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
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
I mention the following to point out that Flyway
meetings include an informal public relations component. While
I didnít personally witness the discussions for the management of public
opinion with regard to "resident" Canada geese, Iíve 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
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
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
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
were dramatically affecting the lives of wild animals in their
service of a small special interest group. A biologist for the
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
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
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
they can no longer make the long trips back to the ancestral nesting
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 countryís 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 nationís wildlife from manís 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. Shouldnít
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
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
wasnít 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
if the number of predators werenít reduced by trapping and hunting.
If snapping turtles werenít shot by local game agents, if the Flyway
didnít initiate and endorse a rampage against mute swans, if stray
dogs and cats werenít 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 Ė the Serviceís preferred alternative - will allow
for the worst decisions to be made for wildlife. It is an illegal
of the mandate of the Fish and Wildlife Service; it would deprive
wild geese of any protection at all. States will succumb to local
and there will be no higher decision made for
them. Geese will be destroyed merely at the whim
of homeowners or municipalities who donít want to trouble themselves
to apply the non-lethal alternatives. This should not be aided,
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
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
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
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
[Editorís Note: It did not go un-noted that Alternative
G Ė General Depredation Order Ė 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
protectors would have given full protection to
individual geese and to the species. The majority of respondents
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.