Comments on the DEIS on Resident Canada Goose Management

The following comments were submitted by Wildlife Watch to the FWS on the DEIS on Canada Geese. We are publishing them for information, and for our readers to use as part of their arsenal in the battle against those who now have control over wildlife.

To: Chief, Division of Migratory Bird Management, USFWS, DOI, ms 634 ARLSQ 1849 C Street, NW, Washington, D.C., 20240

Having attended several Flyway meetings, specifically Atlantic Flyway, and joint meetings of the Atlantic and Mississippi Flyways, Wildlife Watch met the members of the Flyway Technical Division and the Council members who were making decisions about migratory waterfowl. We were able to observe the purpose and nature of “Flyway” meetings. What surprised us the most was the fact that migratory waterfowl are managed solely for purposes of hunting, not in the least for the pleasure of the general public. Contrary to public belief and, I might add, trust, migratory waterfowl are not at all managed for the benefit of the species or the individuals who comprise the species.

I mention the following to point out that Flyway meetings include an informal public relations component. While I didn’t personally witness the discussions for the management of public opinion with regard to “resident” Canada geese, I’ve no doubt that they were a part and parcel of the management process. In one of the “working groups,” decisions were excitedly being made to offer a bonanza to waterfowl hunters by basically doing away with bag limits for snow geese. Discussions led to the preparation of the general and environmentally conscious public to accept virtually unlimited hunting. The federal Flyway representative said he would create the press release which would be passed along to “their people” for publication in the newsletters of Defenders of Wildlife, Audubon, Nature Conservancy and the like. Soon afterward, articles began to appear in these publications, and in virtually every paper and magazine throughout the country about the need to have hunters reduce the population of snow geese that were allegedly “destroying their own habitat.” That interpretation is really a biological oxymoron.

I was prevented from using my video camera to film committee meetings. With the exception of scheduled “general meetings,” I did not bring my camera or recorder with me, but I did take copious notes. As I was leaving one evening, there being nothing more on the listing of meetings, I passed a room where a meeting was taking place and decided to stay. The unannounced meeting was about Canada geese. Needless to say, I was shocked when I witnessed an alcoholic beverage being passed to the members of the Technical Division of the Flyway Council. In attendance were the representative of the Canadian Wildlife Service (CWS) and the representative of the US Fish and Wildlife Service (FWS). The atmosphere was almost party-like and playful, yet surprisingly serious voting was taking place. I witnessed the bag limits becoming extraordinarily high for Canada geese. One representative was negotiating for a bag limit of 10 birds per hunter, per day! I also witnessed a vote that extended the hunting season far beyond the then allotted time.

My eyewitness accounts of this disgraceful and troubling evening were recorded in an affidavit that was filed as part of a lawsuit against the NYS DEC. I asked, after an hour of sitting and watching in disbelief, if they were cognizant of the fact that they were dramatically affecting the lives of wild animals in their service of a small special interest group. A biologist for the Cree Nation who was also in attendance was so outraged by the frivolous manner in which the sport hunting of Canada geese was decided, that he told me he would be advising the Cree to sue the Canadian government for inaction. The representative to the Council from the CWS acquiesced to all decisions made by the FWS and the states. This was particularly upsetting to the Cree because it was at a time when migratory populations were dramatically decreasing. The FWS and CWS said the decline was due to “climatic conditions.” Actually, the FWS and CWS knew that special hunting seasons were further cutting down the migrant populations.

Wildlife Watch has had confirmation that a percentage of “residents” once were migrants who fell victim to hunters and live with shot in them. Although they can fly to some extent, they can no longer make the long trips back to the ancestral nesting grounds.

In its March 4, 2002 News Release titled, “Service Releases Draft EIS on Resident Canada Geese,” the Service states that geese can denude grassy areas and degrade golf courses and water quality. No where in their consideration of the Canada goose “conflict,” were they concerned with what the pesticides used on golf courses, pollution of waters, monofilament fishing lines or wildlife management practices were doing to the geese and other wildlife. Although these agencies are mandated to protect wildlife – and the public believes that is what they are doing – pesticides, sewage, and chemicals flow unceasingly into the country’s waters, lands and air from homes and industries.

Photo by David Cantor, C.A.S.H. Member.

Should not the FWS be in the business of protecting the nation’s wildlife from man’s excesses and abuses, rather than killing wild animals for adding a biodegradable substance to a previously thoroughly degraded environment such as a golf course? In truth, the excrement of the goose helps to restore a bit of what we have poisoned. Shouldn’t the FWS be out of the golf course restoration service as it is a conflict of interest? As an aside, the golf courses that use the non-lethal method of border collies are doing quite well.

I find it puzzling that the FWS merely talks about “resident” Canada geese appearing and proliferating as though they had nothing to do with it. The FWS avoids disclosure of their breeding programs for Canada geese that were designed to create resident populations for hunting purposes. These programs were done with Pittman-Roberson funds, which is the dedicated excise tax on firearms and ammunition and bows and arrows. As of two years ago we were told by a manager who was involved that they were still on going in Western states. Further, the Montezuma National Wildlife Refuge bragged on its website only several years ago about its [resident] goose population and displayed a photograph of the Canada geese enjoying the refuge grounds during the spring and summer. In a call to a manager at the refuge, he said that they had in the recent past set out nesting boxes for the Canada geese but he wasn’t sure if they were doing it that year.

It is disingenuous of the Service to state that the population would automatically climb skyward without human intervention, when it is precisely human intervention that causes higher than usual populations. As only 33% of a Canada goose clutch hatches, as there are still predators and disease in many instances, environmental factors such as monofilament fishing line, pesticides, and degraded environment will limit the population of Canada geese.

The very obvious natural controls, natural predators: skunks, raccoons, snapping turtles, would keep the population of goslings and eggs down sufficiently, and would do so even more successfully if the number of predators weren’t reduced by trapping and hunting. If snapping turtles weren’t shot by local game agents, if the Flyway didn’t initiate and endorse a rampage against mute swans, if stray dogs and cats weren’t shot on site in management areas, surely there would be a decline of geese.

Unlimited numbers of goose, gosling, and egg predators are mercilessly and needlessly trapped in state programs encouraging trapping as a recreational activity.

Offering hunting opportunity should not be a goal of the FWS. The Service itself stated in its regulations that ten to twenty percent of migrating geese were among the “resident” populations during the special season, and these “special” seasons which are now par for the course merely exacerbate the decline of the “migratory” population for indigenous peoples who truly depend on the geese for food.

Alternative F – the Service’s preferred alternative – will allow for the worst decisions to be made for wildlife. It is an illegal breach of the mandate of the Fish and Wildlife Service; it would deprive wild geese of any protection at all. States will succumb to local pressures, and there will be no higher decision made for

them. Geese will be destroyed merely at the whim of homeowners or municipalities who don’t want to trouble themselves to apply the non-lethal alternatives. This should not be aided, abetted, or allowed by the Fish and Wildlife Service which has the mandate to protect these animals by the authority of the MBTA.

Alternative A, in our opinion, leaves the geese no better off, and does nothing to alter wildlife management agency practices.

Although Alternative B may have omitted addling (a lethal method) to dissuade some well-known goose protection groups from choosing it, Wildlife Watch believes that by holding to a wholly non-lethal alternative, those individual communities and entities which have applied for lethal depredation permits by falsely claiming to have tried non-lethal methods first, will be forced to diligently, responsibly, and honestly apply the non-lethal methods that are available. Further, companies and individuals will be encouraged to develop non-lethal methods and products causing more to be available; greater proliferation and purchase of the products will in time drive prices down.

By choosing Alternative B, the Fish and Wildlife Service will, for the first time in its history be treating individual wild animals as precious, giving the message that the individuals of a species are not merely to be “destroyed” at will for reasons that are often frivolous or fraudulent.

While Alternative B excludes addling, an alternative that our organization has “lived with” and at times promoted to appease those who find geese intolerable, we believe its exclusion will lead to a finer and more honest application of other methods as stated above. It may also cause states to eliminate trapping to allow for natural predation. Shooting domestic animals on wildlife state and federal management areas, the method of operation now, and trapping, will have to be stopped if this agency is to turn from the abuse of wildlife and become the true guardians of this precious gift on earth.

In Alternative B, the establishment of new positions, additional funding, reallocation of existing activities will be a welcome change from what we currently have. We would like to see funds and personnel used to help communities implement the non-lethal methods that are available, to encourage businesses to develop products, and to work to turn the nightmarish scenarios of hunting and round-ups into a dream of harmonious living with the wildlife that we have left on earth.

Wildlife Watch wholeheartedly supports and lauds Alternative B.

[Editor’s Note: It did not go un-noted that Alternative G – General Depredation Order – was added as a sadistic counter to the Alternative G conceived of and supported by the Coalition to Prevent the Destruction of Canada Geese. The Alternative G as proposed by wildlife

protectors would have given full protection to individual geese and to the species. The majority of respondents supported Alternative G. The FWS in the latest DEIS officially added an alternative G which they titled, “General Depredation Order.” Their Alternative G removes every protection that the geese have. The Alternative G of the FWS is out of the question!]

For more about Canada Geese, please see www.canadageese.org  the website of the Coalition to Prevent the Destruction of Canada Geese, a division of Wildlife Watch.