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Comments on the Draft Management Plan for Mute Swans in NYS

February 12, 2013

COMMENTS ON THE DRAFT MUTE SWAN PLAN (ELIMINATING ALL WILD MUTE SWANS) NEEDS COMMENTS BY 2/21/14.  Please see below.

Mute Swans

The draft Management Plan for Mute Swans in New York State is available on the DEC website. The mute swan is a non-native, invasive species brought to North America from Eurasia for ornamental purposes in the late 1800s.

Mute swans are most numerous on Long Island and in the lower Hudson Valley, but have expanded their range in recent years, especially around Lake Ontario. Mute swans can cause a variety of problems, including exhibiting aggressive behavior towards people, destruction of submerged aquatic vegetation, displacement of native wildlife species, degradation of water quality and potential hazards to aviation.

This draft management plan supports actions by DEC to eliminate free-ranging mute swans from New York by 2025, while allowing responsible ownership of these birds in captivity. DEC recently proposed listing mute swan as a "prohibited species" under new Invasive Species regulations, which would prohibit the sale, importation, transport, or introduction of this species in New York.

Comments on the draft mute swan plan may be submitted in writing through February 21, 2014 (please type "Swan Plan" in the subject line):

NYSDEC Bureau of Wildlife
Swan Management Plan
625 Broadway, Albany
NY 12233-4754
fwwildlf@gw.dec.state.ny.us 

See PDF of the text below.

Wildlife Watch, Inc.

P.O. Box, 562

New Paltz, NY 12561

Office: 845-256-1400

www.wildwatch.org; wildwatch@verizon.net

Toll free Hotline: 877-wild-help

In this draft plan, the Bureau of Wildlife (BOW) of the DEC proposes eliminating all mute swans by 2025.  BOW asserts that the mute swan is not native, is aggressive, destroys submerged aquatic vegetation (SAV), displaces native wildlife species, degrades water quality, and is hazardous to aviation.

The plan proposes entirely wiping out all free-ranging mute swans, in spite of the observation that the mute swan population in NYS has been stable over the past decade, and over a period of 110 years has grown to a total state population of merely 2,200 individuals.

In the section titled: MANAGEMENT GOALS AND STRATEGIES, Point 1, it is clear that one ultimate goal of the plan is the replacement of mutes with trumpeter swans.  BOW writes: As trumpeter swans…and tundra swans (both of which are native to North America) become more common in New York, they may satisfy some of the public desire to see free-ranging swans in NY, so outreach efforts will direct some interests to those native species.  The statement would give the impression that the population of trumpeter swans is naturally occurring.  However, building a free-ranging, breeding population of trumpeter swans is an orchestrated introduction of this species that was never native to New York State. 

One need only look at the website of the special interest group, the Trumpeter Swan Society, headquartered in MN, to learn its goals and affiliation with wildlife management agencies, and its persistent, aggressive, and, no doubt, well-funded demand to introduce this swan species throughout the United States, although it is well-documented that their breeding range never included eastern states.

Wildlife Watch opposes this plan which seeks to destroy the naturalized mute swans and further opposes the implementation of an introduction of non-NYS native swans, which is currently in progress. The trumpeter swan that BOW plans to replace for the mute has had its NY pedigree called into question by ornithologists Bill Whan and Gerry Rising, who challenge the literature used to claim that the trumpeter was established in the east.  They call the alleged science “salesmanship,” and “a stretch.”   http://www.acsu.buffalo.edu/~insrisg/nature/whan_essay.htm

Aside from not being native New Yorkers, there is no evidence that tundra and trumpeter swans will be at all different in the very aspects that are being used to condemn the mute swans.  All of the literature points to the fact that behavior and food eaten are the same for all swan species.  All swans eat SAV, all swans become protective during nesting and brooding periods, all swans fly, and all swans defecate.  In fact, the larger size of trumpeters ensures that they will require more food, and will defecate even more than their naturalized cousins.  Trumpeters also give small crustaceans and fish to their young, something mutes are not known to do.

BOW asserts that the “native” swan species stay in more remote areas and shun human contact, unlike the mutes.  However, their location will change as hunters begin to hunt trumpeters and tundra swans in remote areas, thus driving them to more populated areas where they will seek safety, as happens with Canada geese. 

BOW’s draft management plan incorporates so many “mays” and “coulds,” that it becomes a study unto itself in how to stay on the side of truth while propagandizing.  For example, it asserts that “Too much fecal matter [they assume ALL fecal matter is caused by mute swans, and not humans or other wildlife] MAY contribute to fecal coliform, which MAY be a concern to public health, and COULD affect shell fishing on Long Island.”  Such uncertainty expressed here indicates that mute swan fecal matter IS NOT a REAL concern.  We ask (rhetorically) if the poop from leaching septics, kids who swim in the water, dogs who play in the water, and huntable waterfowl who live in the water, is a politically sanitized poop that renders it of no concern?

The Draft Plan, in keeping with BOW’s wildlife management for hunting goals, naturally proposes allowing the hunting of mute swans, along with removing them for private enterprises.  Among those private enterprises are breeding, and likely licensed canned hunt operations in NYS, or for shipment to other states.  All this while trumpeters are being bred and introduced at two primary sites.  See: http://www.nybirds.org/KBsearch/y2007v57n1/y2007v57n1p2-8sherony.pdf  One site is the private 5,000 acre canned hunt facility called Savannah Dhu, which is owned by Robert Congel, a mall developer and large political contributor.  Among the people he has entertained at Savannah Dhu is Governor Andrew Cuomo going back to his days as a NYC housing official.  In addition to Savannah Dhu, there are canned hunt facilities in NYS where swans may be hunted.  Please visit this link if there is doubt that swans are hunted privately in NYS, and note that all are licensed by BOW: http://www.dec.ny.gov/docs/wildlife_pdf/spfactsheet.pdf

Swans, in general, due to their larger size will keep other waterfowl from nesting near them.  In fact, one way to keep Canada geese and ducks from nesting in a particular area is to allow mute swans to nest there.  That is unlikely to gain the approval of BOW as its goal is to keep waterfowl numbers up (including those of Canada geese) for hunters’ guns in the fall.  Waterfowl managers do not want huntable populations of waterfowl, including Canada geese, reduced by mute swans, although trumpeter and tundra swans will have the same impact as the mutes do now once they are introduced as free-ranging breeding populations.

As the Plan itself mentions, even without BOW’s effort to kill the swans, there are population controls already occurring, such as poaching, vandalism, starvation, disease, natural predation at the egg, cygnet, and adult stages of life, accidents, collisions with power lines, and flooding of nests.

On federal waterfowl management areas in NYS, and NYS wildlife management areas, population controls are minimized so as to yield the largest waterfowl populations.  On those lands, habitat and water manipulation favor maximum populations.  Further, within the management areas, wild animals are trapped, and even dogs and cats can be shot on sight for the threat they pose to waterfowl populations.

BOW’s Plan includes methods other than outright killing to reduce the population:  nest destruction, egg oiling, sterilization, pinioning of a wing, and removal to location where they will be confined.

There is no urgency for the extremist measures proposed by BOW that would quickly and immediately remove mute swans.  Letting “nature take its course” can take time.  If there is a conflict that must be resolved, then consideration also must be given to the individual swans who will be impacted.

Replacing mutes with trumpeters has been discussed at flyway meetings at the behest of the Trumpeter Swan Society and hunters for at least 20 years. I personally recall a committee meeting at which they discussed trying to find evidence that trumpeters were ever in the Atlantic Flyway so that they could legally proceed with a more palatable “REintroduction.”  When one waterfowl manager said he had found a citation that indicated there was a trumpeter spotted in the 1800s, they all seemed to breathe a sigh of relief!

Allowing the population to gradually be reduced by natural population controls, ending habitat manipulation on wildlife management areas, ending cooperative agreements with large landowners to allow their lands to be used for propagation, stopping the trapping of natural predators, allowing the swan population to keep the Canada goose population in check during breeding seasons, are all alternatives that should be used – and would be used if BOW were not managing wildlife strictly for hunting.

Preventing nesting in an area of potential conflict with people is far preferable to nest destruction, oiling some of the eggs but not all, and at the earliest possible time, will allow for a natural cue to the swan that she can leave the nest.  If all eggs are oiled, and all embryos die, the natural cue, caused by egg movement and hatching, never occurs, so the swan may become extremely weak from waiting.

Pinioning a wing irreversibly is tantamount to chopping off a human’s leg or arm.  Birds fly.  If impermanent pinioning is done to accustom a swan to a location for the sake of the swan that would be more acceptable.

While the DEC is a proponent of hydraulic fracturing (fracking), a process for extracting oil that is notorious for destroying drinking water - and for which there is plenty of data documenting the deadly consequences for every species that lives in a fracked area, -- it seems extremely hypocritical of the DEC to be so concerned over the few mute swans who eat SAV, thus proposing an extremist plan to kill them all.

Oblivious to its own discordance and misplaced concerns, BOW arrogantly lists the ways they should spend our tax dollars to convince us that 100% removal of mute swans is necessary, and must be done fast in order to protect the environment:  BOW suggests printing brochures to overcome what they call the lack of understanding by the public about why it’s important to kill or remove the mute swans.  They also suggest assigning staff to cooperate with “conservation [hunting] groups” in local areas and encourage municipalities to allow public and private areas to be used to kill and capture mute swans.

In Point 5 of the Plan, which on its surface seems benign, they suggest “Allow[ing] free-ranging mute swans to be taken and possessed by licensed persons.”  However, Wildlife Watch would object to this if the capture and possession were not in the best interest of the swans.  If the possessor is a wildlife rehabilitator, a park such as Popcorn Park in NJ, a place of sanctuary for the welfare of the swans, then we can accept Point 5 if the condition of the swan warrants it.  If, however, the purpose is to use the swans for canned hunt operations, for breeding, for sale to further exploit them, or for any purpose that does not benefit the individual swans, then Wildlife Watch opposes it.  Point 5 needs to be very carefully detailed, and necessitates far more transparency of purpose and scope than the Plan presently provides.

Finally, to whitewash the killing of mutes, BOW’s Plan proposes donating the flesh of mute swans to zoos and the “needy.”  This is risky business at best as the USDA does not inspect wild animal flesh.  As there is no control of the living conditions of the animal, the contaminants the animal has been subjected to in the environment, the food the animal has eaten prior to being killed, or the water they have drunk, they can offer no guarantees as to the quality of the meat.  Basically, a hunter inspection involves a quick look.

In 1996, the NYS Department of Health, Social Services and Ag & Markets were asked to approve deer flesh from a cull for distribution to the “poor and needy.”  They said, We cannot, and should not engage in selective enforcement of the law or establish separate standards of food safety.  The poor and homeless are entitled to receive the same level of health protections from government as those more fortunate…We do not take issue with hunters who choose to consume game meat which they have killed since they do so at their own risk.  However, the general public should not be exposed unwittingly to the potential food safety risks of consuming wild game which are ‘processed’ in this fashion.

BOW’s imprudent suggestion stands in stark contrast to a recent recall of 9 million pounds of meat because, according to the USDA, it was processed “without the full benefit of federal inspection.”

WE CALL UPON NY TO SPARE THE MUTE SWANS FROM DAMOCLES’ SWORD.

We call upon Mayor Bill De Blasio to keep our NYC owned property in the state safe for wild animals and for the public.  We urge him to keep our mute swans safe from BOW’s plans to rid the state of them.

Picture of three banded mute swans.

Majestic swans reduced to this sad state by BOW.  Photo is from BOW’s website: http://www.dec.ny.gov/animals/7076.html

IF OUR REGULATORS CAN NOT REGULATE, THEN OUR LEGISLATORS MUST LEGISLATE.

In the light of its plans to pass regulations to eliminate the free-ranging mute swan population, we ask that our NYS Legislature take active control over BOW that operates within the DEC.  Regulatory free rein has truly been a reign of terror against wildlife.  The only way the majority of people, the real public, not merely hunters, can ever have hope of taking back its wildlife from the firm grasp of BOW (a bureau tied to the firearms industry and in the business of killing wild animals) is to put BOW under legislative control.

There are many non-lethal methods that can be used to resolve “conflicts” with mute swans, if truly warranted.  A committee of independent, qualified, and unaffiliated (with hunting interests and free of entanglements with BOW) individuals should be set up to determine if there is such a need.

Wildlife Watch further urges the NYS Legislature to prevent BOW’s use of public funds to demonize the mute swan for the purpose of paving the way for acceptance of their removal and killing.

Mute swans are, in truth, among the most magnificent animals to grace our sad world. 

Send comments to CASH at CASH@abolishsporthunting.com and we will respond!

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E-mail: CASH@AbolishSportHunting.com
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