From Jane Clark at [log in to unmask]
++++++++++++++++++++++++++++++++++++++++++
"Written comments must be received by March 6, 2000....
Please write today or tonight. Comments received late are usually
considered so don't hesitate to write late.
++++++++++++++++++++++++++++++++++++++++++
Phil Mastrangeleo is in charge of the Environmental Assessment, entitled,
"Spring Blackbird Damage Management Project for the Protection of Ripening
Sunflowers":
email: [log in to unmask]
Phil Mastrangelo
USDA-APHIS-WS
2110 Miriam, Suite A
Bismarck, ND 58501-2502
ph: 701.250.4405
fax: 701 250 4408
>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>
I thought you might be interested in the letter from National Audubon. You
could use these points in your letter.
From Dan Beard, National Audubon Society
Honorable Dan Glickman
Secretary of Agriculture
#200-A
Department of Agriculture
14th St. and Independence Ave. SW
Washington, DC 20250
Dear Secretary Glickman:
I am writing to request that you immediately end the blackbird research
program by the Animal and Plant Health Inspection Service, a program based
on dubious science and economics that poses a lethal threat to some of the
most threatened birds in America-- grassland songbirds. APHIS proposes to
kill two million blackbirds migrating through North and South Dakota this
spring with poison rice, and as many as six million blackbirds over the
next three years, or 25% of this migrating blackbird population.
There does not appear to be any scientific or economic justification for
this program. Indeed, the little science that is known indicates that the
poison is non-target specific. Bird surveys show 68 bird species in or
near the poisoned bait areas including nine species of federal management
concern. Eight of these bird species are on National Audubon's national
Watch List Species and three more bird species are on the state Audubon
Watch Lists for North and South Dakota.
According to your own Department's information, "superficial surveys of
agricultural fields often overestimate blackbird damage and thus exaggerate
the overall severity of the economic threat." Furthermore, "during the
past two decades, studies on blackbird damage to various crops such as corn
and sunflowers indicate that on statewide or regional level, overall damage
is low, generally 1 to 2 percent of the crop."
The publication also points out that the blackbirds to be killed feed
primarily on insects. What are the consequences on humans and crops of
eliminating 25% of the population of these efficient insect predators with
Agriculture Department's proposed research project?
The blackbird poisoning and killing has been an escalating research project
since 1994. The Department has been killing an estimated 250,000 to one
million blackbirds a year for the past six years. What is the
justification of increasing the scale of the proposed blackbird killing
this spring, which seems to clearly shift this effort from a research
program to an operational program.
The blackbird killing program is seriously questioned by the U.S. Fish and
Wildlife Service, the North Dakota Game and Fish Department, and the South
Dakota Department of Game, Fish and Parks. Attached are their comments on
the blackbird killing program.
In perhaps the ultimate irony, some of the crops the blackbirds are being
killed to protect are grown for bird seed. Mr. Secretary, the Animal and
Plant Health Inspection Service research program to kill 25% of the
blackbird population moving through the Dakotas does not even meet the
common sense test.
Thank you for your attention to this matter. On behalf of National Audubon
Society's one million members and supporters, we urge you to halt the
blackbird poisoning program.
Sincerely,
Daniel P. Beard
Senior Vice President for
Public Policy
National Audubon
====
More background and talking points provided by
Michael Melius, of Prairie Hills Audubon Society, Hermosa, SD
===
The birds targeted for poisoning in spring are not necessarily the ones
that cause damage in sunflower fields in the fall. APHIS is planning to
poison flocks near roosts in SE SD in the spring. There's very little
research done on where those flocks eventually nest, but what research
there is suggests they nest in Canada, and are therefore not a problem in
the U.S. What little research exists on the birds doing damage in the
Dakotas and MN indicates those birds are flocking and roosting in Missouri
in the spring.
APHIS is supposed to target only animals doing damage, not just randomly
kill animals in the hope they'll get some problem animals in the process.
If they can't demonstrate a connection between the problem birds and the
birds poisoned, their EA is flawed from the outset.
Their study methods are flawed. They're going to observe some fields in
northern SD in the fall to see if there are fewer birds. But they aren't
going to control variables, and can't, the scale is so big.
Another problem is that the EA doesn't consider the environmental effects
of so many dead birds, probably falling into a marsh where they roost. (The
poison is a rather slow killer, 1-3 days.)
Another key issue is non-target species. Since the poison kills slowly,
it's hard to find the dead birds, which die away from the poison site. So,
it's difficult to assess how other species are affected. We just don't
know.
Non-target species include Whooping Cranes, all of which migrate through
SD, and during the poison season. Their main flyway is just west of the
poisoning site, but not far. There will be more birds of other species
mixed in with those flocks--including Brewer's Blackbird and Rusty
Blackbirds. Among the collateral kills could be substantial numbers of
WatchList species like Yellow-headed Blackbirds and grassland sparrows.
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