Dr. Gary Pearson

May 30, 2000

Dear Mr. Maestrelli:
I would like to request that the following comments be included in the official record of public comments on the May 2, 2000, (Pre-Decisional) Environmental Assessment for Management of Conflicts Associated with Non-migratory (Resident) Canada Geese in Wisconsin prepared by United States Department of Agriculture, Animal and Plant Health Inspection Service, Wildlife Services.

SUBVERSION OF THE PUBLIC PARTICIPATION PROVISIONS OF THE NATIONAL ENVIRONMENTAL POLICY ACT
Your May 2, 2000, cover letter inviting public comments on the Environmental Assessment sets a deadline of June 2, 2000, for comments to be provided to your office. A month clearly is not sufficient time for the public to learn of the availability of the Environmental Assessment, to request and receive copies, to read the 59-page, single spaced, 10-point print document which Wildlife Services likely spent months to prepare, review relevant scientific literature and other information, draft comments and submit them to your office. It is abundantly clear, therefore, that, rather than complying with its mandate under the National Environmental Policy Act to promote and facilitate public involvement in evaluating the environmental impacts of the proposed Resident Canada Goose Damage Management program, Wildlife Services is imposing arbitrary restrictions deliberately designed to thwart meaningful public participation in the process. On this basis alone, the Environmental Assessment must be rejected as failing to meet compliance with the National Environmental Policy Act.

FAILURE TO PROVIDE SUBSTANTIVE ANALYSIS OF THE ENVIRONMENTAL IMAPCTS OF THE PROPOSED ACTION AND ALTERNATIVE ACTIONS
The Environmental Assessment is fatally flawed by its failure to provide an objective, factual and substantive analysis of the alleged "conflicts with resident Canada geese throughout the State of Wisconsin" upon which the proposed action is based. Except for the statements on page 11 that damage to agricultural crops caused by Canada geese are appraised on less than 0.04% of farms in Wisconsin and totaled $31,401 in 1999, the Environmental Assessment provides no factual information to substantiate, validate and quantify the "damage" alleged to be caused by Canada geese in Wisconsin. Indeed, although Figure 6 in Appendix C indicates that resident Canada geese have caused from $14,400 to $31,400 per year in damage to agricultural crops in Wisconsin form 1997 through 1999, no information is provided to validate these claims.
Without factual and objective data to substantiate, validate and quantify the alleged conflicts and damages resulting from Canada geese in Wisconsin, the Environmental Assessment fails to establish a need or justification for the proposed action or the alternatives considered, and it fails to provide any substantive or meaningful description, discussion, evaluation or analysis of the impacts or efficacy of the proposed action or alternatives in alleviating the conflicts and damaged alleged to be caused by resident Canada geese in Wisconsin. Because of the constraints imposed by Wildlife Service's inadequate and unrealistic public comment period, the potential human health risk allegedly posed by resident Canada geese will be considered here as an example of this fundamental deficiency of the Environmental Assessment. The other alleged justifications for the proposed Resident Canada Goose Damage Management Program will be addressed briefly.

Need for Resident Canada Goose Damage Management to Protect Human Health
The Environmental Assessment states on page 7 that, "Increasing populations of. . . resident geese are resulting in. . . increasing concerns related to human health." On page 8, it states that resident Canada geese conflicts "negatively impact human health" in several ways, and that "[w]aterfowl can threaten human health through fecal matter when contaminated water or fecal droppings are ingested or by inhalation of causative organisms." On pages 8-10, the Environmental Assessment then discusses six "pathogens involving waterfowl which may be contracted by humans." On page 30, the Environmental Assessment asserts, without substantiation, that, "The current program has failed to adequately protect human health. . .," The Environmental Assessment then states on pge14 that, "The EA evaluates resident Canada goose damage management by WS to protect human health. . .," and on page 18 that, "The effectiveness of each alternative can be defined in terms of decreased potential for health risks. . ."
It is relevant to note that "human health concerns" and "public health risks" allegedly posed by resident Canada geese are mentioned frequently and prominently throughout the Environmental Assessment as major justification for the proposed action. In fact, nearly two full pages (8-10) are devoted to discussion of the "Need for RCGDM to Protect Human Health," compared with less than one page (10-11) to discussion of the "Need for RCGDM to Protect Human Safety," less than one page (11) to "The Need for RCGDM to Protect Property and Quality of Life" and two brief paragraphs (page 12) to the "Need for RCGDM to Protect Natural Resources." It is appropriate and instructive, therefore, to consider these alleged "human health concerns" and "public health risks" in greater detail.
Cryptosporidiosis
The first disease for which resident Canada geese are alleged to pose a human health risk is cryptosporidiosis. Cryptosporidia are ubiquitous protozoan parasites belonging to the coccidia group, and various species are know 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 epidemics 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 humans and other 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 by sophisticated filtration systems.
The statements in the Environmental Assessment that (1) resident Canada geese negatively impact human health, (2) waterfowl can threaten human health through fecal contamination of water, (3) several pathogens involving waterfowl may be contracted by humans, (4) "Cryptosporidiosis is recognized as a disease with implications for human health." and (5) "Over 400,000 people in Milwaukee, Wisconsin during 1993 became ill with diarrhea from drinking water contaminated with Cryptosporidium spp." are combined to imply that resident Canada geese represent a significant threat to human health as a result of fecal contamination of water supplies with cryptosporidia. However, this implication is categorically false and grossly misrepresents the epizootiology of cryptosporidiosis.
As pointed out above, Canada geese are not infected with C. parvum, the species pathogenic for humans, and cryptosporidiosis in humans results either from direct human-to-human transmission or contamination of water supplies with feces of domestic mammals or human sewage. Consequently, there is absolutely no evidence that the 1993 Milwaukee cryptosporidiosis epidemic was in any way related to resident Canada geese any other wild or domestic waterfowl.
According to the Environmental Assessment:

"The public is advised to be careful when swimming in lakes, ponds, streams and pools, to avoid swallowing water while swimming, and to a void touching fecal matter (Colley, 1976).

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 indicate in any way that waterfowl are a source of Cryptosporidium infection in humans. Therefore, this statement in the Environmental Assessment seriously misrepresents the scientific literature it cites.
Similarly, the Environmental Assessment asserts that:

"Canada geese in Maryland were shown with molecular techniques to disseminate infectious Cryptosporidium parvum oocysts in the environment (Graczyk et al. 1998)."
However, examination of the paper by Garczyk et al. (1998) discloses that it really said:

" Cryptosporidium parvum is unable to establish intestinal infection in birds [citation 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 [citation 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 those oocysts in the environment, including drinking water supplies."
Thus, the study shows that domestic livestock were the source of the C. parvum oocysts ingested by the Canada geese, but that passage through the digestive tracts of geese removed up to 75% of the oocysts. Although Canada geese might have the potential to disseminate infective 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 resident Canada geese would 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. In any event, the situation described in the paper by Graczyk et al. where migratory Canada geese were observed following behind domestic cattle and eating undigested corn directly from their feces represents an extreme level of exposure to C. parvum oocysts that is not representative of the environments in which resident Canada geese generally occur.
It is important to note that the Environmental Assessment 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 a microscopic parasite that has become recognized as one of the most common causes of waterborne disease in humans in the United States and that it is contracted by swallowing contaminated water or putting anything in your mouth that has touched the stool of an infected animal or person are true. However, the subsequent statement that:

"Giardia sp. oocysts were present in the feces of Canada geese in Maryland (Graczyk et al. 1998) and may have serious implications for the contamination of watersheds (Upcroft et al. 1997 In Graczyk et al. 1998. Davidson and Nettles 1997, Smith et al. 1997)."
seriously misrepresents the evidence regarding the role of Canada geese in the epidemiology of human giardiasis.
First, giardiasis is the most commonly diagnosed 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 per ownership is a significant risk factor for giardiasis in humans (Taboada and Merchant, 1995).
Wobeser (1997) does not list Giardia among the diseases of wild waterfowl, and Garczyk et al. (1998) simply reported the presence of Giardia sp. cysts in the feces of migratory Canada geese, and 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."
It should also be noted t hat their citation for their statement that avian Giardia cysts are potentially a danger for humans is a report of an isolation from a wild-caught sulphur-crested cockatoo.
The Environmental Assessment states that:

"The Wisconsin WS program has been contacted by the public inquiring if they could get giardiasis from geese."
but it does not does not cite any evidence that they could.
The Environmental Assessment cites absolutely no credible scientific evidence to support its implication that resident Canada geese are a significant source of Giardia infection for humans, but instead attempts, through unsubstantiated speculation and unfounded insinuation, to create the impression that resident Canada geese "may have serious implications" for transmitting Giardia to humans.
Salmonellosis
The statement that:

"Salmonella can be contracted by humans handling materials soiled with bird feces (Stroud and Friend 1987).
is not an accurate representation of the epidemiology of salmonellosis in humans and it is a gross misrepresentation of the risk for humans contracting salmonellosis from resident Canada geese.
First, salmonellae are found in a large variety of mammals, birds, reptiles and insects (Greene, 2000). From 1 to 36% of dogs and from 0 to 14% of cats have been reported to be infected with Salmonella (Green, 2000). 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, 1997).
Second, 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." (Emphasis added.)
Moreover, 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 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.
Finally, it should be noted that Friend (1999a) points out that:

"Wild bird surveys have often been concurrent with studies of this disease in poultry and as sources for human infection. These and other investigations have resulted in numerous strains of Salmonella sp. being isolated from free-ranging and captive wild birds. However, findings from these studies have also disclosed a much lower infection rate than anticipated and have caused numerous investigators to conclude that in general, salmonellosis is not an important disease of free-ranging wild birds."
and:

"The general level of Salmonella in most species of wild birds is low, but extra care with personal hygiene is warranted by people who handle these birds or materials soiled by bird feces. This consideration is not limited to situations where disease is apparent, and it extends to routine maintenance of birdfeeders, cleaning transport cages, and handling birds during banding and other field activities."
Thus, any risk that resident Canada geese might pose for transmitting salmonellae to humans would be exacerbated by activities involving the capturing, handling, transportation and processing for human consumption of the geese--the very activities that would be undertaken in the Integrated Wildlife Damage Management/RCGMD Program (Proposed Action) outlined in the Environmental Assessment. On the other hand, the risk posed by resident Canada geese for transmitting salmonellosis to the general public is less than that associated with maintaining feeders for songbirds.
Chlamydiosis
The Environmental Assessment states that:

"Chlamydia psittaci, which can be present in diarrhetic feces of infected waterfowl, can be transmitted if it becomes airborne (Locke 1987)"
However, it neglects to report that Locke (1987) also stated that:

"Direct contact with infected birds and inhalation of the causative organism in airborne particles are the usual routes of transmission of this diesase."
and Franson (1999) states that:

"Individuals who work in areas in which there is a strong possibility of inhaling airborne avian fecal material should consider wearing a mask or respirator. Dry, dusty areas with bird droppings can be wetted down with a 5 percent solution of household bleach, or a commercial disinfectant. Working with large numbers of birds in dusty, closely confined areas should be avoided as much as possible."
Of course, resident Canada geese are waterfowl and do not normally frequent dry, dusty areas, and few members of the public have direct contact with resident Canada geese or work with them in dusty, closely confined areas, so even if they were infected with C. psittaci, any public health risk would be minimal.
It should be noted that Locke (1987) also pointed out that:

"Chlamydiosis has been found worldwide in feral rock doves [pigeons], in gulls and northern fulmars on islands of coastal Great Britain, in waterfowl and shorebirds on the Caspian Sea, and in herons and waterfowl throughout the United States. Infected parrots and parakeets have been found through the tropics and Australia."
In fact:

"Seventy percent of the 1,025 [human] cases [of chlamydiosis] 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. 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 also become infected. . ." (Emphasis added.) (Anderson et al., 1997)
The Environmental Assessment asserts that:

"Severe cases of Chlamydiosis have occurred among wildlife biologists handling snow geese, ducks and other birds (Wobeser and Brand 1982)."
and:

"Infection of chlamydiosis is usually thought of in association with pet birds, domestic pigeons or poultry, but there have been a number of recorded instances involving wild birds (Wobeser and Brand 1992)."
However, Wobeser (1997) states that:

"The only human cases directly related to wild waterfowl that I am aware of involved C. J.Brand and myself. We both required hospitalization after necropsying Lesser Snow Geese and Sandhill Cranes (Wobeser and Brand, 1982)."
Thus, the Environmental Assessment again seriously misrepresents, exaggerates and distorts the risk of transmission of chlamydiosis from resident Canada geese to humans.
On the other hand, it is the very control program proposed in the Environmental Assessment involving the capture, euthanasia and processing of geese which would represent the greatest public health risk for humans contracting chlamydiosis from resident Canada geese in Wisconsin. For other people in the area, however, the risk of contracting chlamydiosis from domestic and cage birds is far greater. The Environmental Assessment cites absolutely no evidence that resident Canada geese pose a risk for transmitting chlamydiosis to anyone in Wisconsin except perhaps those who might be implementing the proposed control program and those handling or consuming the processed geese.
Avian tuberculosis
According to the Environmental Assessment:

"There have been many cases of Mycobacterium avium, or avian tuberculosis transmitted to people (Roffe 1987). Most humans are considered highly resistant to avian tuberculosis except those with pre-existing diseases of the lungs or whose immune systems are impaired (Roffe 1987).
Roffe (1987) also pointed out that:

"The prevalence of tuberculosis in free-living waterfowl has not been determined, although generally less than 1% of birds examined at postmortem are affected."
Friend (1999b) states that:

"Studies in the United States disclosed that 0.3 percent of 3,000 waterfowl necropsied were infected with tuberculosis. . ."
Of course, birds examined at postmortem generally are those that have died of some disease, so the 0.3-1% figure simply reflects the percentage of mortality attributed to avian tuberculosis rather than prevalence of tuberculosis in waterfowl populations which are comprised primarily of healthy individuals.
Although tuberculosis is relatively common in captive waterfowl, the prevalence is higher in ducks and swans than in geese (Wobeser, 1997). However, Wobeser (1997) points out that:

"Tuberculosis appears to be most prevalent in species, such as House Sparrows and Starlings, that live in close association with livestock and in scavenging and raptorial species."
In addition, human M. avium infections are most common in patients with acquired immunodeficiency syndrome (AIDS) (Thoen, 1997).
The Environmental Assessment has cited no evidence that resident Canada geese in Wisconsin have a significant rate of M. avium infection or that they pose a significant public 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 Environmental Assessment would reduce any such risk that might exist from resident Canada geese.
Escherichia coli
After noting that E. coli are fecal coliform bacteria associated with fecal material of warm blooded animals, that over 200 serotypes have been identified, the majority of which are harmless, that the pathogenic E. coli O157:H7 serotype which produces serious human infections is associated with cattle, the Environmental Assessment states that:

"Resident Canada geese may also create a disease threat (i.e., coliform bacteria) to bathers using beaches, ponds, and lakes where excessive numbers of geese defecate (Anderson 1998.)"
However, examination of the Literature Cited discloses that the citation for Anderson 1998 is not a scientific report documenting E. coli infections in humans acquired from using beaches, ponds and lakes where excessive numbers of resident Canada geese have defecated, but rather simply a newspaper story from the June 18, 1998, edition of The Atlanta Journal-Constitution.
In fact, there is no credible scientific evidence that resident Canada geese pose a public health risk of E. coli infections to bathers and other using beaches, ponds and lakes where they occur. For example, in chickens, only 10 to 15% of intestinal coliforms belong to serotypes potentially pathogenic for birds (Gross, 1991). In addition:

"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.)
Therefore, without evidence that E. coli from resident Canada geese are pathogenic for humans, there is no evidence to support the statement in the Environmental Assessment that resident Canada geese pose a threat to humans using areas where they occur.
To put the public health threat posed by the presence of E. coli from resident Canada geese found on beaches, ponds and lakes used by humans into perspective, it should be noted that from 0.5 to 6.0% of eggs from normal hens contain E. coli (Gross, 1991), and these are routinely brought directly into kitchens where they frequently are incorporated into foods without cooking.
Although avian E. coli from resident Canada geese may complicate interpretation of the significance of fecal coliform counts in surface waters, that does not in itself constitute a public health threat, but rather simply reflects a deficiency in common public health protocol and procedures for monitoring surface waters which rely on fecal coliform counts as an index of risk to humans from fecal pathogens. Consequently, although the Environmental Assessment cites reports linking fecal coliform bacteria from waterfowl to fecal contamination in lakes in Washington, Pennsylvania and New York, it cites no evidence that fecal coliform bacteria from waterfowl pose a public health risk for humans, and it acknowledges that "potential health threats in Wisconsin are unknown."
After two pages of discussion of the public health threat posed by resident Canada geese and although still arguing that, "While transmission of disease or parasites from geese to humans has not been well documented, the potential exists," even the Environmental Assessment is forced to concede that "the risk of infection is believed to be low" and "the probability of contracting disease from fecal droppings is believed to be small." In fact, the Environmental Assessment has not cited a single documented case of transmission of disease from resident Canada geese to humans.
Rather than dealing with the public health issue in a factual, objective, honest and responsible manner, the Environmental Assessment couples misinterpretation and misrepresentation of the scientific literature with unwarranted speculation to fabricate unfounded insinuations regarding hypothetical threats to human health from resident Canada geese. The lack of rational foundation for the Environmental Assessment's assertion that resident Canada geese pose a threat to human health invalidates this section of the Assessment, as well as the principal justification for the Resident Canada Goose Damage Management Program that is proposed.
The section of the Environmental Assessment alleging a Need for RCGDM to Protect Human Health should be deleted and replaced with the statement that there is no credible scientific evidence that resident Canada geese pose a significant threat to public health.
As noted on page 2 above, the Environmental Assessment claims to "evaluate resident Canada goose damage management by WS to protect human health" and it states that, "The effectiveness of each alternative can be defined in terms of decreased public health risks." However, not only does the Environmental Assessment fail to provide any credible evidence that resident Canada geese pose a significant public health risk, but it makes no attempt what-so-ever to evaluate the resident Canada damage management by WS to protect human health or to define the effectiveness of each alternative in decreasing the public health risks that are alleged. Consequently, the Environmental Assessment fails entirely to deal with the issue of public health threats posed by resident Canada geese in the substantive and responsible manner required of Federal agencies by the National Environmental Policy Act.

Need for Resident Canada Goose Damage Management to Protect Human Safety
The Environmental Assessment cites a gross estimate of $245 million damage to civilian and military aircraft each year from "bird strikes" and states that waterfowl comprise 35% of all bird-aircraft strikes and 16% of bird-aircraft strikes where civil aircraft were damaged. It says that, except for gulls, no other bird species cause as many damaging bird-aircraft strikes as waterfowl, and it points out that three Canada goose-aircraft collisions at airports in New York resulted in over $15 million in damage during 1995 and one the collisions with an Air France Concorde resulted in a lawsuit and eventual $5.3 million settlement against the Port Authority of New York and New Jersey and the John F. Kennedy International Airport. It mentions that in 1995 an Air Force AWACS jet taking off from Elmendorf Air Force Base in Alaska hit a flock of geese and crashed, killing all 24 crew members and destroying the $184 million airplane. Finally, it states that at least 13 goose strikes have occurred to aircraft in Wisconsin since 1992. What the Environmental Assessment fails to do, however, is show that any of these reported bird-aircraft strikes involved resident Canada geese, or that resident Canada geese pose a significant threat to aviation in Wisconsin. Consequently, the Environmental Assessment fails to demonstrate that the proposed Resident Canada Goose Damage Management Program would have a significant impact in reducing bird-aircraft strikes in Wisconsin, and it fails to consider the alternative of limiting control activities to those specific locations where resident Canada geese are demonstrated to pose a legitimate risk to aviation.
The Environmental Assessment states that, "WS records show that goose attacks on people are fairly common occurrences during the nesting season and can result in injuries." However, it cites only two incidents where people were reported actually to have been injured as the result of "attacks" by resident Canada geese, and one of these is based on a personal communication and the other is based on a newspaper story. The Environmental Assessment does not disclose whether the injuries actually were inflicted by the geese or whether they were the result of the actions of the alleged victims. To put these "attacks" by nesting Canada geese into perspective, it should be noted that more than one million people per year in the United States report dog bites and it is estimated that 10 people die in this country each year as a result of dog bites (Overall, 1997). Although many people are intimidated by the defense displays of nesting Canada geese, the Environmental Assessment provides no credible evidence that resident Canada geese pose a significant threat to human safety by "attacking" people in Wisconsin.
Finally, the Environmental Assessment resorts to claims that the build-up of fecal material from geese on docks and walkways creates a slipping hazard and that geese straying onto highways create traffic hazards, but it fails to mention that fecal material from other birds, such as gulls, also accumulates on docks and walkways and that domestic dogs, cats and deer cause far more frequent traffic hazards.
Not only does the Environmental Assessment fail to provide substantive evidence that resident Canada geese pose a significant human safety hazard in Wisconsin, but it again fails totally to evaluate resident Canada goose damage management by Wildlife Services to protect human safety or to determine the effectiveness of each alternative in terms of decreased human safety hazards.

Need for Resident Canada Goose Damage Management to Protect Property and Quality of Life
The Environmental Assessment cites complaints of soil erosion and other damage to landscaping, piers, boats, beaches, shorelines, parks, golf courses, driveways, athletic fields, ponds, lakes, rafts, porches, patios, gardens, foot paths, swimming pools, swimming pool shower facilities, play grounds, school grounds and cemeteries as examples of property damage caused by resident Canada geese. However, it makes no attempt to validate or quantify the damages attributed to resident Canada geese, and it concedes that the majority of the complaints are related simply to the goose "droppings." Although some people may find goose feces esthetically offensive, this rises, at most, to the level of a nuisance, rather than property damage or a significant reduction in the quality of life. In fact, goose feces is no more offensive than the cow and sheep manure that many home owners purchase in bags to spread on their lawns and gardens.
The Environmental Assessment states that:

"Nutrient loading has been found to increase in wetlands in proportion to increases in the numbers of roosting geese (Kitchell et all 1999, Manny et al 1994)"
but it neglects to mention that the reports cited deal with migratory geese that tend to range over larger areas and not with resident Canada geese that tend to feed in the same watersheds as the wetlands they occupy. As the Environmental Assessment acknowledges, "Scherer et al. (1995) stated that waterfowl metabolize food very rapidly and most of the phosphorous contributed by bird feces probably originates from sources within a lake being studied." The Environmental Assessment makes no attempt to compare nutrient loading of urban ponds and lakes from resident Canada geese with other sources within those watersheds, including other wildlife and domestic animals, home septic systems, and the runoff of fertilizes from lawns and golf courses. It also does not consider the impacts on urban wetlands of other chemicals, including insecticides and herbicides, applied to lawns and gold courses.
As noted above on page 1, the Environmental Assessment states that damage to agricultural crops totaling $31,401 in 1999 was appraised on less than 0.4% of the farms in Wisconsin. It provides no data demonstrating that resident Canada geese cause significant damage to agricultural crops in Wisconsin except in isolated incidents, and it does not consider the alternative of simply compensating farmers for documented losses caused by resident Canada geese.

Need for Resident Canada Goose Damage Management to Protect Natural Resources.
The only natural resource issue related to resident Canada geese mentioned in the Environmental Assessment is an alleged disease threat posed to migratory waterfowl, where it states, without substantiation, that:

"In large concentrations, resident Canada geese can create a reservoir for disease and may pose a health risk to migrating waterfowl."
The Environmental Assessment does not cite a single documented instance where resident Canada geese have been shown to pose a health threat to migrating waterfowl. Indeed, the concentrations of migratory Canada geese at the Horicon National Wildlife Refuge and other areas in Wisconsin are orders of magnitude larger than any "concentrations" of resident Canada geese, and even those have not been demonstrated to pose a health risk to migrating waterfowl.
The statement that:

"Tens of thousands of migratory waterfowl have been killed in single dieoffs, with as many as 1,000 birds succumbing in a day (Friend and Franson 1987)."
neglects to tell the reader that mortalities of these magnitudes in migratory waterfowl have been reported only for diseases such as botulism, which is not a contagious disease (Wobeser, 1997), and avian cholera and duck plague, both of which are enzootic in migratory waterfowl populations (Botzler, 1991; Pearson and Cassidy, 1997; Wobeser, 1997). The Environmental Assessment does not cite a single documented case where resident Canada geese have been responsible for transmitting a disease to migratory waterfowl, let alone for killing tens of thousands of migratory waterfowl. Indeed, none exist.
The only substantiation provided by the Environmental Assessment for its claim that resident Canada geese may pose a health threat to migrating waterfowl is an unsubstantiated 1993 resolution by the American Association of Wildlife Veterinarians stating that:

". . . the AAWV encourages local authorities and state and federal agencies to cooperate to limit the population of waterfowl on urban 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."
It is important to note, however, that the AAWV resolution cites no evidence to support the implication that limiting the populations 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. . ."
Because those diseases and parasites already are enzootic in free-ranging wild ducks, geese and swans, the resolution fails to provide any evidence that semi-domestic ducks, geese and swans pose a significant risk for introducing them into wild waterfowl populations.
The significance of this lack of documentation for the AAWV's resolution on urban waterfowl is demonstrated by the similar Resolution on the Control of Duck Plague which the organization adopted on August 9, 1993. The resolution had been drafted by the U. S. Fish and Wildlife Service's National Wildlife Health Center in Madison, Wisconsin, to support its controversial recommendations in a duck plague epizootic at Venice, California, and it called for the destruction of all exposed semi-domestic and feral waterfowl in order to prevent the spread of duck plague to wild waterfowl populations (Anonymous, 1993). However, when the Wildlife Disease Association, which had adopted the same resolution the preceding day (Barrows, 1994), was asked to identify the scientific foundation for the premise that duck plague is not enzootic in wild waterfowl, it was unable do to so, and the Wildlife Disease Association subsequently rescinded the resolution (Howerth, 1998; Pearson, 1999). When the same information was requested from the Fish and Wildlife Service under the Freedom of Information Act, the Service was unable to cite any scientific evidence to support its claim that duck plague is not established in wild waterfowl populations.
Not only does the Environmental Assessment cite no credible scientific data to support its assertion that resident Canada geese create a reservoir for disease and may pose a health threat to migrating waterfowl, but it, again, makes absolutely no attempt to evaluate resident Canada goose damage management by Wildlife Services to protect natural resources or to define the effectiveness of each alternative in terms of decreased damage to natural resources.
Humaneness of Lethal Resident Canada Goose Damage Management Methods used by Wildlife Services
The Environmental Assessment states that:

"In situations where geese are being captured alive by use of drive nets or by hand to test for contaminants known to be harmful to humans, the birds would be euthanized by methods approved by the AVMA (Andrews et al. 1993) (e.g., cervical dislocation, CO2 gas). Most people would view AVMA-approved methods of euthanizing animals as humane."
The Environmental Assessment fails to mention, however, that even Andrews et al. (1993) point out that cervical dislocation may not result in immediate unconsciousness, and that the Ornithological Council's 1997 Guidelines to the Use of Wild Birds in Research emphasize 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)
Thus, contrary to the assertion of the Environmental Assessment, AVMA approved methods of euthanizing animals cannot automatically be assumed to be humane for birds.
Effects on Non-target Wildlife Species and Populations, Including Threatened and Endangered Species. Alternative 1: Integrated Wildlife Damage Management/RCGDM (Proposed Action)
The Environmental Assessment states under 1.8.2.5 Investigational New Animal Drug (INAD) that:

"The drug alpha-chloralose has been used as a sedative for animals and is registered with the U. S. Food and Drug Administration (FDA) to capture waterfowl, coots, and pigeons. FDA approval for use under INAD (21 CFR, Part 511) authorizes WS to use the drug as a non-lethal form of capture. The drug can only be purchased from WS."
and here it states that:

"The only method described in the proposed action that could be employed by WS and which has the potential for non-target take is the oral tranquilizer drug AC. There is potential to capture some non-target wildlife such as American coots, Common grackles, or house sparrows with AC, but they can be released unharmed upon recovery. A formal risk assessment of WS methods showed no probable risk from primary (e.g., from AC treated baits) or secondary (e.g., from scavenging on birds that have eaten AC treated baits) exposure to AC, and determined no hazards to water resources (UDSA 1994: Appendix P, p. 181-184)."
It should be noted that 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 also is relevant to note that, because of the drug's narrow therapeutic index and margin of safety (with mortality rates from 2.5% to 37% in target species), the difficulty in delivering 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 dispersed from the bait site before they are immobilized and becoming vulnerable 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 its being considered a satisfactory immobilizing agent for Canada geese and flatly refute the Environmental Assessment's claim that it poses no probable risk to non-target species from primary or secondary exposure.

CONCLUSIONS
Wildlife Services' May 2, 2000, (Pre-Decisional) Environmental Assessment For Management of Conflicts Associated with Non-migratory (Resident) Canada Geese in Wisconsin fails to discuss the conflicts associated with resident Canada geese in Wisconsin in a substantive, objective, factual and responsible manner, it seriously and repeatedly misinterprets, misrepresents and distorts the scientific literature related to resident Canada geese, it grossly exaggerates the threats to human health and public safety and the damages to property and natural resources resulting from resident Canada geese in Wisconsin, and it fails totally to describe, discuss, evaluate or analyze the efficacy of the proposed Resident Canada Goose Damage Management program in reducing the alleged threats to human and public safety and damages to prperty and natural resources.
Because the Environmental Assessment does not address the justification or efficacy of the proposed Resident Canada Goose Damage Management program in a substantive or responsible manner, it fails, on its face, to meet the statutory requirements of Section 102 (C) of the National Environmental Policy Act. Moreover, the Environmental Assessment demonstrates a clear and pervasive attempt by Wildlife Services to misrepresent the issues and distort the facts to justify pre-formed conclusions and decisions.
Because the Environmental Assessment itself reveals significant flaws in the proposed Resident Canada Goose Damage Management program and raises clear and disturbing questions about Wildlife Service's ability and commitment to address them in a substantive and responsible manner, the only acceptable option remaining is the preparation of a full environmental impact statement on the proposed program, with all of the required and appropriate provisions for review and comment by the public and other agencies.
I trust that these comments will assist Wildlife Services in meeting its statutory responsibilities under the National Environmental Policy Act for addressing the environmental impacts of its proposed Resident Canada Goose Damage Management program in Wisconsin.
Sincerely,
Gary L. Pearson, D.V.M.

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Coalition to Prevent the Destruction of Canada Geese