U.S. FISH AND WILDLIFE SERVICE (FWS) ATTEMPTS TO FORMALLY
REMOVE MBTA "PROTECTIONS"
Disturbingly, the US Fish and Wildlife Service is attempting
to turn its authority over to the states in two instances: with regard to "resident" Canada
geese and double-crested Cormorants. The FWS released two Draft Environmental
Impact Statements (DEIS) on the management of Cormorants and Canada Geese
respectively in which they favor the alternative that would allow state game
make decisions unilaterally. Wildlife Watch does not want to see that happen.
To the end of protecting Cormorants and asking for a review
of the FWS, we arranged a meeting with the aides of Senators. Clinton and Schumer
with Wildlife Watch, the Fund, and the local Audubon Society in Albany, NY.
The reason we chose Albany, instead of NYC, is that it showed an upstate constituency.
NYC is an easy vote for Democrats but not so Upstate. The following letter
was drafted by Andy Mason for concerned organizations whose input was given
at the meeting, the last paragraph (added by Wildlife Watch and accepted by
all) is of UTMOST IMPORTANCE:
US Senator Hillary R. Clinton
March 8, 2002
Dear Sen. Clinton:
We are writing on behalf of our respective organizations to seek your assistance
in addressing an important pending environmental and wildlife issue. Our groups
represent a combined membership of over 7
million individuals, with over 500,000 in NY State.
The US Fish & Wildlife Service (USFWS) has recently released
a Draft Environmental Impact Statement on management of Double-crested Cormorants
nationwide. Cormorants are a native, non-game, colonial waterbird ranging across
North America and Mexico. They are protected under the Migratory Bird Treaty
Act of 1918 (MBTA), our nation’s basic bird protection statute.
USFWS proposal would result in the killing of over 200,000
cormorants annually-10-20 % of their population—in addition to permitting
the lethal practice of egg oiling of many thousands of cormorant nests.
proposal would allow killing of cormorants at their night roosts in 12
southern states, and perhaps most importantly, delegate management authority
cormorants to the states, other federal agencies, Indian tribes, and
their agents, without
retaining significant oversight.
The unsupported rationale put forth by the USFWS for embarking
on this assault on cormorants is the perception that recent cormorant
population increases are impacting sportfishing opportunities, the aquaculture
and other bird populations. The Service has received heavy pressure from
special interest groups representing commercial charter boat operators,
tourism interests, elected officials and others to "do something about
cormorants". However, sound science does not support significant
This action would set a dangerous precedent in managing our native wildlife
resources. Rather than basing its determinations on factual evidence,
USFWS has succumbed to these pressures and put forth a plan that is contradicted
by its own studies and research. Prior to preparing the DEIS, the Service
commissioned a study and literature review that is heavily referenced
the document. "The
Status of the Double-crested Cormorant in North America", Wires, et. al.
(2001), and the DEIS itself state that cormorant population increases may well
be merely a return to historic levels, following a century of pollution, persecution,
and habitat loss. If anything, this is a positive sign of a healthier environment.
Also, the Wires report and other studies clearly show that fish sought by sport
anglers make up a very small (<1.5%) proportion of cormorants’ diet,
and that cormorants have an insignificant impact on the forage fish used
sport fish. Recent catch reductions cited by anglers are a result of
less nutrient loading of waterways, introduction of exotic species such
zebra mussels, overfishing, and other factors unrelated to cormorants
and other fish-eating birds.
Canada Geese: Not only are they persecuted by the Fish and Wildlife Service
and State Game Agencies, but as you can see above, they are often subjected
to sadistic individuals. This goose was found in a park in Montana with
an arrow in her back.
Photo Credit: Pat O’Neill, Butte, Montana
We thank Gregg Feigelson for posting the above photograph.
Similarly, the DEIS fails to make a compelling argument for controlling cormorants
at aquaculture facilities. Disease, not cormorants, is the primary cause of
mortality and financial loss in aquaculture. If control is needed at certain
aquaculture locations, there is a range of effective non-lethal techniques
In essence, the Double-crested Cormorant, an abundant, uncharismatic,
fish-eating species, is being scapegoated to placate an angry, vocal
group that cannot see below the surface of the water. If this approach
all of our fish-eating birds-herons, egrets, Bald Eagle, loons, pelicans,
terns and many others, could be at risk of similar "management".
In addition, by handing off its authority in this matter
to the states and other agencies, the USFWS is avoiding its statutory
responsibility to " . . conserve, protect, and enhance fish, wildlife and plants and
their habitats for the continuing benefit of the American people".
This is indicative of an increasing tendency for Service management to
science and its own field staff in making its decisions.
The public comment period on the Cormorant Management
DEIS ended Feb. 28, 2002, and the Service anticipates a
final decision by this summer. We have urged the Service to adopt Alternative
action, or Alternative B-non-lethal management, in the Final EIS. This
would allow continued consideration and determination on cormorant conflicts
a case-by-case basis, and would retain the USFWS’ important role in overseeing
control of these birds.
We ask that you review this matter and communicate to the
Director of the US Fish & Wildlife Service the need to use facts
and science in establishing its policies, and seek a fair and unbiased
cormorant plan, consistent with the MBTA and the bilateral treaties with
foreign nations on which this statute is based.
Further, we urge that you give consideration to a full and
thorough review of the Service’s overall management and direction in recent
years, including its willingness to recommend and apply non-lethal solutions
to human-wildlife conflicts. The importance of this agency’s independence and
integrity in preserving and protecting our nation’s natural legacy cannot
Michael Markarian, Executive Vice President,
The Fund for Animals, Inc.
John W. Grandy, Ph.D., Senior Vice President,
The Humane Society
of the United States
League of Humane Voters
Wildlife Watch, Inc.
Please see Waterfowl, for
more letters and Schumer’s action!