The EA/PD then states that:

"Although it is uncertain whether the E. coli found in goose feces causes illness in humans, people have been reported to have become sickened after swimming at contaminated beaches (public involvement)." (p. 7)

From this, the EA/PD goes on to state that:

"Most people would agree that exposing the public to high levels of potentially hazardous bacteria should be avoided, regardless of the source." (p. 7)

Thus, based on eight beach closings in 1998 due to fecal coliform contamination, only one of which was shown to have resulted from "geese and ducks," and one undocumented cafeteria closing alleged due to goose feces, but without any evidence that the feces of free-flying waterfowl contain significant levels of bacteria pathogenic for humans, the EA/PD extrapolates this absence of evidence that feces from free-flying Canada pose a significant threat to public health into the unsubstantiated insinuation that Canada goose feces contains" high levels of potentially hazardous bacteria." Certainly, high levels of potentially hazardous bacteria should be avoided, but EA/PD provides no evidence that Canada geese are a significant source of such bacteria.

In fact:

"Avian strains of E. coli are not recognized as important causes of infections in other animals, including man. Most serotypes isolated from poultry are pathogenic only for birds." (Gross, 1991)

"Chickens, however, are susceptible to colonization with E. coli O157:H7, an important enterohemorrhagic pathogen of humans." (Barnes and Gross, 1997)

and:

"Between 0.5 and 6% of eggs from normal hens contain E. coli." (Barnes and Gross, 1997)

Thus, based on the scientific evidence which is not considered by the EA\PD, chicken eggs in home kitchens and cafeterias in the Puget Sound area undoubtedly are a much more significant potential source of pathogenic E. coli for humans than are the non-migratory Canada geese.

Because the EA/PD does not compare the contribution to fecal coliform contamination of waters from non-migratory Canada geese with that from domestic animal and human sources, both of which are much more likely to include human pathogens, the EA/PD fails to show that any of the action alternatives considered in the EA/PD for addressing non-migratory Canada goose issues would have a significant impact on fecal coliform levels at beaches and other waters of the Puget Sound area.

Rather than presenting an objective and factual discussion of the threat to human health posed by coliforms from non-migratory Canada geese in the Puget Sound area, the EA/PD attempts to alarm the public with unsubstantiated and unwarranted speculation about an undocumented and insignificant problem.

Cryptosporidiosis

The EA/PD states that:

"Cryptosporidiosis is recognized as a disease with implications for human health." (p. 7)

The statement is documented and it is true.

The EA/PD then states that:

"It [cryptosporidiosis] is a disease carried by waterfowl, caused by the parasite Cryptosporidium parvum." (p. 7)

The statement is not documented and lacks foundation in scientific fact. Cryptosporidia are ubiquitous protozoan parasites belonging to the coccidia group, and various species are known to infect a wide range of vertebrates, including reptiles, birds and mammals. Of the dozen or more species of cryptosporidia identified, two may infect mammals. Cryptosporidium muris infects mice, and C. parvum infects a wide range of mammals, including mice, dogs, cats, cattle, sheep, goats, swine, several species of wild ungulates, and humans. C. parvum does not infect birds. C, baileyi and C. meleagridis infect both chickens and turkeys (Current, 1997), but C. baileyi is the only species known to infect waterfowl (Wobeser, 1997).

C. parvum is the only cryptosporidian species pathogenic for man, where it generally causes an acute, self-limiting diarrhea and abdominal pain of 5 to 10 days duration. However, in humans with compromised immune systems, particularly those with acquired immunodeficiency syndrome (AIDS), infection may result in a severe and debilitating chronic diarrhea that is refractory to treatment.

Human-to-human transmission of C. parvum occurs within families and in day-care settings, but most epizootics of cryptosporidiosis in humans result from drinking water contaminated with domestic animal or human feces. Cattle, sheep, goats, and swine, particularly young animals with diarrhea, most frequently are implicated as the animal reservoirs for human infections. Consequently, runoff from pastures, feed lots, other domestic animal holding facilities or sewage treatment plants are common sources of contamination of surface waters. Cryptosporidium oocysts (the form shed in the feces of infected animals) are highly resistant, surviving exposure to most disinfectants except steam, and they can be found in 90% of untreated municipal water supplies. The oocysts are not killed by chlorination and they can be removed from drinking water supplies only be sophisticated filtration systems.

The statements in the EA/PD that cryptosporidiosis has implications for human health and is a disease carried by waterfowl clearly implies that waterfowl are a major, if not the primary, source for the disease in humans. However, this implication is categorically false and it grossly misrepresents the epizootiology of cryptosporidiosis.

According to the EA/PD:

"The public is advised to be careful when swimming in lakes, ponds, streams and pools, to avoid swallowing water while swimming, and to avoid touching fecal matter (Colley, 1996)." (pp. 7-8)

However, examination of the paper by Colley (1996) on "Waterborne Cryptosporidiosis Threat Addressed" that is cited as the authority for this statement reveals that it deals with the development of regulatory standards for Cryptosporidium in drinking water, but it says nothing about swimming in lakes, ponds, streams and pools or the avoidance of fecal material, nor does it mention waterfowl as being a source of Cryptosporidium for humans. Therefore, this statement in the EA/PD misrepresents the scientific literature it cites.

Finally, the EA/PD asserts that:

"It has been shown, using molecular techniques, that Canada geese disseminate infectious Cryptosporidium parvum oocysts in the environment (Graczyk et al. 1998)." (p. 8)

However, examination of the paper by Graczyk et al. (1998) shows that it really said:

"Cryptosporidium parvum is unable to establish intestinal infection in birds [citations omitted], and therefore we conclude that the infectious C. parvum oocysts were acquired by the birds from their natural habitat. . . The Eastern Shore of Maryland is a predominantly agricultural region with scattered cattle farms, and migratory geese were actually observed to wander behind the cattle and pick up undigested corn from their feces. Previous studies showed that approximately 25% of C. parvum oocysts administered orally to geese and ducks was recovered [citations omitted]; thus geese in the present study may actually ingest higher numbers of oocysts than we recovered. . . The present study provides clear evidence that birds can act as mechanical carriers of infectious oocysts of C. parvum and can disseminate these oocysts in the environment, including drinking water supplies."

Thus, the study shows that Canada geese may ingest C. parvum oocysts deposited in the environment by livestock, but passage through the digestive tracts of the geese removes up to 75% of the oocysts. Although Canada geese might have the potential to disseminate infectious oocysts to uncontaminated waters, with 90% of untreated municipal water supplies already contaminated with C. parvum, this would appear to be a rare event. The more common situation would be that the geese return to water bodies within the same watersheds where they feed and where they ingest C. parvum oocysts from domestic livestock. Because runoff from those contaminated watersheds is likely to be the principal source of oocysts in those waters, by removing up to 75% of the oocysts they ingest, Canada geese may actually reduce the oocyst load reaching those waters.

The EA/PD does not cite a single documented case of cryptosporidiosis in humans contracted from Canada geese. More importantly, it does not cite any credible scientific evidence to substantiate the implication that non-migratory Canada geese are a significant source of cryptosporidia causing disease in humans.

Giardiasis

The statements that giardiasis is caused by Giardia lambia (G. intestinalis), that it is recognized as one of the most common causes of waterborne disease in humans in the United States, and that it is contracted by the ingestion of water or other material contaminated with fecal material from infected animals are true. However, the subsequent statement that:

"Giardia sp. oocysts have been found in the feces of Canada geese (Graczyk et al. 1998) and may have serious implications for the contamination of watersheds (Davidson and Nettles 1997, Smith et al. 1997, Upcroft et al. 1997. In Graczyk et al. 1998)." (p. 8)

seriously misrepresents the evidence regarding the role of Canada geese in human giardiasis.

First, giardiasis is the most commonly diagnose intestinal parasite in humans in North America (Taboada and Merchant, 1995), with prevalence rates as high as 20% (Dimski, 1994). Giardiasis is especially prevalent in infants and children in day care facilities (Taboada and Merchant, 1995). Although the prevalence of giardia infection has been reported to be as high as 8% in dogs and 4% in cats, epidemiologic studies have not shown that pet ownership is a significant risk factor for giardiasis in humans (Taboada and Merchant, 1995).

Wobeser (1997) does not list Giardia infection among the diseases of wild waterfowl, and Graczyk et al. (1998) simply reported the presence of Giardia sp. cysts in the feces of Canada geese, but noted that:

"Because avian giardiasis produces a minimum number of cysts [citation omitted] and this pathogen was not previously reported from the Canada goose, it is possible that Giardia cysts were acquired by the birds in their natural habitat."

and the citation for their statement that avian Giardia cysts are potentially a danger for humans is a report on an isolate from a wild-caught sulphur-crested cockatoo.

The EA/PD cites absolutely no credible scientific evidence to show that non-migratory Canada geese are a significant source of Giardia infection for humans, but instead attempts through unsubstantiated speculation and unwarranted insinuation to create the impression that non-migratory Canada geese have "serious implications" for transmitting Giardia to humans.

Salmonellosis

The statement in the EA/PD that salmonellosis is contracted by handling materials soiled by bird feces (p. 8) is not an accurate representation of the epidemiology of human salmonellosis, because salmonellae are found in a large variety of mammals, birds, reptiles and insects (Greene, 1995). From 1 to 36% of dogs and from 0 to 14% of cats have been reported to be infected with Salmonella (Greene, 1995). In the United States, 51% of human food-borne bacterial disease has been reported to be caused by salmonellae which frequently are found in domestic poultry (Gast, 1997). In fact:

"Poultry products are consistently identified as important sources of salmonellae that cause illness in humans. More than one-third of food-borne salmonellosis outbreaks in humans in the United States between 1983 and 1987 were associated with poultry meat or eggs [citation omitted]." (Gast, 19970)

The statement in the EA/PD that:

"Paratyphoid infections are frequent in waterfowl (Stroud and Friend 1987)" (p. 8)

also seriously misrepresents the role of wild waterfowl as sources of salmonellae in humans. What Stroud and Friend (1987) actually said was:

"Paratyphoid infections occur in most species of warm- and cold-blooded vertebrates, are more prevalent in turkeys than in any other domestic birds, and are common in young domestic geese and ducks, pigeons, and many species of wild birds (Fig. 9.1)." (Emphasis added.)

And, Figure 9.1 in the publication by Stroud and Friend (1987) simply shows the "Relative occurrence of three types of salmonellosis in selected avian species." Although paratyphoid infection is shown by a crude four-point system to be frequent in ducks, geese and swans, there is no distinction between domestic and wild waterfowl, nor are any figures provided to show the actual prevalence of salmonellae in wild waterfowl. Furthermore, none of the three references listed in the publication by Stroud and Friend (1987) indicates that salmonellae are common in free-flying wild waterfowl (Steele and Galton, 1971; Williams, 1984; Wobeser, 1981). In fact, Steele and Galton (1971) do not list a single isolation of Salmonella from wild waterfowl in North America.

The EA/PD cites no credible scientific evidence to substantiate the insinuation that non-migratory Canada geese are a significant potential source of salmonellae for humans.

Chlamydiosis

The irrelevance of the statement in the EA/PD regarding chlamydial infections being common in waterfowl to a human health threat posed by non-migratory Canada geese (p. 8) is demonstrated by the preceding statement in the EA/PD that chlamydiosis "is contracted by direct contact with infected birds and inhalation of the causative organism in airborne particles" (p. 8). (Emphasis added.) Clearly, few people have direct contact with non-migratory Canada geese even when the geese are in the immediate area.

Chlamydiae have been reported in 159 species of birds, including 139 wild bird species, of which 114 species have documented infections in the free-living state (Brand, 1989). However,:

"Seventy percent of the 1,025 [human] cases reported to the [Centers for Disease Control] during the 10-year period from 1975 to 1984 (where the source of infection was known) were the result of exposure to pet cage birds. Those at highest risk of acquiring chlamydiosis included bird owners or fanciers, pet shop employees, or pigeon fanciers. This group accounted for 62% of the risk. People who were not bird owners, for the most part exposed in some way to pet birds or pigeons, accounted for another 9%. . . ." (Williams, 1989)

and:

"The avian strains of C[hlamydia] psittaci can infect humans, and precautions should be taken when handling infected birds or contaminated materials. Human infections are common following handling or processing infected turkeys or ducks. Most infections are through inhalation of infectious aerosols; therefore, processing plant employees are especially at risk. Also at risk are farm workers and poultry inspectors at processing plants. Personnel who are employed to process turkey meat have also become infected . . ." (Emphasis added.) (Anderson et al., 1997)

Consequently, it is the very control programs proposed in the EA/PD involving the capture, euthanasia and processing of geese which present the greatest public health risk for humans contracting chlamydiosis from non-migratory Canada geese in the Puget Sound area. For other people in the area, however, the risk of contracting chlamydiosis from domestic and cage birds is far greater. Thus the EA/PD cites no evidence that non-migratory Canada geese pose a risk for transmitting chlamydiosis to anyone in the Puget Sound area except those who would be implementing the programs proposed in the EA/PD or handling the processed geese.

Schistosomiasis

The EA/PD states that:

"Geese can also act as a host in the life cycle of the schistosome parasites which cause cecarial dermatitis ("swimmers itch") in humans [citations omitted]." (p. 8)

but it does not provide any information on the occurrence of schistosome dermatitis in the Puget Sound area or on the contribution of non-migratory Canada geese to any "swimmer’s itch" problems that might occur. Consequently, the EA/PD provides no evidence that schistosome dermatitis is a significant problem related to non-migratory Canada geese in the Puget Sound area, or that and of the action alternatives proposed in the EA/PD to control non-migratory Canada geese in the area would have a measurable impact on any such problems that might exist.

It should be noted that other migratory birds besides waterfowl, as well as muskrats, may serve as definitive hosts for the schistosomes that cause human schistosome dermatitis, and that snails usually are the intermediate hosts (Plorde, 1977). Therefore, eliminating non-migratory Canada geese will not control "swimmer’s itch." In fact, considering that the control of schistosome dermatitis generally is directed at reducing snail populations (Plorde, 1977), and that many waterfowl actively feed on snails, it is reasonable to postulate that removing non-migratory Canada geese and feral waterfowl actually would be more likely to exacerbate "swimmer’s itch" problems. Finally, it should be noted that immediate drying with a towel after swimming is helpful in preventing the development of schistosome dermatitis (Plorde, 1977).

Influenza A Viruses

The statements in the EA/PD that influenza A viruses are known to emerge from the aquatic avian reservoir and cause human pandemics and that virtually all influenza viruses in mammalian hosts originate from the avian gene pool appear to be intended to imply that non-migratory Canada geese represent a significant potential source of influenza A viruses for initiating epidemics in humans in the Puget Sound area. However, this implication seriously misrepresents the epidemiology of influenza A viruses and the public health threat posed by non-migratory Canada geese.

Wild water birds are considered to be the natural reservoirs of influenza viruses (Wobeser, 1997), and there is evidence that some human influenza A virus strains have contained avian genetic material and that either genetic material or intact avian viruses have been transmitted to swine, horses, mink, seals and whales (Webster et al., 1992; Lin et al., 1994; Easterday et al., 1997).

It is instructive to note, however, that:

"Although evidence for the infection of wild birds existed prior to the 1970s, it was not until then that the high infection rate among migratory waterfowl was recognized. Surveillance studies revealed the widespread distribution of influenza viruses in these birds, particularly ducks [citations omitted] and more recently shorebirds [citation omitted]. . ." (Emphasis added.) (Easterday et al., 1997)

and:

"Avian influenza viruses are distributed throughout the world in many domestic birds, including turkeys, chickens, guinea fowl, chukars, quail, pheasants, geese, and ducks, and in wild species, including ducks, geese, sandpipers, ruddy turnstones, terns, swans, shearwaters, herons, guillemots, puffins, and gulls [citations omitted]. Migratory waterfowl, particularly ducks, have yielded more viruses than any other group, while domestic turkeys and chickens have experienced the most substantial disease problems due to influenza. Influenza viruses have also been isolated from caged birds, including mynahs, parakeets, parrots, cockatoos, weaverbirds, finches, and hawks [citations omitted." (Emphasis added.) (Easterday et al., 1997)

It is important also to recognize that direct transmission of intact influenza A viruses from migratory waterfowl to humans not been demonstrated to occur. However, it is clear that whatever hypothetical risk the 13,500 non-migratory Canada geese in the Puget Sound area (EA/PD p. 8) might pose for contributing avian influenza A virus genetic material to new human influenza virus strains would be infinitesimal in comparison with the potential from the 90 million migratory ducks on North America and the tens of thousands of gulls and other water birds in the Puget Sound area. Of course, human contact with these wild species provides far less direct exposure than with the thousands of domestic chickens and turkeys and cage birds in the area.

Not only does the EA/PD cite no credible evidence that the non-migratory Canada geese in the Puget Sound area constitute a significant threat for introducing influenza A viruses into the human population, but it provides no evidence at all to demonstrate that any of the action alternatives considered in the EA/PD would measurably reduce any hypothetical risk that might exist for transmission of influenza A viruses from avian reservoirs to humans in the area.

Avian Tuberculosis

The statement in the EA/PD (p. 8) that, despite the fact that its prevalence in waterfowl has not been determined, there are many authenticated cases of Micobacterium avium infection in humans implies that non-migratory Canada geese pose a significant hazard for transmitting M. avium to humans.

Although tuberculosis is a common disease in captive waterfowl, the prevalence is higher in ducks and swans than in geese (Wobeser, 1997). However, the prevalence of tuberculosis in free-flying wild waterfowl is reported to be from 0.3% to 0.6% , compared with 10.3% infection reported in gulls (Wobeser, 1997), and:

"Tuberculosis appears to be most prevalent among species, such as House Sparrows and Starlings, that live in close association with livestock and in scavenging and raptorial species." (Wobeser, 1997)

In addition, human M. avium infections are most common in patients with acquired immunodeficiency syndrome (Thoen, 1997).

The EA/PD has cited no evidence that non-migratory Canada geese in the Puget Sound area have a significant rate of M. avium infection or that they pose a significant pubic health hazard for transmitting avian tuberculosis to humans, that any such hazard that might exist is not inconsequential compared with other sources of M. avium in the area, or that any of the action alternatives considered in the EA/PD would significantly reduce any such risk that might exist from non-migratory Canada geese.

Campylobacteriosis

The EA/PD (p. 9) acknowledges that transmission of disease or parasites from geese to humans has not been well documented, but says the potential exists. In support of this statement, the EA/PD (p. 8) cites one report by Wobeser and Brand (1982) of two biologists contracting chlamydiosis while investigating waterfowl disease events, a paper by Blankenspoor and Reimink (1991) on controlling "swimmer’s itch" in Michigan, the 1998 paper by Graczyk et al. reporting the recovery of Giardia cysts and Cryptosporidium parvum oocysts from Canada goose feces in Maryland, and three reports on Campylobacter jejuni from migratory birds (Hill and Grimes, 1984; Pacha et al., 1988; Luechtefeld et al., 1980).

As pointed out above, the EA/PD cites no credible scientific evidence to show that non-migratory Canada geese pose a significant public health threat of chlamydiosis, giardiasis, cryptosporidiosis or schistosome dermatitis for humans in the Puget Sound area, or that any of the action alternatives considered in the EA/PD would significantly reduce any potential risks that might exist. Similarly, the EA/PD cites no credible evidence to show that non-migratory Canada geese pose a significant public health threat of campylobacteriosis for humans. It should be noted, for example, that:

"Poultry serve as primary reservoir hosts of thermophilic campylobacters [citation omitted]. Up to 90% of broilers may be infected [citation omitted], while 100% of turkeys [citations omitted] and 88% of domestic ducks [citation omitted] may harbor the organisms.

Various species of Campylobacter have been isolated from free-ranging pigeons in the United States [citation omitted] and Japan [citation omitted]. Infection has been recorded among game birds, including partridges, pheasants [citation omitted], and quail [citation omitted]. Campylobacters have been isolated from marine birds such as puffins [citation omitted] and gulls [citation omitted], from waders [citation omitted], and migratory Anseriformes [citation omitted]. . . It was noted that numerically higher recovery rates were obtained from scavenges and omnivores than from granivores [citation omitted]. The prevalence of C. jejuni in avian species is a function of the intensity of surveillance, since diligent collection and culturing will generally reveal intestinal infection in many orders of exotic and domestic birds within a specific area [citations omitted]. . .

Human campylobacteriosis is a food-borne condition of emerging significance [citations omitted]. . .

Early studies of the epidemiology of intestinal campylobacteriosis in human populations demonstrated that consumption of chicken meat was a significant risk factor [citations omitted]. The high carriage of campylobacters in the intestinal tract of broilers [citation omitted] and turkeys [citation omitted] contributes to contamination during processing [citation omitted]. This is reflected in high levels of C. jenuni on poultry meat [citation omitted]. Recovery of campylobacters from chicken carcasses is approximately six times higher than from pork or beef, and ranges from 30% to 100% of specimens surveyed [citation omitted." (Emphasis added.) (Shane, 1997).

Thus, it is obvious that consumption of chicken poses a far greater public health risk for campylobacteriosis in humans than the presence of non-migratory Canada geese in the Puget Sound area. Indeed, the only way that the "resident" Canada geese might pose a significant risk for transmitting C. jejuni to humans would be if they were to be used for human consumption.

The statement in the EA/PD that:

"In worst case scenarios, infections may even be life-threatening for immunocompromised and immunosuppressed people [citations omitted]." (p. 8)

disregards two important facts. First, far more significant potential sources of infection than non-migratory Canada geese are readily available to immunocompromised and immunosuppressed people in the Puget Sound area. And second, the likelihood of even immunocompromised or immunosuppressed people acquiring infections without direct contact with non-migratory Canada geese is extremely remote.

Rather than dealing with the public health issue in an objective and factual manner, the EA/PD couples misinterpretation and misrepresentation of the scientific literature with unwarranted speculation to fabricate unsubstantiated insinuations about hypothetical threats to human health from non-migratory Canada geese. The lack of rational foundation for the EA/PD’s assertion that diseased non-migratory Canada geese pose a threat to human health is revealed by the fact that, under the Capture and Euthanasia provisions of the Current Program Alternative:

"Geese suitable for human consumption are donated to qualified charitable organizations whenever feasible." (p. 16)

The section of the EA/PD alleging that non-migratory Canada geese pose a Threat to Human Health should be deleted and it should be replaced with the statement that there is no credible scientific evidence that non-migratory Canada geese pose a significant threat to human health.

Threat to other wildlife

The EA/PD states that:

"In large concentrations, resident Canada geese, feral geese, and hybrids create a reservoir for disease and pose a threat to migrating waterfowl." (p. 9)

but no citation is provided for this statement. It should be noted, however, that free-flying migratory waterfowl commonly form far larger "concentrations" than "resident" Canada geese, feral geese or hybrids, with flocks of several hundred thousand birds occurring on some migration staging and wintering areas. In addition, virtually all infectious diseases of waterfowl, including avian cholera and duck plague, the two most important contagious diseases of migratory waterfowl, already are enzootic in free-flying wild waterfowl populations (Botzler, 1991; Pearson and Cassidy, 1997; Wobeser, 1997). There simply is no credible scientific evidence that "resident" Canada geese create a reservoir of disease and pose a threat to migratory waterfowl.

The statement that:

"Tens of thousands of migratory waterfowl have been killed in single die-offs, with as many as 1,000 birds succumbing in 1 day [citation omitted]." (p. 9)

is technically accurate, but it is important to note that there are no documented reports of epizootics of that magnitude occurring as a result of transmission of diseases from "resident" Canada geese, feral geese or hybrid geese to free-flying wild waterfowl. In fact, the largest reported mortalities of migratory waterfowl have resulted from type C botulism, which is not a contagious disease (Wobeser, 1997). The first recognized epizootics of avian cholera in migratory waterfowl in California and Texas in 1943-1944 followed epizootics in domestic poultry in those areas (Rosen and Bischoff,, 1949; Gordus, 1993), and the evidence indicates that the largest epizootic of duck plague reported in wild waterfowl was initiated by carrier migratory waterfowl (Pearson and Cassidy, 1997). Consequently, the statement that tens of thousands of migratory waterfowl have been killed in single epizootics has no relevance to "resident" Canada geese.

In support of the erroneous assertion that "resident" Canada geese create a reservoir for disease and pose a health treat to migratory waterfowl, the EA/PD states:

"For this reason, the American Association of Wildlife Veterinarians (AAWV) put forth the following resolution:

". . . the AAWV encourages local authorities and state and federal agencies to cooperate to limit the population of waterfowl on urban water areas to prevent disease outbreaks in semi-domestic as well as free-ranging ducks, geese and swans and discourages the practice of relocating nuisance or excess urban ducks, geese and swans to other parks or wildlife areas as a means of local population control." (p. 9)

It is important to note, however, that the AAWV resolution cited in the EA/PD cites no evidence to support the implication that limiting the population of waterfowl on urban water areas will prevent disease epizootics in free-ranging waterfowl. In fact, the premise upon which this portion of the resolution is based states only:

"Whereas . . . semi-domestic ducks, geese and swans are susceptible to and carriers of diseases and parasites of free-ranging wild ducks, geese and swans. . ."

Therefore, because the EA/PD cites no scientific documentation to substantiate its assertion that, in large concentrations, resident Canada geese, feral geese and hybrids create a reservoir for disease and pose a health threat to migratory waterfowl, this section of the EA/PD should be deleted and replaced with the statement that there is no evidence that resident Canada geese in the Puget Sound area are a reservoir for disease or pose a health threat to migratory waterfowl.

Threat to Human Safety

The EA/PD (p. 9) states that bird strikes cause an estimated seven fatalities and $245 million damage to civilian aircraft each year, but it does not state how many of those bird strikes involve non-migratory Canada geese. The EA/PD (p. 9) also states that, in 1995, a Boeing 700 AWACS jet taking off from Elmendorf Air Force Base in Alaska ingested geese into two engines and crashed, killing 24 crew members and destroying the $180 million aircraft, but it again does not indicate whether the geese involved were non-migratory Canada geese or other migratory geese. And, of course, none of the action alternatives considered in the EA/PD would have any influence on bird strikes elsewhere in the country, including Canada goose strikes in Alaska.

The EA/PD (p, 9) also states that at least nine goose strikes have occurred to aircraft in the Puget Sound area since 1990, but it identifies only four in which aircraft damage, but no fatalities, were reported, and one of these, at McMinnville, Oregon, was not in the Puget Sound area. Furthermore, the EA/PD identifies "resident" Canada geese as having been involved in only one of the four goose strikes—an August 31, 1998, incident at the Renton Municipal Airport. No date is given for a 1995 incident at SeaTac International Airport where a Boeing 737 passenger jet struck seven geese while on final approach, so it is not possible even to speculate as to whether these might have been non-migratry or migratory geese. The third strike in the Puget Sound area occurred on October 23, 1994, at Paine Field/Snohomish County Airport when a general aviation aircraft hit a flock of geese. Although the "flock of geese" is not identified further, the date of the strike suggests that migratory geese could have been involved.

The EA/PD (p. 10) cites four reports for the statement that it is estimated that only 20% to 25% of aircraft bird strikes are reported, and from this extrapolates the unsubstantiated statement that "the number of strikes involving Canada geese was probably greater than FAA records show." However, because most bird strikes involve much smaller passerines and shorebirds that usually cause no damage to the aircraft and may not even be noticed, they are much less likely to be reported. On the other hand, a nine-pound goose hitting an aircraft is more likely to cause sufficient damage to be noticed and reported. Consequently, contrary to the conclusion of the EA/PD, FAA records likely do accurately reflect the number of aircraft strikes involving Canada geese.

Because the EA/PD identifies only one aircraft strike as involving "resident" Canada geese, and because it provides no information on the number of bird strikes in the Puget Sound area involving other species such as raptors, gulls, ducks, or flocks of small birds such as starlings and blackbirds which also can present significant hazards to aircraft, it fails to demonstrate that non-migratory Canada geese constitute an inordinate threat to human safety, or that any of the action alternatives considered would significantly reduce the occurrence of bird strikes in the Puget Sound area. However, to whatever extent non-migratory Canada geese might pose a danger to aircraft in the Puget Sound area, only site-specific actions directed at airports would be expected to be effective.

Attacks / Hazards

The statement in the EA/PD that:

"Geese in urban areas aggressively defend their nests or goslings and may attack or threaten pets, children, and adults [citation omitted]." (p. 10)

is true. However, the statement that:

"WS records show that goose attacks on people are fairly common occurrences during the nesting season and can result in injuries." (p. 10)

is supported only by eleven anecdotal reports of unconfirmed reliability gleaned from replies to 377 "public involvement" letters (sent to state, federal, county, and municipal agencies, businesses, animal welfare and animal rights organizations, and individuals) (EA/PD p. 4), and by one newspaper account, also of unconfirmed reliability.

Details are provided on only one "attack" (reported in the May 13, 1998, Oregonian) where a 57-year old woman allegedly was "knocked to the ground and attacked by two Canada geese," resulting in "a swollen and bruised face, two black eyes, a 3-inch scratch down her cheek and a concussion." However, it is not plausible that two nine-pound Canada geese could knock a healthy adult human to the ground, so it appears more probable that the woman over-reacted and fell in a hasty attempt to avoid the geese. It also appears probable that the concussion and at least some of the other injuries she sustained resulted from the fall, rather than having been inflicted by the geese. Because Canada geese generally defend an area up to 50 feet or more in diameter around their nests, in all likelihood, the "attack" and resulting injuries could have been avoided if the woman would simply have retreated when the geese first appeared. In any event, the EA/PD cites only one alleged incident of injury resulting from an "attack" by Canada geese in the Puget Sound area. The rest of the direct human "hazards" attributed to non-migratory Canada geese (slipping hazards caused by the accumulation of feces on surfaces, and the elderly being more prone to fractures and complications from injuries) are hypothetical and undocumented and of undetermined significance. The EA/PD (p. 10) states that WS records show traffic hazards from geese straying onto busy streets and highways, but it provides no information on the significance of the problem in the Puget Sound area.

In the final analysis, the EA/PD cites only one specific report of human injury in its entire discussion of Attacks / Hazards associated with non-migratory Canada geese in the Puget Sound area, and that report is of questionable validity. The rest of the discussion consists of speculation about hypothetical problems. Consequently, the EA/PD fails to provide substantive evidence that non-migratory Canada geese are responsible for significant attacks or hazards in the Puget Sound area.

Damage to Property / Natural Resources / Quality of Life

The EA/PD states that:

"Soil erosion and other damage caused by geese to landscaping (Laycock 1982, Conover and Chasko 1985), gardens, golf courses, public parks, and cemeteries, are well documented throughout the Puget Sound area (USDA, MIS 1993-1998)." (p. 10)

However, the article by Laycock was written in 1982 and the paper by Conover and Chasko was published in 1985, but, according to the EA/PD (p. 6), there were only 3,110 geese in the Puget Sound area by 1988. In addition, the paper by Conover and Chasko deals with nuisance Canada goose problems in the eastern United States. Therefore, neither of these publications cited by the EA/PD provides relevant documentation of damages caused by geese in the Puget Sound area. Furthermore, the Annual Tables in the MIS that are cited in the EA/PD simply contain listings of complaints received by Wildlife Services without verification of their validity (EA/PD p. 7). And, the paper by Allan et al. (1995) does not address specifically the situation in the Puget Sound area, so the relevance of their estimate of a costs of $60 per goose for reestablishing over-grazed lawns and cleaning goose feces from sidewalks to the Puget Sound area is questionable. Therefore, the EA/PD provides no substantive evidence to support the allegation that geese are causing soil erosion and other damage in the Puget Sound area, nor does the EA/PD make a substantive attempt to qualify or quantify the alleged damage.

 

The statement in the EA/PD that:

"In 1998, resident Canada geese at a military installation in the Puget Sound area activated security systems in a nuclear arms storage area so frequently as to compromise the security of the facility (WS records)." (p. 10)

is a far more telling reflection on the value and sophistication of a security system at a nuclear arms storage area that can readily be "compromised" by geese than on damage caused by geese.

The EA/PD states that:

"Ecological damage to area lakes from resident geese has been documented since the early 1980s." (p. 10)

but it does not cite the documentation. However, this statement appears to be inconsistent with Figure 2, which shows the population of Canada geese in the Olympia-Seattle-Tacoma area to have been less than 1,000 birds in the early 1980s (EA/PD p. 2).

The only specific example of ecological damage to an area lake identified in the EA/PD is an uncited "Washington State study of Lake Ballinger [where] fecal matter from geese was found to be the major source of phosphorus in the lake" (EA/PD p. 10). However, the EA/PD provides no information on the size or location of Lake Ballinger, the number of geese using the lake, the duration of their use of the lake, or even whether the geese involved were non-migratory Canada geese, migratory geese or domestic geese, or some combination. Therefore, it is not possible for the reader to determine the significance or relevance of the subsequent statements regarding the impacts on water quality and aquatic habitat.

Similarly, the EA/PD states that:

"Phosphorus loading from fecal material is a serious ecological concern that has become a common problem in the Puget Sound area (WDOE 1999)." (p. 10)

However, the WDOE citation is not listed in the References and the EA/PD provides no information on the relative contribution of non-migratory Canada geese to total phosphorous loading from fecal material compared with other sources in the Puget Sound area, such as human sewage, domestic animal wastes, and other wildlife. Consequently, the EA/PD fails to show that any of the action alternatives considered would significantly reduce phosphorus loading of waters in the Puget Sound area.

The EA/PD states that:

"The majority of respondents to the public involvement process of this EA described a general decline in their quality of life due to local overabundances of geese." (p. 10)

According to the EA/PD:

"Public input was obtained through written comments provided in response to a public involvement letter." (p. 4)

but it does not indicate how many of the 377 "public involvement" letters actually were sent to members of the public (EA/PD p. 4), nor does it indicate how many responses were received from members of the public. Furthermore, the EA/PD provides no information on the validity or seriousness of any of the problems that were reported. For example, the EA/PD states that:

"Piers, yards, boats, beaches, roads, parks, gold courses, landscaping, driveways, athletic fields, ponds, lakes, rafts, porches, patios, gardens, foot paths, wading pools, play grounds, irrigation ponds, school grounds, cemeteries, and reservoirs all have been negatively affected (public involvement 1998 – 1999)." (p. 11)

but it provides no indication of the nature, seriousness or extent of these obviously subjective negative effects.

The absence of factual, objective information on damages caused by non-migratory Canada geese to property, natural resources and quality of life in the Puget Sound area not only precludes an informed evaluation of the alternatives considered in the EA/PD, but it also precludes an informed decision regarding the justification for Wildlife Services’ involvement and the expenditure of public revenues in attempting to address those damages.

2.0 ALTERNATIVES

Because the EA/PD provides no clear evidence that non-migratory Canada geese are causing significant problems in the Puget Sound area, the only alternative that is supported by the information contained in the EA/PD is the No Action Alternative. Nevertheless, the following comments are provided on selected points of the alternatives considered in the EA/PD.

2.1. Alternative 1: Current Program Alternative

The EA/PD states that:

"Under the Current Program, IWDM [Integrated Wildlife Damage Management] has been modified to focus on nonlethal control and technical assistance. Lethal control has been restricted to specific, limited circumstances related to human health and safety concerns. Primarily due to social concerns, nonlethal control and technical assistance have been used under circumstances where lethal control would have been more effective and biologically sound." (p. 14)

However, the EA/PD cites no credible scientific evidence that non-migratory Canada geese pose a significant risk to human health, and indeed none exists. Therefore, no justification exists for employing lethal control of non-migratory Canada geese under the guise of protecting human health.

Similarly, because the EA/PD provides no substantive, factual evidence that non-migratory Canada geese pose significant public safety problems in the Puget Sound area, or that lethal control would eliminate or substantially reduce problems that might exist, lethal control would be justified only on a case-by-case basis where it can be demonstrated to be necessary and effective.

 

Technical Assistance

Because non-migratory Canada geese do not pose significant risks to human health, Wildlife Services should immediately cease making recommendations to the U. S. Fish and Wildlife Service that permits be issued to resource owners for lethal control on the basis of unfounded threats to public health (EA/PD p. 15)

Capture and Euthanasia

According to the EA/PD:

"A capture drug, alpha chloralose (AC), is normally the method used to capture geese outside the molt period. AC is regulated by the Food and Drug Administration (FDA). WS is authorized to use AC under the Investigational New Animal Drug Registration (INAD 6602), and WS personnel are trained and certified in its use. . ." (p. 16)

It should be noted, however, alpha chloralose has been available for more than 100 years (Shideman, 1958), its use as an anesthetic agent in animals was reported over 60 years ago (Kochmann, 1936), and its use as an immobilizing agent in Canada geese was reported over 30 years ago (Crider and McDaniel, 1967). Therefore, to imply that alpha chloralose is a new animal drug would be a serious misrepresentation of the facts.

It should also be noted that, because of the drug’s narrow therapeutic index and margin of safety (with mortality rates from 2.5% to 37.5%), the difficulty in delivering an appropriate oral doses to birds of varying size consuming varying amounts of treated bait over varying periods of time, the long and variable induction period, the danger of birds being flushed from the bait site before they are immobilized and becoming subject to drowning, predation or other trauma, the danger to non-target animals, and the prolonged recovery period (Crider and McDaniel, 1967; Crider et al., 1968; Belant and Seamans, 1997), alpha chloralose has serious fundamental pharmacologic limitations that preclude it from being considered a satisfactory immobilizing agent for Canada geese.

The EA/PD states that:

"WS lethally removed a total of 159 resident geese in FY 1997 and 419 in FY 1998 (WS, MIS)" (p. 16)

but it does not indicate how many additional "resident" geese were removed as a result of Wildlife Services recommendations to the U. S. Fish and Wildlife Service to issue permits to local resource owners for lethal control (EA/PD p. 15). Without information on the total number of "resident" Canada geese currently being removed from the area, it is not possible to evaluate objectively alternatives involving increased lethal control.

2.2 Alternative 2: Nonlethal andTechnical Assistance Only Alternative

The EA/PD states:

"Alternative 2 would discontinue any lethal control of geese by WS, except in emergency situations involving human health and safety. If lethal control were used in other situations, it would be employed by persons or programs other than WS. . .

. . . Permits could be requested to allow the property owners or resource managers to implement lethal methods themselves or contract others to do so. Permits would be issued by and at the discretion of USFWS." (p. 16)

 

However, because there is no credible scientific evidence that non-migratory Canada geese pose a significant threat of human health, and because the EA/PD cites no substantive evidence that they pose significant risks to human safety in the Puget Sound area, no justification has been shown for lethal control of non-migratory Canada geese by Wildlife Services or by other persons or programs, and no justification has been shown for the U. S. Fish and Wildlife Service to issue permits to property owners or resource managers to implement lethal methods or to contract with

others to implement lethal methods.

2.3 Alternative 3: Nonlethal Methods First Alternative

Under this alternative:

". . . WS personnel would be required to use nonlethal methods prior to recommending using lethal methods to control goose damage. Unlike the Current Program, lethal control would not be limited to situations of human health and safety. . .

. . . the important distinction between the Nonlethal Methods First Alternative and the Current Program Alternative is that the former alternative would require that all nonlethal methods be recommended or used before any lethal methods are recommended or used." (p. 17)

However, because there is no evidence that non-migratory Canada geese pose a threat to human health and because the EA/PD has provided no substantive evidence that they pose a threat to public safety or cause significant damage in the Puget Sound area, the EA/PD fails to establish justification for the employment of lethal control methods under any circumstances.

2.4 Alternative 4: Expanded Program Alternative (Proposed Action)

According to the EA/PD, the Expanded Program Alternative:

". . . is identical to the Current Program Alternative, except that it would not limit the option for lethal control to situations of human health and safety." (p. 17)

Again, however, because there is no evidence that non-migratory Canada geese pose a thereat to human health and because the EA/PD has provided no substantive evidence that they pose a threat to public safety or cause significant damage in the Puget Sound area, the EA/PD fails to establish justification of the expansion of lethal control methods under this alternative, as well.

2.5 Alternative 5: No Action Alternative

The EA/PD acknowledges that:

"The "No Action" Alternative. . . is a viable and reasonable alternative that could be selected." (p. 17)

In view of the facts that 1) there is no evidence that non-migratory Canada geese pose a threat to human health, 2) the EA/PD provides no substantive evidence that they pose a threat to public safety or cause significant damage in the Puget Sound area, or 3) that any of the action alternatives proposed would significantly reduce any of the problems attributed to non-migratory Canada geese in that area, the No Action Alternative is the only viable and reasonable alternative that could be selected.

Alternative Not Considered in the EA/PD

Because the problems most commonly attributed to non-migratory Canada geese are associated with goose fecal deposits in areas that also are utilized by humans, most of the problems are esthetic in nature and typically constitute little more than a nuisance. In many cases, these perceived nuisance problems occur on private property. However, because the justification for expending public revenues to deal with nuisance situations on private property frequently is questionable, another alternative that should be considered would be for Wildlife Services to offer to contract with private entities to provide technical assistance in those situations. This would relieve the public of the financial burden of implementing control measures on private lands and it would shift the costs to the beneficiaries, thus better assuring that the public is not required to subsidize unwarranted and economically unjustified control programs. In addition, it would maintain Federal supervision of control programs involving migratory waterfowl species.

3.0 ENVIRONMENTAL CONSEQUENCES

3.0.0 Method of Analysis

According to the EA/PD, one of the issues included in the analysis of environmental consequences of the alternatives considered is:

"Effectiveness of control measures in reducing or minimizing damage." (p. 18)

However, because there is no evidence that non-migratory Canada geese pose a threat to human health and because the EA/PD provides no substantive evidence that they pose significant threats to human safety, any discussion of the effectiveness of control measures in reducing or minimizing human health or safety threats is irrelevant. Similarly, because the EA/PD provides no substantive evidence that non-migratory Canada geese in the Puget Sound area cause significant damage beyond occasional nuisance problems, any discussion of the effectiveness of control measures in reducing or minimizing damage is at most speculative.

3.1 Impact of the Current Program Alternative

3.1.1 Humaneness of control methods

The EA/PD states that:

"Humaneness is a person’s perception of harm or pain inflicted on an animal, and people may perceive the humaneness of an action differently." (p. 18)

Although different people may have different perceptions of humaneness, just as they may have different perceptions of morality, this is not justification for the EA/PD’s superficial consideration of the issue. In fact, however, consensus does exist within society regarding the fundamental elements of humane treatment of animals. For example, in its 1993 report, the American Veterinary Medical Association Panel on Euthanasia states:

"The term euthanasia is derived from the greek [sic] term eu meaning "good" and thanatos meaning "death." [citation omitted] A "good death" would be one that occurs without pain or distress. In the context of this report, euthanasia is the act of inducing humane death in an animal. Euthanasia techniques should result in rapid unconsciousness followed by cardiac or respiratory arrest and ultimate loss of brain function. In addition, the technique should minimize any stress or anxiety experienced by the animal prior to unconsciousness. Stress may be minimized by technical proficiency and humane handling of the animals to be euthanized." (Emphasis added.) (Andrews et al., 1993)

Although the AVMA Panel’s report focuses on euthanasia, it is clear that humane treatment of animals includes other actions such and handling as well. From the report, it is clear that the accepted standard for treatment of animals includes minimizing not only pain, but also distress, stress and anxiety. While there may be debate regarding the degree to which these must be minimized in order for the treatment to be humane, it is clear that humane treatment of animals places severe restrictions on the amounts of pain, distress, stress and anxiety that are acceptable in control measures for non-migratory Canada geese. Because Canada geese are evolutionarily adapted and behaviorially accustomed to avoiding dangers, the pain, distress, stress and anxiety associated with control measures that do not involve capture, handling and euthanasia are substantially lower than those measures that require capture, handling and euthanasia. Although properly conducted shooting has the potential to be more humane than capture and relocation, non-lethal control measures generally can be expected to be substantially more humane than lethal control measures. And while alpha chloralose immobilization may be a humane technique under ideal conditions, a high potential for inhumane results exists.

It should be noted that in the discussion of Lethal Control by WS, the EA/PD states:

"For purposes of lethal control, resident geese are usually captured by drive trapping, in which a group of flightless geese is herded into a net [citation omitted]. Drive trapping is used to catch adult geese during their molt period in early summer, as well as juveniles before they have gained the ability to fly." (p. 26)

Because flightless geese are deprived of their primary means of avoiding danger, and because drive-trapping subjects them to the prolonged stress of being herded from their normal surroundings into traps, to the distress of capture and handling, and to the anxiety of family groups being disrupted, this technique carries a high potential for inhumane treatment of free-ranging geese.

It also is important to note that, while the EA/PD states that:

"Captured geese are euthanized following methods recommended by the AVMA." (p. 26)

The Ornithological Council’s 1997 Guidelines to the Use of Wild Birds in Research point out that:

"Many techniques for euthanasia have been reviewed by the American Veterinary Medical Association (Andrews et al. 1993). Relatively few are appropriate for birds, and none consider the needs of field studies." (Gaunt et al., 1997)

Consequently, just because geese are euthanized following methods recommended by the AVMA provides no assurance that it is done humanely.

It is evident, therefore, that lethal control measures involving capture and euthanasia of non-migratory Canada geese carry high potentials for failing to meet accepted standards for humane treatment of animals.

3.1.2 Possible impact on non-target, Threatened, and Endangered Species

The EA/PD states that , under the Current Program Alternative, it has been determined that there is no effect on Threatened or Endangered species and it points out that:

"Most captures take place during the molt which generally occurs in June and July. These seasonal captures harvest only resident geese due to the absence of migratory populations at this time of the year. All capture and removal methods allow for positive identification of target species." (p. 19)

From this, it concludes that:

"Under the Current Program, there has been no impact observed on non-target, Threatened, and Endangered species." (p. 19)

and under 3.4 Impacts of Expanded Program Alternative (Proposed Program), 3.4.2 Possible impact on non-target, Threatened, and Endangered Species, that:

"Impacts on non-target, Threatened, and Endangered Species would be similar to the Current Program Alternative (3.1.2)." (p. 31)

However, simply because no impact has been observed under the Current Program does not relieve the EA/PD of its obligation to discuss fully and objectively the potential impacts on non-target, threatened and endangered species of the alternatives considered, especially those which involve lethal control and expanded lethal control. For example, with the use of alpha chloralose, the potential exists for non-target species such as other waterfowl and seed-eating birds to consume the treated bait and to be affected and suffer direct mortality as a result (Crider and McDaniel, 1967). In addition, because birds that are under the influence of alpha chloralose are more vulnerable to predation and may attract predators by their abnormal behavior, secondary toxicosis can occur in species such as raptors and in mammalian predators, including domestic dogs and

cats.

3.1.5 Effectiveness of control measures in reducing or minimizing damage

The EA/PD states that:

"Domestic and feral geese and ducks and domestic/wild hybrids may also carry disease which threaten wild populations (AAWV undated.)" (p. 21)

However, as discussed under Threats to other wildlife on pages 11-12 above, there is no scientific evidence that feral and domestic/wild hybrid waterfowl pose a significant disease threat to wild waterfowl populations, so there is no foundation for the implication that removing domestic waterfowl from ponds would reduce the occurrence of diseases in wild waterfowl.

4.0 CONCLUSION

The EA/PD concludes that:

"The proposed program [Expanded Program Alternative] offers greater flexibility in implementing lethal control, and for this reason, would be more effective in reducing economic losses and human health and safety concerns than any other alternative." (p. 36)

However, because no credible scientific evidence exists to demonstrate that non-migratory Canada geese pose a significant threat to human health, the claim that the Expanded Program Alternative would be more effective in reducing this non-existent problem is not valid. Similarly, because the EA/PD provides no substantive evidence that non-migratory Canada geese pose significant human safety risks in the Puget Sound area, the claim that the Expanded Program Alternative would be more effective in reducing these problems is merely speculative. Finally, because the EA/PD provides no factual data verifying the occurrence and validating the magnitude of economic losses attributed to non-migratory Canada geese in the Puget Sound area, the claim that the Expanded Program Alternative would be more effective in reducing those losses is unsubstantiated. Therefore, the relative merits of the alternatives considered must be evaluated under other criteria.

NATIONAL ENVIRONMENTAL POLICY ACT REQUIREMENTS

Because the ENVIRONMENAL ASSESSMENT/Predecisional Document does not evaluate the alleged conflicts associated with non-migratory Canada geese in the Puget Sound area in a substantive and factual manner, and because it fails adequately to address other issues associated with the management of non-migratory Canada guess outlined in the enclosed copy of COMENTS ON THE UNITED STATES DEPARTMENT OF THE INTERIOR FISH AND WILDLIFE SERVICE AUGUST 1996 DRAFT ENVIRONMENTAL ASSESSMENT: PERMITS FOR CONTROL OF INJURIOUS CANADA GEESE, it fails to provide compliance with the requirements of Section 102 (2) (C )of the National Environmental Policy Act.

I trust that these comments will assist Wildlife Services in achieving compliance with the National Environmental Policy Act and in selecting an appropriate alternative based on sound scientific information for addressing the perceived conflicts associated with non-migratory Canada geese in the Puget Sound area.

Sincerely,

 

Gary L. Pearson, D.V.M.

 

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