January 7, 2002

Docket No. 01-013-1
Regulatory Analysis and Development
PPD, APHIS
Suite 3C71
4700 River Road Unit 118
Riverdale, MD 20737

Comments on Proposed Blackbird Poisoning by the United States Department of Agriculture

Docket No. 01-013-1 Protection of Sunflowers from Red-Winged Blackbird Damage in North and South Dakota

Dear Wildlife Services:

On behalf of Audubon's one million members and supporters, I am writing to express our continued opposition to Wildlife Services (WS) proposal to poison and kill millions of red-winged blackbirds in the Dakotas. The comments below seek changes in the scope of the environmental impact statement (EIS) being prepared to analyze the potential environmental effects of reducing blackbird damage to ripening sunflowers in North and South Dakota. The proposed scooping document and request for further comments are set forth in the December 6, 2001 Federal Register.

We are particularly concerned about the limited alternatives that the proposed EIS will consider. The three alternatives WS proposes to analyze in detail in the EIS are all based on the premise that killing millions of red-winged blackbirds is the primary solution to reducing damage to sunflower crops in the area. We believe this is a flawed premise as outlined in our earlier comments. Previous killing of millions of blackbirds has not been justified on economic or scientific grounds and has not solved the problem for the sunflower growers.

We request that two additional alternatives be considered fully. Both are reasonable alternatives, and without considering them the WS is not meeting its obligations under NEPA.

First, the EIS should include a full analysis of a blackbird insurance program. While existing programs may be inadequate or not within the jurisdiction of WS, the environmental impact statement should examine ways this alternative could be made viable. The insurance program could be modeled on other insurance programs such as hail insurance. There is no requirement that EIS alternatives be limited to actions currently within the jurisdiction of WS.

Further, the EIS should include a full analysis of the alternative of the Department of Agriculture assisting farmers with developing alternative crops and/or providing farmers with advice about not planting sunflowers near typical blackbird roosting areas. Too often it is the same sunflower fields that receive the blackbird damage year after year. This is analogous to rebuilding in a flood plain year after year. Full evaluation of this reasonable alternative would make the EIS more effective as an aid to the decision-makers here.

Finally, we also urge you to address fully the concerns and issues raised by the U.S. Fish and Wildlife Service.

Thank you for the opportunity to continue to provide input into the process which will allow the decision-maker to make an informed decision on the important issue of whether to poison and kill millions of red-wing blackbirds to protect sunflowers in the Dakotas. We urge you to undertake a full and effective environmental analysis of the matter, and to end the blackbird-poisoning program.

Sincerely,

Lois J. Schiffer
Senior Vice President, Public Policy