April 23, 2001

Docket No. 01-013-1
Regulatory Analysis and Development
PPD, APHS
Suite 3COS
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

Dear Wildlife Services:

On behalf of Audubon’s one million members and supporters, I am writing to strongly oppose the killing of millions of blackbirds as a means of protecting certain sunflower crops. Wildlife Services has failed to justify the blackbird poisoning and related activities on either scientific or economic grounds.

Nowhere does the proposal indicate that killing millions of blackbirds with poison would lessen the crop damage. The target flock of blackbirds is about 39 million birds. The proposal targets not more than 2 million birds per year. By reducing the flock by 5%, is the damage to the crop reduced by 5% or is it zero because there are still 37 million blackbirds?

Wildlife Services has not provided a cost/benefit ratio for the blackbird-poisoning program. Are the American taxpayers getting a fair return on their investment in the sunflower crop protection? Gannett News Service on April 19 outlined the cost of just several of the programs that are involved with the blackbird poisoning effort. Those programs alone ran into the hundreds of thousands of dollars. Is the poisoning effort costing as much or more than the value of the crops protected?

Wildlife Services has failed to demonstrate that the poison they are using will not kill other birds especially threatened bird species and other wildlife. Wildlife Services can not have it both ways saying that it is effective killing blackbirds but other birds will not be poisoned. The fact is that 68 species of nontarget birds have been observed in/or near sunflower fields in the spring. Thirty-two of these bird species are granivorous birds which like blackbirds are likely to be killed by the poison bait. This is especially true because these birds are under stress from migration with limited food choices making Wild Services poisoned banquet that much more tempting and deadly.

Audubon also strongly opposes the so-called nonlethal technique of using glyphosate herbicide (commonly known as Roundup) on cattail stands larger than 10 acres. In effect, Wild Services is proposing the killing of all vegetation in selected wetland areas. This sterilization of the cradles of some of the most productive wildlife habitat for birds, waterfowl, and animals simply defies common sense. What consideration has Wildlife Services given to the effect this significant destruction of critical habitat will have on birds and wildlife?

In the U.S. Department of Agriculture publication, Controlling Blackbird Damage to Sunflower and Grain Crops in the Northern Great Plains it is noted that the blackbirds to be killed feed primarily on insects. What consideration has Wildlife Services given the human, economic, and crop consequences of eliminating these efficient insect predators?

Simply put, the killing of millions of blackbirds by Wildlife Services is a waste of taxpayer dollars. Audubon supports the alternative of "no involvement by WS in sunflower protection." Wildlife Services cannot justify the poisoning of millions of blackbirds on economic or scientific grounds.

Sincerely,

Perry Plumart
Director of Government Relations
Senior Policy Advisor