Please include my comments in the preparation of your study "Environmental Assessment: Management of Conflicts Associated With Non-migratory (Resident) Canada Geese in Wisconsin Environmental Assessment: Management of Conflicts Associated With Non-migratory (Resident) Canada Geese in Wisconsin".

USDA APHIS WS (ANIMAL DAMAGE CONTROL) ABILITY TO CONDUCT THIS ENVIRONMENTAL ASSESSMENT

Rather than facilitating public involvement required by the National Environmental Policy Act, USDA Wildlife Services (Animal Damage Control) (hereinafter referred to as WS-ADC) has done everything to undermine citizen involvement. What is the rush in getting this Environmental Assessment completed? We understand from our sources that permission has already been granted to proceed to kill Canada geese this season. It appears that the purpose of the EA to leave the  impression of factual basis and public involvement when they were lacking.

John Maestrelli, State WS Director has not adequately notified the public of the Environmental Assessment. The instructions were to submit comments by US mail. Efforts by citizens to get adequate time for preparation and comment by getting a 30-day extension and e mail and fax submission of comments were refused by the State and Eastern WS directors. Some copies of the EA document were lacking Appendices C & D which made getting basic information and cross checking the authors' statements impossible. Even when verification of the lack of appendices were documented to the State Director on May 23, requests for extension and fax/e mail submissions were refused.

A form letter sent by WS-ADC to those requesting a copy of the EA was the following:

TO: All Interested Parties

DATE: May 31, 2000

SUBJECT: Comments on the Canada Goose Environmental Assessment(EA)

On May 23, 2000, you were sent a memorandum from this office which indicated that you may not have received a copy of appendix C and D of the Canada goose EA that was previously mailed to you. Also included with the memorandum was a copy of appendix C and D.

This memo is to inform you that in light of the possibility you did not receive appendix C and D when you received a copy of the Canada Goose EA, we will consider your comments on the EA that are mailed to this office up until the final decision is made regarding the EA. Please be advised that this should not be construed as being an extension of the comment period which will end on June 2, 2000.

Sincerely,

John R. Maestrelli
State Director
USDA-Wildlife Services

What is the urgency in getting this EA completed? Is the final decision going to be prior to the relocations and contaminant-test killings? This is not a thoughtful, deliberative and scientific process where citizen comments are respected.

Repeated requests for extension and e mail/fax comment submission resulted in a letter of refusal from Eastern Region Director Gary Larson. Quoting from the letter of refusal: "Our agency's contracted e mail system is so primitive and unreliable that we cannot be sure that messages are sent or received. The fax machine...shares a circuit with our on-line administrative system so it rings busy most of the day " (5/25/00)

Does this mean that the fax in the State office and e mail share a common line? But the e mail doesn't work! When the State WS-ADC office doesn't have a working fax line and doesn't have a working e-mail, is your business being conducted by phone and snail mail?

To test the ability of your fax machine, I have sent several faxes. All have been received. For example, on 5/30/00 I sent you a fax at 9:28:12 AM Central Daylight Time. According to my records, you received it successfully at 05/30/00 09:31:42 002 The transmission took 2:29 minutes duration. None of my faxes has been delayed.

But in another letter from Maestrelli permitting a fax submission by this commenter "...our fax machine, while relatively new, does not provide us with easy to read copies. " (6/2/00)

If the fax were unreliable, and assuming a citizen-friendly attitude, the faxes could be sent to Eastern Region Director Gary Larson's office and forwarded by snail mail to Mr. Maestrelli. The refusal to accept faxes and e mail comments demonstrates a lack of problem solving ability and a care-less attitude about citizen concern.

I would like to believe that Maestrelli and Beckerman are just suffering bureaucrats with a citizen unfriendly atmostphere. However various sources tell us that the e mail is working, the fax is working and that citizens are routinely treated with disrespect.

The present Canada goose kill relocation practice in Wisconsin is for the federal (WS-ADC) and state (WI Department of Natural Resources) to distance themselves from the killing and relocating of Canada geese. However, the legislature provided grants for municipalities and other entities to kill and relocate Canada geese, but the process allows for no scrutiny by the public prior to the action. Applications and permits are transmitted by fax, allowing for denials to be issued and citizens are unaware until the killing and relocation are all a matter of fact. Responsibility is shuffled between WI DNR and WS-ADC in order to have "reasonable deniability".

REFERENCES NOT ALL AVAILABLE

In spite of my request several days in advance of my review of the references to be able to speak to the authors about the EA, author Maestrelli had a sudden urgent need to be out of the office on the day of my review. My repeated requests to speak to the authors were met with refusal. Mr. Maestrelli said he couldn't meet with me until June 2 -- after the deadline for the EA.

I reviewed the references in the State WS-ADC office on May 23, 2000. The references were sorted curiously in two separate alphabetical piles. Eighteen of the references were not provided, in violation of law. Some were listed in the references as abstracts. Some purporting to be studies were abstracts (Cooper). Mr. Maestrelli told me in a fax on May 30 "Regarding the literature citations of author J.S. Cooper, which you had questions about, I would recommend you contact Mr. Cooper directly as we did during the writing of the EA to obtain the information you need. " He again refused my in-person request on June 1.

Many of the references are game agency trade publications and conference proceedings. EA statements were falsified as to the substance of the discussion in the reference. Ankney's paper, for example, deals with snow geese, not Canada geese. Shortly after their discussion about the Canada geese being "residents" and "non migratory", the authors cite Zicus, 1981, (page 7, para. 2) as saying "It is known that non-breeding resident Canada geese and geese which have failed nesting attempt conduct a migration to northern areas in the summer prior to molting. " Why did the authors not reveal that the northern areas are northern Manitoba!! It is hard to imagine that this is less than deceit because the authors need only have read the abstract! It was one of the few references related to Wisconsin, although two decades old.

The references cited were inappropriate. For example, rather than citing scholarly works such as Bellrose on the matter of sexual maturity of Canada geese, the authors cite Cooper, 1978, a paper in a game agency trade journal on geese at Marshy Point, Manitoba! The authors do not show the relevance to the "resident" (US) population.

The National Environmental Policy Act requires agencies to promote and facilitate public involvement in evaluating situations that affect the environment. The USDA WS-ADC appears to be avoiding public comment and scrutiny on this EA. It has refused reasonable requests for a 30 day extension, submission of comments by fax and email, has not provided all the references as required by law, and falsified information.

I saw a similar deceipt in the City of Fond du Lac. The public hearings were held AFTER the decision to file for a permit and grant to relocate juvenile Canada geese and kill their parents. City Council members were bewildered as to why the Parks Board had no authority and why the City Council didn't have to make a decision after the hearings. EA author Scott Beckerman, having postured himself as being there to do what the community wanted, was listed on record as "in support of" the motion to kill and relocate. So was Ricky Lien of the WDNR. Why should game agency staff be masquerading as citizens of Fond du Lac?(x)

What is the need for deceit and evasion in this matter? If the killings and relocations are "perfectly legal", then why the need to rush? Why the need to mislead and cite scientific literature for statements that were never made?

There is one more charge which should be made public: attempt to intimidate. On May 23, when I was in the USDA WS-ADC office reviewing the references, Mr. Maestrelli asked if he could take my picture. When I asked if I could take his picture, he responded "Oh, you don't want me to take your picture? ". I said no, I did not want him to take my picture. He did not. On June 1, when I came to try again to locate the missing references, and asked for a few photocopies since my scanner would not scan some of the charts in articles they cited. He indicated that USDA was not supposed to provide free copies, but when he handed them to me he made the free photocopy contingent on my signing a statement:

"I was provided with a desk and electrical outlet at the Wisconsin Wildlife Services office on May 23 and June 1, 2000, where I used my personal computer and scanner to copy documents associated with an environmental assessment being prepared by Wildlife Services. Wildlife Services also provided me with 26 copied pages at no charge. "

I asked why the signature. He said that he needed to keep a record. I signed the statement.

I have grave reservations about entrusting the care and "management" of wildlife to a state office that can't "clearly communicate" with the public, can't get its management systems working, lies to citizens, intimidates them and violates federal law.

This should be adequate to abandon the "Environmental Assessment: Management of Conflicts Associated With Non-migratory (Resident) Canada Geese in Wisconsin Environmental Assessment: Management of Conflicts Associated With Non-migratory (Resident) Canada Geese in Wisconsin".

PURPOSE AND NEED FOR ACTION

1.0 Chapter 1: Purpose and Need for Action

1.1. Introduction

WS  has decided to prepare this EA to assist in planning giant Canada goose ...damage management activities (page 5, para. 6).

This Environmental Assessment claims to be elective ("has decided") on the part of USDA Wildlife Services Animal Damage Control (WS-ADC). Considering that there has been six years of controversy over the slaughter of conveniently named "nuisance" Canada geese, this should not have been considered a public relations matter for the agency to justify its slaughter. Since there is a national Environmental Impact Statement underway at the moment at US Fish and Wildlife Service (USFWS), this should have been mandatory.

In an oblique reference to the National Environmental Policy Act (bottom of page 5 and 1.5), this EA claims to be "tiered" to a national Environmental Impact Statement. Maestrelli, Beckerman and Peterson refer to the USDA Animal Damage Control 1994 EIS. But the EA for Wisconsin should be tiered to the Federal US Fish and Wildlife Service currently underway, and it will require an EIS for Wisconsin and site-specific studies. Even if Maestrelli, Beckerman and Peterson could argue successfully that the 1994 EIS applies, the need for site-specific data and analysis is not obviated. This is a major error and fatal flaw in this report. Clearly, WS-ADC cannot pursue any action under this EA until the "gag order" on WS-ADC, John Doe 1 (Farm Bureau) Glickman is resolved because site-specific studies are required under Title 40 Section 1508.28.

Sec. 1508.28 Tiering.

Tiering refers to the coverage of general matters in broader environmental impact statements (such as national program or policy statements) with subsequent narrower statements or environmental analyses (such as regional or basinwide program statements or ultimately site-specific statements) incorporating by reference the general discussions and concentrating solely on the issues specific to the statement subsequently prepared. Tiering is appropriate when the sequence of statements or analyses is: (a) From a program, plan, or policy environmental impact statement to a program, plan, or policy statement or analysis of lesser scope or to a site-specific statement or analysis.

Authors Maestrelli, Beckerman and Peterson do not say what issues are of concern, so the readers can never know if WS addresses "the issues". In fact, rather than "clearly" communicating, this appears to be blatant and intended miscommunication, falsification and deception of citizens. This includes obfuscation of population count, "population goals", detailed explanation of possible health and safety issues while stating that "the risk of infection is believed low", phony "stakeholder" involvement (the Urban Waterfowl Task Force) was stacked with "WS-ADC cooperators", hunters and DNR staff), violation of Environmental Justice and Executive Order 12898 with no data or analysis being provided that would support the safety of the Canada goose carcasses, nonsensical and self-serving mis-statements about humaneness of the trap and slaughter operation, meaningless statements about impact on other subspecies of geese.

The EA "documents the analysis (emphasis mine) of the potential environmental effects of the proposed program. " (page 5, last para.). What does this mean? In this EA, there is no documentation of Canada goose problems in Wisconsin. In this EA, there is no analysis of any Canada goose problems in Wisconsin. Further, there is no indication whatsoever of any evidence that their management plan will work.

Maestrelli, Beckerman and Peterson never provide any data to show damage. They do not contribute to management activities. It is clear that this is a failed public relations gimmick.

1.2 (page 6, para. 3) The purpose of this EA is to analyze the effects of WS activities in Wisconsin to manage damage caused by resident Canada geese.

This would appear to be a program evaluation of WS-ADC, rather than an Environmental Assessment. To address the question of competence at managing Canada geese, WS-ADC rates an F. I reviewed the WS-ADC Wisconsin files regarding management of Canada geese from 1997-1999 (under Freedom of Information Act). There was only one instance where there was there ever a site visit or verification of the alleged cost of damages. According to Figure 4 (Appendices C & D were not provided in some copies of this EA), the "problem" as judged by complaints concerns SE Wisconsin and that the problem is not distributed throughout the state. Yet the EA states that it intends for this to be the guide for

...current and future resident Canada goose damage management (RCGDM) actions wherever they might be requested within the State of Wisconsin." (page 5, para. 6). Since the EA does not even "clearly communicate" its purpose, it is difficult to see how the reviewers can evaluate the options for management.

1.3.2 Past, Present, and Future Information About Resident Canada Geese in Wisconsin

These locally breeding, "resident" Canada geese are defined as those non-migratory Canada geese that nest and reside predominantly within the conterminous United States. (page 6, para. 5)

(According to Webster, conterminous US means all the states but Alaska and Hawai'i.)

Federal and state agencies have obfuscated the nature of the locally breeding Canada geese for their own purposes. "Locally breeding" is correct, but "resident" is a fiction. Resident, according to Webster, is a bird or animal that is not migratory. The issues of resident and migratory has been dispelled by a study by the South Dakota Fish and Game Department (1998). They found in banding studies that the 'resident' geese they propagated were found in:

South Dakota 3,217
Kansas 721
Nebraska 460
Texas 328
Missouri 260
Minnesota 219
Oklahoma 166
Saskatchewan, Canada 87
Iowa 67
North Dakota 51
Manitoba, Canada 43
Colorado 35

To be as far south as Texas presumes they could go to Mexico. But the data is clear that the South Dakota 'residents' were found in Canada. This should dispel both the notion that the geese are "resident" and "non migratory". They do migrate from state to state and across international borders.

Further evidence from the Wisconsin EA references is that the non-breeding Canada geese travel to Canada as "molt migrants."

The sightings or recoveries of neck-banded geese were from birds known to have been at Crex Meadows until May or June of the same year, whereas the leg-band records were from geese recovered dead more than 1 year after banding. Twenty of the 34 records were in a corridor between Crex Meadows and the Interlake region of Manitoba. Six of the 25 fall records came from the vicinity of Agassiz NWR and 7 others were from southeastern Manitoba. Outside the corridor, hunter-recovered geese were reported from North Dakota, Minnesota, and northeast of Crex Meadows in Wisconsin. Five additional geese, banded in 2 different years and on 2 different brood-rearing marshes, were re-trapped together as 4 yearlings and a 2 year old near Hudson Bay. (p. 58). The proportion of yearlings assumed to be alive that returned differed...among years, and ranged from 48-85%. In contrast, fall return of older non-nesters ranged from 75-93%, whereas return of unsuccessful pairs ranged from 93-100%. (p. 60).

Migratory flocks of Canada geese pass over the Potomac region during the fall and may attract resident West Virginia geese which then join these flocks and move out of state. (p. 114).

The fact is, "resident" Canada geese commonly travel long distances from their nesting areas, especially in their molt migrations. For example, Nelson and Oetting (1991) reported that Canada geese from Wisconsin have been found in Kansas; Canada geese from Michigan have been found in Indiana, Ohio Illinois, Kentucky, Tennessee, Wisconsin, Alabama, the Carolinas and on Akamiska Island in James Bay; Canada geese from Iowa have been found in Minnesota and Missouri; Canada geese from Missouri have been found in South Dakota, Wisconsin and Ontario; Canada geese from Illinois have been found in Wisconsin, Michigan, Ontario, Minnesota, North Dakota, Manitoba, Kentucky and Tennessee; and Canada geese from Ohio have been found in Michigan, Ontario, Akamiska Island and on the Thelon River in the Northwest Territories.

The federal and state governments' case rests with the illusion that the geese on a given pond or park, if killed or relocated, will reduce the population of geese in that area. The federal and state governments' case rests with the illusion that the geese on a given pond or park, if killed or relocated, will reduce the population of geese on that park or pond.

1.3.2 (page 8, para. 2) In addition to increasing harvest through implementation of an early hunting season, the WDNR has relocated young of the year geese from the Green Bay area and SE Wisconsin to under-utilized habitats primarily in northern Wisconsin (Table 1) and provided adult birds to other states (Table 2). WS also trans-located young of the year geese from Horicon (179) and Fond du Lac (87) in 1999. However, the trans-location effort within the state for restoration purposes is not expected to continue beyond the next few years, and in recent years other states have not been interested in receiving adult birds.

This constitutes WS-ADC's efforts to respond to our request in the scoping comments to provide data on the restoration efforts. It is gratifying that the authors confess that the restoration efforts are continuing. However, it was these same restoration efforts that caused the current situation in Kansas and Missouri (note 3,500 geese have been sent during the 1983-93 decade. EA Table 2 Appendix D) Where was the Environmental Impact Statement for that program? If there had been a scientifically sound EIS, it would have predicted this very situation. The restoration efforts continue. It would appear that the WDNR and the USDA WS-ADC has little regard for the public or for Canada geese. Is this a continuing fund raiser for theWDNR (not to mention additional sources of state taxpayer revenues for grants) and for USDA WS-ADC as the hired hands.

It should have been mentioned in the EA that the WDNR provides 140 ton of grain for the Canada geese at Bay Beach sanctuary. Juveniles are routinely relocated from Green Bay Sanctuary. Is this the DNR's nursery for their restoration programs to create more geese for hunting? Admonitions from the WDNR and the USDA WS-ADC to halt all feeding at parks and ponds ring hallow. At the same time, even at Bay Beach Wildlife Sanctuary, there is discussion about "too many geese" and possible goose killings.

1.3.3 Wildlife Acceptance Capacity is the limit of human tolerance for wildlife or the maximum number of a given species that can coexist compatibly with local human populations...known as cultural carrying capacity.

No scientific credibility is given for this eugenics-sounding assertion. Does this include the Arctic population, considerably larger that concentrates in our area in the fall and spring?

The wildlife acceptance capacity for resident Canada geese in Wisconsin appears to be approximately 5-20 birds for an 18-hole golf course or similar sized park.

The authors provide no reference for this. It appear that the authors are riding on the coat-tails of a Conover and Chasko 1985 estimate of "wildlife acceptance capacity."

How does WS-ADC implement this? What is their policy? Where are their WAC counts for their year 2000 operations to kill and relocate?

1.3.4 Need for RCDGM to Protect Human Health

There are no data showing that there are any human health problems in Wisconsin attributable to Canada geese.

Some public swimming beaches in Wisconsin have documented a goose dropping per square foot of beach (J. Jackley, pers.com).

If this is a study, why is it not cited? Even if true (the authors cite a WDNR staff member - no title provided), this would not constitute a health hazard. Other animals also defecate in public places.

Over 400,000 people in Milwaukee, Wisconsin, during 1993 became ill with diarrhea from drinking water contaminated with Crypotosporidium spp. (CDCP 1995).

Maestrelli, Beckerman and Peterson are trying to leave the impression that this outbreak was caused by Canada geese. Otherwise, what is the purpose of this statement?

Fecal coliform bacteria from waterfowl, Canada geese in particular, have been linked to fecal contamination in Lake Washington near Seattle, Juanita Beach in Kirkland, Washington and Deep Creek Lake in Montgomery County, Pennsylvania (Anonymous 1998, Jamison 1998, Samadpour 1998).

To prove that geese were responsible requires very sensitive testing. The authors rely on a newspaper article when they could have provided the actual tests! Anonymous and Jamison are newspaper articles. Poor sources of scientific information. The Samadpour paper was not in your references when I examined them on May 23 and June 1, 2000. This was listed as a paper given at the American Society of Agronomy in Baltimore in 1998 and it appears not to have been published even in a conference proceeding. Poor source of scientific information. Did the genetic testing implicate the geese?

While transmission of disease or parasites from geese to humans has not been well documented, the potential exists. ...(Blandespoor and Reimink 1991). (page 10, para.2).

A review of Blandespoor and Reimink shows that mallards, wood ducks and common merganser were responsible for swimmer's itch in that study, but not Canada geese. So the authors choose to leave the impression of the potential for disease/parasite transmission. Also the authors seem to be asserting that swimmer's itch would justify the killing or relocation of Canada geese.

Severe cases of Chlamydiosis have occurred among wildlife biologists handling snow geese, ducks and other birds (Webeser and Brand 1982). Chlamydiosis can be fatal to humans if not treated with antibiotics. (Page 9, para. 4).

Maestrelli, Beckerman and Peterson are trying to leave the impression that people who live around Canada geese or walk in their feces could contract Chlamydiosis.

In fact, if this is true, then Wildlife Services is remiss by not reporting this to the Wisconsin Department of Natural Resources and alerting them of a serious hazard to hunters who would be handling the dead geese. Why are there no advisories to Canada goose hunters?

A sanctuary run by the Wisconsin Department of Natural Resources year round is that of Bay Beach Sanctuary at Green Bay, WI. Currently there are 6,000 geese. Have there been health problems associated with this sanctuary? No mention of Bay Beach Wildlife Sanctuary in this discussion.

In short, there is no data presented and no evidence to show there is a problem. It is very interesting that WS-ADC (page 5, para. 3) claims a mandate to safeguard public health and safety in Wisconsin. Why no statements from the public health officials in the EA? Why have public health officials neither found instances of health problems nor have they studied the issue? According to the Department of Health and Family Services Dr. Mary Proctor and John Archer, "There have been no reported outbreaks of human illness associated with Canada geese, nor do we have any confirmed reports of contact with Canada geese."

With regard to the health threats, the authors give no explanation on how this plan would in any way reduce the claimed threat to public health.

Noticeably, there is no assessment in this section of the health hazards WDNR and USDA WS-ADC would impose by feeding the geese to the poor and minorities of this state. The previous contaminant study by the WDNR was ignored. Why?

Gary Pearson, DVM, reviewed the current WDNR protocol (WS-ADC will conduct the round up and killing of the geese) for testing Canada geese for contaminants. Pearson states: ". "The obvious flaw in these guidelines is is the unsubstantiated assumption that

the targeted populations utilize the same habitats year after year and that the Department knows what those habitats are, where they are located and what contaminants are present, and it assumes that no geese from other areas with different contaminant exposures move in to occupy vacancies created in those habitats by the Departments' urban Canada goose control program." The authors try to sound the alarm with regards to human health hazards, but are completely unsuccessful. If the 'resident' geese are a human health hazard, then so are the 'migratory' geese in their review.

1.3.5 Need for RCGDM to Protect Human Safety

Regarding bird strikes, there is no data given in the EA to show any threat whatsoever in Wisconsin. Further, the instances cited do not distinguish between so-called "resident" Canada geese and other Canada geese protected under the Migratory Bird Treaty. Should we likewise be considering killing the Arctic migratory population? How does the airport population differ from summer to fall.

An e mail from Sandra E. Wright, USDA, and charts reviewed in Beckerman's files is instructive. MSP presumably refers to Minneapolist St. Paul Airport.

Subject. MSP goose strikes and significant strikes

Scott (Beckerman), There aren't many goose strikes for MSP , especially not at the airport. The reference for the NY NJ settlement of $5.3 million for a goose strike to the Air France Concorde in 1995 is "The Star Ledger" Monday, Nov 9, 1998. This is a New Jersey paper. The name of the Manager of Airside Operations at MSP is John Ostrom (612) 726-5780. He is very nice to deal with. His e-mail is j ostrom@mspmac. org. Let me know if you want a copy of the article from the Star Ledger. I can fax it. Sandy

Author Beckerman apparently did not request the Star Ledger. It was not on file. However, there was some data in charts. See Appendix B. From 1990 to 1999 at KMSP (Minneapolis St-Paul?) there were 6 instances in which a plane hit 2-10 geese. The rest (11) of the instances involved 1 goose. In four of the 6 instances of multiple hits, there were four precautionary landings. In only three was there substantial damage in nine years. Nine of the 18 reports were from October to February, so presumably they were or could have been Arctic nesting geese.

With regard to the injury to the Fond du Lac woman, I had the opportunity to read the report in its file regarding this woman. Other than the medical report, there appears to have been no investigation of the circumstances surrounding the alleged attack.

With regard to both bird strikes and "attacks", there is no evidence presented whatsoever that any of the plans presented by WS-ADC would reduce the bird strikes or attacks. Are the authors recommending management options (lethal?) of all the Canada geese "resident" and "migratory"?

Need for RCGDM to Protect Property and Quality of Life

Research on human landscape preference has revealed that we have a strong predilection, some assert an innate preference, for savannas with water. Cooper (In Press). Cooper also reported that like humans, but evolutionarily much earlier, Canada geese evolved to use the savanna landscape because the setting offered ample foraging opportunities, a high predator detection likelihood, and ready escape into nearby water. This preference for similar habitats has resulted in the increasing level of conflicts between humans and resident Canada geese. (Page 11, para.3).

So, in Mr. Cooper's opinion, it appears that we must change our genetic make-up or that of the Canada goose. The authors' management options do not include this consideration.

Sadly, Maestrelli, Beckerman and Peterson give no significant data to support a need to kill or relocate Canada geese except the notoriously inaccurate and unverified ADC Annual Tables. (1992-99). Ron Kokel, US Fish and Wildlife Service Office of Migratory Birds has said "ADC doesn't verify, only reports." Maestrelli, Beckerman and Peterson do not explain in their narrative the general claims of damage to crops. Some of these claims may be filed in anticipation of reimbursement for crop losses, but the only assertion of crop losses is $31,401. If there is damage and nobody reports it or claims a loss, what is the urgency to solve an undocumented problem?

But Maestrelli, Beckerman and Peterson make no claim that even if all the geese were killed in Wisconsin that this loss would not occur. Further, they do not distinguish damage made by the Arctic migratory Canada geese or in fact other birds.

1.3.6 Need for RCGDM to Protect Natural Resources

There is no evidence presented that Wisconsin or any "natural resources" have been harmed by the Canada geese. The only source of documentation is the rather suspect and self serving American Association of Wildlife Veterinarians. No data is presented. The WS-ADC is poised to carry out the "health testing" program of the WDNR during relocation of juvenile Canada geese. According to Gary Pearson, DVM,

"The Wisconsin Department of Natural Resources' May 9, 2000, Guidelines for Health Testing of Urban Goose Gosling Relocation are based on a test menu selected for technical ease and convenience rather than epizootiologic significance. All of the diseases listed on the test menu already are enzootic in migratory waterfowl populations and none of them poses a threat for "severe health impacts on waterfowl in recipient wetlands." Because the proposed health testing program considers only contagious diseases in urban Canada geese scheduled for translocation but not in the waterfowl on the recipient wetlands, and because all of the diseases listed already are present in migratory waterfowl where they do not cause significant disease problems, the proposed health testing program will provide no useful or relevant information."

1.4 STAKEHOLDER INVOLVEMENT IN RCGDM DECISION MAKING PROCESS

1.4.1 Prior Citizen involvement in Addressing Resident Canada Goose Damage Management

The process of citizen involvement in addressing urban waterfowl conflicts began in 1996 with the Wisconsin Urban Waterfowl Task Force (UWTF). This approach has been used successfully in contentious or complicated wildlife management situations in New York, Minnesota and other states.

Maestrelli, Beckerman and Peterson did not note that the UWTF was considered the Urban Waterfowl Task FARCE. Stacked with "stakeholders" including the WDNR, Animal Damage Control, USFWS, hunters, 3 of fifteen members represented environmental, welfare and rights groups. As a member of that task force (see my minority report, as well as that of Scott Diehl, Wisconsin Humane Society), I can testify that no data was provided to the Task Force to support any community emergency or serious injury to crops or other interests by Canada geese. In fact, at the last moment, the DNR switched the question to read "waterfowl" rather than Canada geese that had been the subject of complaints and impressions by the task force members. The WDNR engineered consensus in the majority to not present any speakers with opposing viewpoints, either regarding the so-called health issues, or regarding the welfare of the geese themselves and the harm to their well being of the lethal control measures. "We have heard enough" the task force said after they had heard the WDNR, WS-ADC and USFWS present their assertions and claims.

The list of complaints at the Task Force, as outlined by Maestrelli, Beckerman and Peterson are: fecal contamination of lawns, etc., water quality concerns, aggressive behavior, interference with...picnics, aircraft safety concerns, excessive concentrations increasing risk of avian disease, erosion and site damage. The task force heard no data, only "concerns". The wording of this statement shows that undocumented concerns are the WS-ADC's claim to support lethal measures for the Canada geese.

The Urban Waterfowl Task Force report, together with two minority reports, is not cited in the references, though the authors tell the readers how they can get a "nearly complete" transcript on cassette tape.

The authors are correct that there was a successful task force in New York. The Town of Clarkstown, badgered by the NY game agency, rejected the Task Force Report for two years. Finally, a new town council was elected (on this issue) and the Town Council reversed its lethal practices.

I know of no such task force in Minneapolis. Regrettably, the authors never provide any reference to any of the three task force reports.

The UWTF represented a wide range of interests including...animal rights, animal welfare, wildlife educators. (page 12, para. 3).

Maestrelli, Beckerman and Peterson want the public to think that animal rights, animal welfare, and wildlife educators were in concurrence with the lethal measures. They were not! This assertion by the authors in indefensible and deceptive. It should be noted here that the Task Force had a gag order on any press releases or communication with the public via the media. This was in response to my press releases alerting the public to this secretive (but nominally open public) meetings.

1.4.2 Community Based Decision Making

...WS provides technical assistance regarding the biology and ecology of Canada geese ...

If WS has the capacity to do this, why are we not seeing the evidence of their knowledge of biology and ecology in this report?

...and reasonable methods available to the local decision maker(s) to reduce wildlife damage. This includes non-lethal and lethal methods.

It appears that non lethal methods are always deficient and lethal methods are efficient. Your literature review cites Heinrich and Craven that show that non lethal methods were successful in eliminating geese from an area. Swift shows that border collies were successful in keeping geese off lawns and parks. This is particularly important since these are game agency staff who have been involved in the promotion of lethal measures. Why is their own data discounted?

1.4.2.3. Private Property Decision Makers

Affected resource owners who disagree with the direct damage management assistance may request WS not conduct this action on their property and WS will honor this request.

How have the objecting residents been contacted? The experience of the Coalition is that WS ADC kills on request. Further, WS ADC has been very secretive about its current plans, so I doubt very much if objecting neighbors have ever been contacted. A request for documentation of these claims was not acknowledged by Mr. Maestrelli.

Note in 1.4.2.3, WS-ADC makes it appear that residents have a veto power ("honor this request") over other residents who want to kill or relocate. The key words however are "on their property." The inference is that affected resource owners are contacted and the request is discussed. It should be noted that geese can be manipulated into coming onto the permittee's property by placing grain next to a trap.

Mr. Maestrelli refused to provide any documentation that even by policy or procedure, that affected resource owners are contacted.

2.3 ISSUES ADDRESSED IN THE ANALYSIS OF ALTERNATIVES

2.3.4 Humaneness and Animal Welfare Concerns of Methods used by WS .

Pain and suffering, as it relates to WS damage management methods, has both a professional and lay point of arbitration. Wildlife managers and the public would be better served to recognize the complexity of defining suffering since "...neither medical or veterinary curricula explicity address suffering or its relief" (CDFG 1991)

...Therefore, humaneness, in part, appears to be a person's perception of harm or pain inflicted on an animal, and people may perceive the humaneness of an action differently. The challenge in coping with this issue is how to achieve the least amount of animal suffering within the constraints imposed by current technology and funding.

WS-ADC resolves this ethical dilemma by defining humaneness as a human opinion and leaves the relocator/killer's in charge because they are "experienced and professional." The authors cite no other textbooks (medical or veterinary) to demonstrate their claim that the issue of suffering is not addressed. Note: CDFG is the California Department of Fish and Game and the subject is bear hunting.

As a practical matter, the WDNR protocol for health testing, to which WS-ADC has not to my knowledge objected, requires juvenile geese in Fond du Lac, West Bend, Cedarburg and other cities to be caged for two weeks, separated from their parents, while the diagnostic tests are run before they are shipped out to the Vilas Flowage or other undetermined locations to be left where they admittedly will be exposed to a higher rate of death than if they had been left in their parks and ponds. The Coalition has documented relocations where geese were stuffed in trucks without ventilation or water. The Coaltion has documented relocations so traumatic that many geese died. The Coalition has documented holding of geese that were left in open cages over the Fourth of July next to fireworks and firecrackers. The response of the Migratory Bird Coordinator, Steve Wilds, when this was reported was "They are used to the sound of gunfire."

Gary Pearson, DVM, has written of this health testing protocol:

"...the proposed testing is of little value, except perhaps to fabricate a deception that the Department is performing meaningful monitoring of health hazards posed by urban Canada geese to support its urban Canada goose control program."

2.4 ISSUES CONSIDERED BUT NOT IN DETAIL WITH RATIONALE

2.4.1 Appropriateness of Preparing an EA (Instead of an EIS) for Such a Large Area

An EIS is required, further an EIS for each site is required.

2.4.3.1 Effects on Human Health from Consumption of Canada Geese

2.4.3.2 This should have been discussed under Environmental Impacts. In spite of efforts of the WDNR and the USDA WS-ADC to ignore the probable effects of consumption of Canada geese by poor and minority populations, this is a significant (intended) omission. The EA does not discuss the study the WDNR did in 1997. Why was it ignored here? Why does the WDNR have a permit to kill 100 Canada Geese for contaminant testing if the environmental impact does not merit full discussion? I requested a copy of the protocol for the testing and was given a one-page set of guidelines. Why is all this done by local officials? Who is in charge of this effort?

2.4.4 The Relationship Between Canada Goose Restoration Efforts and Current Resident Canada Goose Conflicts

The trans-location of resident Canada geese within Wisconsin has not led to the increase in resident Canada goose conflicts with people.

The deception here is that the authors omit the "increase in resident Canada goose conflicts with people" outside Wisconsin. The trans-location to other states has caused an increase in population and has caused - in the opinion of the game bureaucrats in Missouri - an increase in conflicts between geese and people. Also, Figure 4 indicates that there have been "conflicts" in Barron, Rusk, Sawyer, Taylor, Clark and Marathon County. Isn't this the area where you are trans-locating juveniles? Is the University of Minnesota releasing geese in this area? Does the Minnesota DNR have "lure" fields in and around Minneapolis that might be having an impact on the population in Wisconsin. Might you want to do an overlay of the "lure" fields, trans-locations and the complaints in western Wisconsin?

I note the authors did not discuss Cooper's study regarding the Minneapolis St. Paul airport. In a memo recovered under the Freedom of Information Act, John Ostrom, MSP claims that in spite of the removal and killing of geese at the airport, who questions why there are many geese at the airport in spite of the University of Minnesota goose programs. He states "Why are we seeing an increasing number of geese at MSP, when all of Dr. Coper's data shows that the number of geese around the airport are being kept at a level of 95 +-% below that of 1984?" The possibility that the continued planting of grain to feed to "migratory" birds around the Minneapolis St. Paul area is part of the problem, not to mention the ineffective killing programs.

Once again, the lack of EIS on the restoration projects has caused significant problems. It is for this reason that we sought to have an analysis of this done in the scoping stages of this EA. The EIS, if the current EA is not abandoned, should provide a serious study of the current restoration efforts.

2.0 ALTERNATIVES

3.1 DESCRIPTION OF ALTERNATIVES

Technical Assistance:

Technical assistance is usually provided following a verbal consultation or an on-site visit to determine the nature and history of the problem, extent of damage, and identification of the species responsible for damage.

My review of the files showed that in two years, there was only one site visit. The reports, full of scribbles so that they are unreadable, indicated in a check box that there was never any verification of the cost of damage, and only in one instance an on site review. Permits are recommended for issuance or renewal without a site visit or other verification. When I spoke to Mr. Kiefer, Director of Parks at Fond du Lac recently, I asked if WS-ADC had done a site visit. He hesitated, then said yes. When I said there was no report on file, Mr. Kiefer responded that WS-ADC (he didn't say who) had done it on "his own time."

Technical assistance, at least for Canada goose complaints, would be a joke if it were not so serious.

3.1.3 Alternative 3:; Non-lethal and Technical Assistance RCGDM Only by WS

Sometimes referred to by some individual or organizations as Alternative G, Alternative 3 would disallow any lethal direct damage management assistance by WS.

Alternative G is the preferred alternative. There are no genuine alternatives in this EA such as Alternative G would provide.

ENVIRONMENTAL CONSEQUENCES FOR ISSUES ANALYZED IN DETAIL

4.0.2 Effectiveness of Methods of RCGDM

4.1.2.1. Alternative 1 Integrated Wildlife Damage Management/RCGDM Program (Proposed Action)

This alternative would be more effective that the current program or any of the other alternatives...based on research in the Minneapolis-St. Paul Metropolitan Region of Minneapolis, can slow population growth and even reduce the size of a goose population (Cooper B, in Press).

It is questionable whether Maestrelli, Beckerman and Peterson read the Cooper paper. Only the abstract was available in the referenced I reviewed and the state office refused to provide it for me as required by law. The careful wording of the assertion in 4.1.2.1 suggests that the authors are unconcerned about how well the poop is cleaned up in the softball field in Fond du Lac, but rather in reducing the overall population at the same time there are restoration efforts going on, field of grain increasing exponientally and absolutely no plans - not even any data - on how to reduce the goose poop on the fields.

4.1.3.1 However, waterfowl hunters may benefit by harassment activities in urban/suburban areas that cause Canada geese to move and expose them to harvest.

This is an interesting hypothesis and worthy of consideration. The effect of hunting on the location of the population of Canada geese is not examined scientifically in this document. If harassment causes geese to move from city to field, wouldn't hunting (lethal harassment) cause geese to flee from field to city? The negative effects of the present management schemes should be addressed, perhaps by your own National Wildlife Research office.

4.1.3.2 Alternative 2: Technical Assistance RCGDM Only by WS (No Action)

...under this alternative lethal management would not be prohibited because individuals experiencing conflicts with resident geese would still be eligible to receive permits allowing lethal management from the USFWS.

These options are not mutually exclusive. Hunting is allowed in all measures and relied upon as strategy to reduce Canada geese. Further, not all the options are made. It is only meant to be the illusion of non lethal or no action alternatives.

SUMMARY AND CONCLUSIONS

The "Environmental Assessment: Management of Conflicts Associated With Non-migratory (Resident) Canada Geese in Wisconsin Environmental Assessment: Management of Conflicts Associated With Non-migratory (Resident) Canada Geese in Wisconsin" is fraught with problems: lack of scientific evidence, deliberate falsification of issues and facts, evasiveness on the part of bureaucrats to answer questions, failure to provide all the references in the list. The EA fails to genuinely involve the public; it fails to address the substantive issues; it fails to examine all options. All the options provided should be rejected (and Alternative G implemented) and the entire EA abandoned as hopelessly defective. Should you proceed with the EA, please initiate an Environmental Impact Statement.

Further you will have to require site-specific Environmental Impact Statement for each location where WS-ADC, in the future, plans to kill or relocate Canada geese.

I request that until John Doe 1(Farm Bureau) v Glickman (the federal preliminary order that has placed a gag order on WS-ADC revealing the list of "cooperators") has been resolved, I request that you reject any applications for relocation or killing of Canada geese and that you refuse to participate in the killing of geese for contaminant testing under WDNR.

I request that you reject any applications for relocation or killing of Canada geese until a national and scientifically-based Environmental Impact Statement has been issued together with all the site-specific EIS. I request that you reject any applications for relocation or killing of Canada geese until notification to affected and interested parties has been made and there has been genuine dialog with the public on these proposals.

I request to have a copy of your final report.

Sincerely,