August 17, 2001

The Honorable Ann Veneman
Secretary
United States Department of Agriculture
1400 Independence Avenue, SW
Washington, D.C. 20250

Dear Secretary Veneman:

On behalf of National Audubon Society’s one million members and supporters, I am writing to request that you immediately end all aspects of the blackbird poisoning program in North and South Dakota proposed by the Animal and Plant Health Inspection Service (APHIS). This program is not based on sound science or sound economics and poses a deadly threat to some of the most severely declining birds in America—grassland songbirds. Additionally, I request that you review the appropriateness of all blackbird-poisoning programs throughout the country currently being conducted or proposed by APHIS.

APHIS is proposing to kill two million blackbirds with poisoned rice in North and South Dakota each spring for the next three years. The goal of the program is to kill six million blackbirds, the equivalent of 25% of the migrating blackbird population in the region.

1. The Dakotas

The blackbird-poisoning program in the Dakotas should be terminated for the following reasons:

1. There is no scientific justification for this program. The blackbird poisonings that have been conducted by APHIS in the Dakotas from 1994 to1999 did not demonstrate that mass killing of blackbirds is effective in reducing sunflower damage. The U.S. Fish and Wildlife Service stated in a January 7, 2000 letter to APHIS North Dakota office that: "The APHIS/ADC’s went forward with fall control efforts that ignored the results of your research and have proved not only to be ineffective but inefficient" (letter attached). The Fish and Wildlife Service denied a previous APHIS request to kill two million blackbirds. The Fish and Wildlife Service cited lack of scientific evidence that the poisoning achieved the goal of reducing sunflower damage (FWS letter March 31, 2000).
2. There is no economic justification for this program. According to "Controlling Blackbird Damage to Sunflower and Grain Crops in the Northern Great Plains", a Department of Agriculture publication: "During the past two decades, studies on blackbird damage to various crops such as corn and sunflowers indicate that on a statewide or regional level, overall damage is low, generally 1 to 2 percent of the crop." Furthermore, "superficial surveys of agricultural fields often overestimate blackbird damage and thus exaggerate the overall severity of the economic threat" (Agriculture Information Bulletin No. 679 Revised June 1996).
3. The danger of killing non-target birds is not addressed. The Fish and Wildlife Service has documented 68 species of birds found in or near North and South Dakota sunflower fields in the spring. Thirty-two of the bird species are granivorous birds, as is the blackbird. The poison APHIS uses, DRC-1339, is designed to kill granivorous birds. The non-target birds threatened include grassland songbirds—some of the most severely declining bird species in America today. Eight of the birds are on Audubon’s Watch List (www.audubon.org). Nine species are of management concern for the federal government (FWS letter January 7, 2000). Despite evidence of non-target birds observed near the poisoned bait APHIS fails to address the killing of non-target birds to the satisfaction of the Fish and Wildlife Service (FWS letter March 31, 2000 attached).
4. The affects on wetlands from approximately 150 tons of bird carcasses have not been addressed. Raising the issue of avian botulism outbreaks in wetlands, the Fish and Wildlife Service said: "It is noteworthy that 2 million blackbirds with weights of 2 to 2.5 ounces could result in 150 tons or more of bird carcasses, which we presume will predominately end up in wetland habitats" (FWS letter March 28, 2000 attached).

The blackbird killing program has been and continues to be seriously questioned by state and federal agencies including the U.S. Fish and Wildlife Service, the North Dakota Game and Fish Department, and the South Dakota Department of Game, Fish and Parks.

The ultimate irony of the situation is that blackbirds are being killed to protect sunflowers that are being grown for birdseed. This massive slaughter of millions of birds on America’s prairie must end. 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.

1. The United States

We would also request that you review the efficacy of the all the blackbird-poisoning programs conducted by the Animal and Plant Inspection Service throughout the country. Blackbirds and other birds are being poisoned across America with taxpayer dollars with questionable scientific or economic justification and with little concern for the effects on other birds and the environment.

Thank you for your attention to this matter. Again, we urge you to halt the blackbird-poisoning program.

Sincerely,

Lois J. Schiffer

Senior Vice President, Public Policy